Last Updated: November 2, 2022
We will only use your personal data in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and used for limited purposes. This policy applies to information we collect, use or disclose about you on this website (the “Services”) or through any email, text or email between you and this website.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of the Services after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates
2. Personal Data We Collect About You
Personal Data means any information in respect of commercial transactions that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject. The personal data we collect about you includes the following:
- data that does not directly or indirectly reveal your identity, such as data regarding your use and interactions with the functionality of the Services, statistical and aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregate information from the personal data. For example, we may aggregate personal data to calculate the percentage of users that access a specific feature or the time they spend on the Services;
- login information (including your web3 wallet provider and public address), browser type and version, IP address, time zone setting, browser plug-in types and versions, operating system, platform, internet connection, equipment used to access the Service and usage details;
- usage analytics of the Services include how it is accessed, webpages visited, products viewed or searched for, page response times, length of time spent on certain pages, page interaction information (scrolling, clicks, mouse-overs);
- data regarding your digital asset wallet, its corresponding public address and any relevant transactions performed through it on public blockchains;
- feedback or information you provide to us through the Services or email relating to the Services.
The Services operate by communicating with a number of third-party public blockchains and other service providers that operate in the web3 space. We may collect personal data about you (as outlined in (a) - e)) from these blockchains and third-party services providers as may be required to operate the Services).
3. How We Collect Personal Data
We use different methods to collect your personal data, these include:
- direct interactions with the Services when you provide it to us. For example, when connecting your web3 wallet to the Services to use its functionality. When you carry on a transaction over the Services, details of the transaction will be recorded.
- automated technologies. As you use the Services, personal data may automatically be collected, including usage details, IP address, and information collected through cookies and other tracking technologies.
- from third parties and from publicly available sources. For example, we may collect personal data from service providers and public blockchains that are generally available.
We collect your personal data when you access the Services and utilize its functionality. We may collect your personal data from third-party service providers that integrate with the Services. Some ways we may collect your personal data include:
- Public Blockchains: If you access the Services through a public blockchain, we may collect personal data that is accessible from that blockchain and necessary to interact with your web3 wallet.
- Ethereum Data: If you access the Services using an Ethereum address, we may store the Ethereum Address and collect personal data associated with it.
- OAuth Authentication: If you access and use the Services using our OAuth functionality, your name, email and username from our OAuth functionality may be collected and stored.
We use user insight and analytics tools to continually improve the Services and learn what features and functionality are utilized by you and our other users. We collect your personal data when you spend time on the Services and utilize its features.
Sygma also collects your personal data when you:
- Use the Services to download any file, software, media or other content from it;
- Communicate with us through email, social media, phone or any other means; and
- Provide us with your name, email address or other identifying information through text message, email or other electronic means.
4.How we Collect Personal Data Through Automatic Data Collection Technologies
- Details of your visits to the Services, including traffic data, logs and other communication data and the resources that you access and use on the Services.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical information and may include personal data that you provide to us or that we receive from third parties. It helps us to improve the Services and to deliver a better and more personalized functionality, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Services according to your interests.
- Recognize you when you return to the Services.
The technologies we use for this automatic data collection may include:
- Flash Cookies.Certain features of the Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy
- Web Beacons.Pages of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
5. How We Use Your Personal Data
We use the personal data we collect about you or that you provide to us through providing the Services. We may use your personal data:
- To present the Services and its contents to you. We do not monitor or track personal data provided to the Services except as required by law.
- To provide you with the information, modifications to the Services, products and functionality you may request from us. Personal data may be used to provide a personalized experience and facilitate payments on the Services. To fulfil the purposes for which you provided your personal data or that we
- To fulfil the purposes for which you provided your personal data or that were described when it was collected, or any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts with you, including our Terms and Conditions, for Fees or to comply with legal requirements.
- To notify you about changes to the Services or any products or functionality we offer or provide through it.
- To improve the Services, marketing and your experience on it.
- To provide you with customer support or assist with resolving complaints or issues.
- To conduct screenings, due diligence processes or any identity verification or wallet verification measures to comply with any applicable laws, regulations, directives or requests from relevant authorities.
- To assess and process instructions, transfers and other communications performed by you or others to the Services.
- To monitor infrastructure and third-party service providers the Services interacts with.
