Ethos Privacy Policy

 

ETHOS PRIVACY POLICY

Last modified: 01-08-24

 

1. Introduction.

Zircon Global Technologies, a Nevada corporation (“Ethos,” the “Company,” “we,” “our,” or “us”), takes protecting your privacy very seriously. This Privacy Policy explains the types of information we may collect from you or that you may provide when you visit the Ethos website located at https://www.ethos.io/, its related sub-pages, or use our software applications which include the Ethos non-custodial digital asset wallet software application (collectively, the “Website”), and our practices for collecting, using, maintaining, and disclosing that information.

 

This Privacy Policy applies to information we collect:

 

• • On the Website;

• • In email, text, and other electronic messages between you and the Company; or

• Through the software applications we host including the Pre-Release Software and Ethos’s forthcoming non-custodial digital asset wallet software. As used herein, “our software applications” refers to all of the above.

Please read this Privacy Policy carefully to understand how we interact with your personal information and what we do with it. By using the Website and providing us with your information, you agree to this Privacy Policy. This Privacy Policy may change from time to time, and by continuing to use the Website, you agree to those changes. We encourage you to check this Privacy Policy periodically for updates.

 

2. 2. Children Under the Age of 18.

Our Website and software applications, including our digital asset wallet, are not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any information to us, including on the Website and our software applications. We do not knowingly collect personal information from children under eighteen (18). If you are under eighteen (18), do not use or provide any information on this Website and our software applications or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, any identity or records related to you, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under eighteen (18) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under eighteen (18), please contact us at support@ethos.io.

 

3. 3. The Kinds of Personal Information We Collect.

Information You Provide to Us: The information we collect on or through our Website or our software applications may include:

 

• We collect email addresses for the purposes of creating a “Magic Key” backup file of your keys.
• We also collect basic app analytics such as use frequency and asset search.
• In the event that KYC (“Know Your Customer”) is required and user explicitely opts-in we may collect personally identifable information by which you may be personally identified, such as name, IP address, email address, postal address, telephone number, or any other identifier through which you may be contacted online or offline, including social media handles or any other relevant identifier (“KYC personal information”);

• • Additional information we collect on our website includes:
  • Information that you provide by filling in forms on our Website or our software applications, including web3 wallet or public address information, or any other applicable payment information;

• • Details of transactions you carry out through our Website or through our software applications and of the fulfillment of your orders, as you may be required to provide financial information before placing an order through our Website;

• • Information about blockchain transactions, including but not limited to your public key address or other public identifier related to your blockchain account and information about how you are using the Company’s blockchain infrastructure;

• • Records and copies of your correspondence, including email addresses, if you contact us;

• • Comments and posts that we import from networking pages on social media platforms such as Discord, Telegram, Facebook, Twitter, LinkedIn, Google+ and Instagram to our Website or our software applications. If you post to any of our networking pages on third-party social media platforms, you are providing information to the public and do so at your own risk. Further, we may use these postings on our Website or our software applications without notice or compensation to you. Please visit the privacy policies of any third-party social media platforms before posting to our pages there.

• • Your search queries on our website or through our services; or

• Details regarding how you found our site and how you intend to use it, if applicable.

You also may provide information to be published or transmitted to other users of the Website or our software applications, or third parties (collectively, “User Contributions”). Your User Contributions are provided at your own risk. Additionally, we cannot control the actions of other users of the Website or our software applications with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

If you submit information to us that we believe places your privacy or security at risk, we may immediately delete that information.

The term “Sensitive Personal Data” refers to a smaller subset of personal information which is considered more sensitive to the individual, such as: race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometrical information, physical or mental health information, medical insurance data, or sexual orientation. WE DO NOT COLLECT OR USE, AND WE DO NOT WANT YOU TO PROVIDE TO US, ANY SENSITIVE PERSONAL DATA. YOU ARE RESPONSIBLE FOR NOT SUBMITTING SENSITIVE PERSONAL DATA, THEREFORE, WE CONSIDER ALL DATA SUBMITTED TO OUR WEBSITE OR OUR SOFTWARE APPLICATIONS AS NOT BEING SENSITIVE PERSONAL DATA.

