Ethos Privacy Policy

Effective Date: June 1st, 2018

This Privacy Policy describes how Ethos.io PTE LTD (“Ethos” or “we”) collects and processes information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING ETHOS’ SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.

Ethos.io PTE LTD 80 Robinson Road, #02-00 Singapore 068898 is the data controller of information that you provide us or that we collect.

1. WHEN THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to use of www.ethos.io, Ethos’ Universal Wallet (“App”) and other digital services offered by or on behalf of Ethos in or to which this Privacy Policy is linked or posted (collectively, the “Services”).

The Services provide software tools for users to access and manage various features and functions related to digital assets including tokens, cryptocurrencies, virtual currencies or any other digital assets you own (collectively, “Digital Assets”), including interfacing with third party sources for certain information regarding the value of Digital Assets.

If a particular part of the Services has its own privacy policy or links to a different privacy policy, then that privacy policy — not this Privacy Policy — applies.

This Privacy Policy also does not apply to information that is collected offline or by any third-party website or service that you access through the Services.

In this Privacy Policy, to “process” information means to perform any operation on the information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

2. CHANGES TO THIS PRIVACY POLICY
The Effective Date of this Privacy Policy is set forth at the top of this webpage. As we add new features to the Services, we may amend this Privacy Policy. If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance through the Services. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

3. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect the information that you give, information generated as you use our services and information from third parties.

Information you give us

You choose to give us certain information when using our services, including:

  • When you create an account, we collect your name, email address, mobile telephone, account preferences and any other information that you provide us.
  • When you create a Wallet (as described in our Terms of Service), we collect the information that you provide to track the value of your Digital Assets through your Wallet.
  • If you contact our user support team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
  • When you participate in our surveys, we collect your insights into the Services and responses to our questions. You may choose whether to participate in any survey.

Information collected when you use the Services

When you use the Services, we collect information about which features you used, how you use them and the devices you use to access the Services.

  • We collect information about your activity on the Services. We automatically collect and store in server logs your date and time you logged in, search queries, the date and time of your request and referral URL.
  • We collect information from and about the devices you use to access the Services, including Internet Protocol (IP) address (including country), device ID and type, device-specific and other hardware settings, operating system and other software settings, browser type, browser language, time zones, and certain cookies or other technologies that identify your browser, device or Ethos account. Ethos may associate your Device information with your Ethos account.
  • We collect information from and about information on your wireless and mobile network connection, like your service provider and signal strength.
  • We collect other information with your consent.

Information collected through Third Parties:

Third parties that assist us with our business operations also collect information through the Services.

We engage service providers to collect information to help us secure the Services and detect and prevent fraud. We may receive information about you from our advertising partners, such as when advertising campaigns are published through the Services. Some of this information is collected through the technology described in Section 4.

4. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

How We Use Cookies and Other Data Collection Technology: Data collection technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, helping us analyze technical and navigational information about the Services to better understand how our products and services are being used, personalizing and tailoring ads to your interests and to detect and prevent fraud. We may link information from cookies with other personal information we hold about you.

The Services use the following cookies:

  • Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
  • Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
  • Functionality cookies, which are used to recognize you when you return to the Services.
  • We also use Google Analytics which is a Google service that collects information about use of the Services. Google Analytics does not identify individual users.

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Ethos, do not respond to DNT signals.


5. HOW WE PROCESS PERSONAL INFORMATION

Ethos processes personal information:

To administer your account and provide the Services to you

  • To set up and maintain your Account and Wallets;
  • To communicate with you;
  • To respond to your questions and to try to resolve problems with one of our products;
  • To complete transactions requested by you

To improve the Services and develop new ones

  • Administer surveys
  • Conduct research and analysis of users’ behavior to improve the Services and their content. For example, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior.
  • Develop new features and services. For example, we may decide to build a new interests-based feature further to requests received from users.

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehavior
  • Data analysis to better understand and design countermeasures against these activities
  • Retention of data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

  • Comply with legal requirements
  • Enforce or exercise our rights

To process your information as described above, we rely on the following legal bases:

  • Provide the Services to you: We process your information to perform the contract (Terms of Service) that you have with us.
  • Legitimate interests: We use your information for legitimate business interests when permitted by law. For example, we analyze users’ behavior on the Services to improve them, for direct marketing and for administrative, fraud detection and legal purposes.
  • Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the contact information provided at the end of this Privacy Policy.

6. HOW WE SHARE INFORMATION
Ethos may share information collected through the Services as follows:

  • Service Providers: We share information with our third-party service providers that help us operate the Services, such as by providing customer service or product support or testing and hardening our security measures.
  • Corporate Transaction: We may share and transfer information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Ethos or any affiliated company (in each case, whether in whole or in part).
  • When Required by Law: Applicable law may require Ethos to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant), government investigation or other legal requirements or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
  • Other Lawful Disclosures: We also share information if (i) disclosure would mitigate Ethos’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Ethos, users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.

Ethos may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Aggregated Information”). Ethos shares Aggregated Information with third parties and does not limit third parties’ use of the Aggregated Information.

7. CROSS-BORDER DATA TRANSFERS
Sharing information sometimes involves cross-border data transfers. For example, if the Services are available to users in the European Economic Area (“EEA”), these users’ personal information is transferred to countries outside of the EEA to the US or other jurisdictions. We use safeguards approved by the European Commission to legitimize data transfers from the EEA to other countries.

8. OPTING OUT OR CORRECTING INFORMATION
If you do not wish to receive marketing-related emails from us, please click the unsubscribe link in one of our marketing emails or contact us at [email protected]

To review, correct, update, suppress, restrict or delete personal information that you have previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (if this right to data portability is provided to you by law), you can:

  • Access, correct and delete certain information using Account settings.
  • Change your settings on your device to either consent or withdraw consent to the collection of certain information. Of course, if you do that, certain Services may lose full functionality.
  • Delete your Account.
  • Contact us at [email protected] and provide the email address associated with your Account.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests for the personal information associated with the email address associated with your Account. We may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases also may have residual data which we do not remove. In addition, we also may not allow you to review certain data for legal, security or other reasons.

If at any time you believe that we have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

If you are an EEA resident, you have the right to lodge a complaint with a data protection authority about how we process your personal information.

Notice to California Residents: California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected]

9. LINKS TO OTHER WEBSITES AND SERVICES
The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.

10. PROTECTION OF INFORMATION
We take precautions intended to help protect information that we collect and store. Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.

You are responsible for maintaining the security of your Account, including the device on which your store your Wallet. Access to the Services through your Account is treated as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.

If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

We keep your personal information in identifiable form only as long as we need it for the lawful purpose for which we collected it or, if longer or shorter, to comply with law, to resolve disputes and to enforce agreements with you.

11. CHILDREN’S PRIVACY
The Services are not directed to or intended for use by minors. Consistent with the requirements of the Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.

HOW TO CONTACT US
Please contact us at [email protected] , or;

Ethos.io PTE LTD
80 Robinson Road, #02-00
Singapore 068898