- To measure or understand the effectiveness of the functionality and offerings provided to you.
- To monitor, detect, prevent or otherwise address fraud and other illegal or harmful actions undertaken on or towards the Services in violation of our terms or policies.
- To comply with all application laws, rules, regulations, orders, instructions, directives, and other requests from law enforcement, governmental authorities or regulating bodies; or
- In any other way we may describe when you provide your personal data or for any other purpose communicated to you with your consent.
We may also use your personal data to contact you about our own and third-parties' services that may be of interest to you, as permitted by law. If you do not want us to use your personal data in this way, we will give you the opportunity to opt-out of receiving these communications.
6. Disclosure of Your Personal Data
We may disclose aggregated anonymized personal data about our users, and personal data that does not identify any individual, without restriction.
- Affiliated entities: We may share your person with our subsidiaries, parent company and other related entities to effectively provide you with the Services.
- Third-Party Service Providers: We may share your information with trusted service providers, contractors, the organizations they act on behalf of, and other third-parties (such as decentralized protocols) that we use to support our business. These third-party service providers may require us to provide them with your information to perform or facilitate these functions. If we provide them with your information, we will contractually obligate them to keep your information confidential, use it only for the purposes for which we disclose it to them, and to process the personal data with the same standards set out in this policy.
- Payment Processors: Users may be able to submit payment information into the Service to pay for certain features. Sygma may utilize third-party payment processors to facilitate payments. We do not receive nor store any payment information on our servers. All payment transactions are encrypted when communicated through our third-party payment processor.
- Commercial Partners: We may share your personal data or anonymized aggregated data derived from your information and the information of others with some of our commercial partners.
- Legal Requirements: We may disclose personal data in order to comply with any court order, law, or legal process, including to respond to any government or regulatory request in accordance with applicable law.
- Enforcement: We may disclose personal data in order to establish or exercise our legal rights, or to defend against legal claims, or when we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, data breaches, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
- Applicable Law: there may be laws under the jurisdictions that we operate in that compel us to disclose personal data or Digital Wallet information. If required, we may provide personal data or Digital Wallet information that we receive from you or a third-party in an unencrypted format.
- Business Transactions: Sygma reserves the right to share your information in connection with any proposed or realized merger, divestiture, consolidation, restructuring, purchase, sale or any other type of business combination that requires its disclosure.
7. Transferring of Personal Data
We may transfer personal data that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Services improvements and optimization) and who are contractually obligated to keep personal data confidential, use it only for the purposes for which we disclose it to them, and to process the personal da with the same standards set out in this policy.
We may process, store, and transfer your personal data in and to a foreign country, with different privacy laws that may or may not be as comprehensive as your jurisdiction. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal data through the laws of the foreign country.
Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation.
You are welcome to contact us to obtain further information about Sygma policies regarding service providers outside of your jurisdiction. By submitting your personal data or engaging with the Services, you consent to this transfer, storage, or processing.
8. Data Security
The security of your personal data is very important to us. We use physical, electronic, and administrative measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your personal data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of your Digital Wallet, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Services. Any transmission of personal data is done at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
9. Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
10. Accessing and Correcting Your Personal Data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. If you want to review, verify, correct, or withdraw consent to the use of your personal data, you may also send us an email firstname.lastname@example.org to request access to, correct, or delete any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal data, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information that protected by attorney-client privilege;
- Information that is part of a formal dispute resolution process;
- Information that is about another individual that would reveal their personal data or confidential commercial information; and
- Information that is prohibitively expensive to provide.
11. Withdrawing Your Consent
Where you have provided your consent to the collection, use, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at email@example.com Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
13. Additional Terms for Residents of the European Economic Area (EEA) and the United Kingdom
If you are a resident of the European Economic Area or the United Kingdom, you have the following rights:
- Right of Access. You have the right to request and obtain access to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
- Right to Rectification. You have the right to request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, including through providing us with a supplementary
- Right to Erasure. You have the right to request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Right to Object to Processing.You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to Restriction of Processing. You have the right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- Where you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to Portability. You have the right to request the transfer of your personal data to you or a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to Withdraw Consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may exercise any of the rights listed above by contacting our Privacy Officer at: firstname.lastname@example.org
14. Contact Information and Challenging Compliance
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal data, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.