 

Information Collected Automatically: As you navigate through and interact with our Website or our software applications, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

 

• • Usage details, including the total time you spend on our website, the time you spend on each page, the order in which those pages were visited and the internal links clicked, the general geographic location from which you access our Website, which browser and operating system you are using to visit our Website, and the referring website;

• • Performance details, including diagnostic, technical, and usage logs, monitor page load times, CPU/memory usage, browser crashes and React component rendering; or

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

 

• • Estimate our audience size and usage patterns;

• • Store information about your preferences, allowing us to customize our Website according to your usage patterns; and

• Recognize you when you return to our Website.

The information we collect automatically is only statistical data and does not, itself, include personal information, though it may be correlated with other personal information to build a unique profile about you.

 

The technologies we use for this automatic data collection may include:

• • Strictly Necessary Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Some cookies are essential to the operation of our Website. They are used to facilitate our log-in process, authenticate users, and enable you to navigate the Website and our software applications and to use their features. They are also used by our customer service team for in-product messaging and analytics. Without these cookies, we may not be able to provide certain products, services or features, and the Website or our software applications may not perform as smoothly for you as we would like. Because strictly necessary cookies are essential to operate our products on the Website and our software applications, if you choose to use a product on our Website or our software applications, there is no option to opt out of these cookies.

• • Functionality Cookies. In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make while browsing on the Website or our software applications, and to provide enhanced and more personalized content and features, such as customizing a certain webpage or application page, remembering if we have asked you to participate in a promotion and for other services you request, like watching a video or commenting on a blog. In order to permit your connection to the Website, our servers receive and record information about your computer and browser, potentially including your IP address, browser type, and other software or hardware information. All of these features help us to improve your visit and assist in navigation of the Website’s features. To manage the use of functionality cookies on our Website, or to opt out of their use, follow the instructions in the Section below entitled Opt-Out Instructions. Note that opting out may impact the functionality you receive when using our Website.

• • Analytics Cookies. We and our service providers may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the Website or our software applications and enable us to improve the way they work. Analytics cookies collect information about how you use the Website, for instance, which pages you go to most. The information allows us to see the overall patterns of usage, help us record any difficulties users may have while using the Website and show us whether or not our advertising is effective. To manage the use of analytics cookies on our Website, or to opt out of their use, follow the instructions in the Section below entitled Opt-Out Instructions. Note that opting out may impact the functionality you receive when using our Website or our software applications.

• • Advertising Cookies. We may also use cookies and similar tools to correlate your use of the Website or our software applications to personal information obtained about you. For example, if you have asked us to provide you information about our services or any promotions, we may utilize our cookie and/or clickstream data about your activities when you engage with us on the Website or our software applications. By evaluating this information, we may more clearly target the information we provide you to the specific items we think you will find interesting, based on your prior online activities and preferences. We also use third-party advertising cookies. We may use advertising cookies to deliver ads that we believe are more relevant to you and your interests.

• Web Beacons. Pages of the Website and our emails 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 or opened an email and for other related website statistics (for example, verifying system and server integrity).

We also collect data concerning the users of our applications. For example, any information that you may provide when creating an account (including personal identifying information, but excluding private keys, Magic Keys, Safe Words, and Recovery Phrases as defined in our Terms of Use) will be retained by us. We also collect IP addresses, and information on the activities of the users of our applications, both on an individual and aggregate level, including, for example, how often a user uses a certain platform and what activities the user engages in on a platform.

 

4. 4. How We Use Your Information & Why We Collect It.

We use information that we collect about you or that you provide to us, including any personal information:

 

• • To test our software applications and help us, our partners, and third party developers assess the performance of the software to use in improving our software applications;

• • To present our Website, our software applications, and their contents to you;

• • To manage our relationship with you;

• • To communicate with users on how to use our services;

• • To market our services and features;

• • To fulfill any other purpose for which you provide it (including to interact with our affiliates or subsidiaries, or third parties that we contract with to provide our software applications on a white label basis);

• • To carry out our obligations and enforce our rights under our Terms of Use, including restricting access to the Website and our software applications from specific Prohibited Jurisdictions (as defined in our Terms of Use);

• • To allow you to participate in interactive features on our Website and our software applications;

• • To help facilitate the ongoing development of our services;

• • In any other way we may describe when you provide the information; or

• For any other purpose with your consent.

5. 5. Third-Party Use of Cookies & Other Tracking Technologies.

Some content or applications, including advertisements, on the Website or in our applications may be served by third-parties, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

The third party tools that we use on our Website and our software applications include the following:

 

• • Brevo. Brevo provides email marketing, lead capture and web analytics to Ethos. Brevo captures visitor behavior and IP address information on our Website or our software applications. All web-browsers offer the option to refuse any cookie. If you refuse the Brevo cookies or delete them from your device, Brevo will not gather any personal information about you, you will need to re-enter certain information whenever you visit our Website or our software applications, and you’ll be prevented from customizing certain features on our Website or our software applications according to your preferences. Brevo may link the information they store in cookies to any personally identifiable information you choose to submit to Ethos while on our Website or our software applications. You may reject cookies and request to have data removed via form submission; you may also clear your browser’s cookies and website data to reject cookies from this third-party vendor. For more information, please visit the following pages: https://www.brevo.com/legal/cookies/

• • Google Tag Manager. Google Tag Manager is a tag management system created by Google to manage JavaScript and HTML tags used for tracking and analytics on websites. For more information, please visit the following page: https://www.google.com/analytics/tag-manager/use-policy/

• • Google Analytics. Google Analytics is an ad management and ad serving technology. Google Analytics places cookies on the Website so that we can record how many signups and leads originated from our marketing activity. For information on how to reject or delete this cookie, please visit: tools.google.com/dlpage/gaoptout

• • Facebook. Facebook is used by the Website and our software applications for advertising, display ads and retargeting. For more information on Facebook’s cookie practices, please visit: www.facebook.com/policies/cookies/

• • Instagram. Instagram is used by our Website and our software applications to drive brand awareness, boost sales, and build and track audience engagement. For more information on Instagram’s cookies policy, visit: https://help.instagram.com/1896641480634370

• • Google AdWords And Google Display Network. Google is used by the Website or our software applications for advertising, display ads, retargeting, and organic search. To opt out of Google’s use of cookies, please visit: https://adssettings.google.com/authenticated

• • SEMrush. Ethos, its portfolio of companies, Website and our software applications may use SEMrush to analyze website traffic data and SEO efforts. For SEMrush’s cookie policy, and information on how to control or delete cookies, please visit: https://www.semrush.com/company/legal/cookie-policy

• YouTube. YouTube is a video-sharing website that enables users to upload, view and share videos. The Website and our software applications contain embedded videos and/or directs users to the YouTube site. The videos shown on Ethos’s channel include those that include events, testimonials, and employees of Ethos and its related companies. Whenever a YouTube video is played or a still frame of a video is shown on our Website, a communication connection will be established with the corresponding YouTube server to exchange various data. These include the IP address of your computer, as well as previously stored cookies and information stored during previous contacts with YouTube. If no data has been stored before, the service will set an initial cookie on your computer. Whenever you contact a YouTube service, that service will also receive information about your YouTube account, in case you have one. When you interact with the video (e.g., by clicking the start, pause or stop button), details about these interactions will also be transmitted to the provider. You can terminate the data processing session by visiting a page that has no video content and deleting all cookies from your computer. Further information about YouTube’s data processing and data protection policies is available at https://policies.google.com/privacy

These third parties may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

 

6. 6. Disclosure of Your Information.

We may disclose aggregated information, and information that does not directly identify any individual about our users without restriction. We may disclose personal information that you provide to us as described in this Privacy Policy:

• • To our subsidiaries and affiliates;

• • To contractors, service providers, and other third parties we use to support our Website and our software applications and services;

• • To provide you with information, products, or services that you request from us;

• • To fulfill any other purpose for which you provide it;

• • To provide you with notices about your account, including expiration and renewal notices;

• • To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding;

• • For any other purpose disclosed by us when you provide the information; or

• • With your consent.

We may also disclose your personal information:

• • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or

• • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, or identifying malicious actors using our products, or the Company’s affiliates or subsidiaries.

We do not sell your personal information to third parties for monetary compensation.

 

7. 7. Opt-Out Instructions

If you want to control the cookies that are placed on your computer, smartphone or other device, you may view cookies stored on your hard drive, choose whether or not to permit cookies to be set by default by changing browser settings as provided in this Section, or delete the cookies stored on your hard drive. Please be aware, however, that your decision to control cookies may affect your experience of our Website or our software applications. You may not be able to access all or parts of the Website or our software applications. Turning cookies off, for instance, will prevent you from registering for, signing in to, and using many of the services on our Website or our software applications. Web browsers may allow you to change your cookie settings directly through their browser software applications. These settings will typically be found in the ‘options’ or ‘preferences’ menu of your browser. In order to understand these settings, the following links may be helpful; otherwise you should use the ‘Help’ option in your browser for more details:

 

• • Chrome: support.google.com/chrome/bin/answer.py

• • Microsoft Edge: https://learn.microsoft.com/en-us/microsoft-edge/devtools-guide-chromium/storage/cookies

• • Internet Explorer: support.microsoft.com/en-us/products/internet-explorer

• • Safari: https://support.apple.com/guide/safari/privacy-sfri35610/16.1/mac/13.0

• Firefox: support.mozilla.org/en-US/kb/Cookies

For information on how to use the browser of your mobile device to amend cookie settings, you will need to refer to your mobile device manual. The following third-party links contain additional information about cookies and other helpful information on your ability to control what cookies apply to you (please note, however, that these links will take you to third party sites over which Ethos has no control):

 

• • Offers comprehensive information on how to amend the settings of a wide variety of browsers, details on how to delete cookies from your computer, and more general information about cookies: www.allaboutcookies.org/manage-cookies/index.html

• • Offers information about third-party cookies generated by advertisers and how to turn thee off by going to the International Advertising Bureau’s consumer site: www.youronlinechoices.com/uk

• • Offers a comprehensive listing of opt-outs for advertising platforms; however, note that there are many more networks listed on this site than those used by Ethos and our Website: www.networkadvertising.org

8. Retention and Management of your Data.

If you wish to access or amend your personal information, obtain a copy of the data we hold about you, or require any assistance related to your data rights, email support@ethos.io. We uphold the responsibility of safeguarding your personal information for as long as we continue to provide our Services to you. Furthermore, we will retain your personal data even after the cessation of our Services, but only to the extent necessary for various purposes, such as:

 

• • Fulfilling your specific requests (e.g., maintaining your email address to ensure it’s removed from our mailing list).
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  • Complying with legal and regulatory obligations.
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  • Monitoring, detecting, and preventing fraud.

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Our data retention practices align with the limitations and obligations imposed by applicable laws, including any prescribed limitation periods and records retention regulations. Should you opt to remove your personal information, it’s important to note that certain functionalities, which rely on your personal data to operate, may become unavailable to you.

Privacy & The Blockchain.

A key feature of many blockchain technologies, including any blockchain on which the Company’s services rely, is the transparency and public accessibility of on-chain transactions. As such, any information stored on-chain may be public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your account with the Company may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our services.

 

9. 9. Data Security.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or our software applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Please see our Terms of Use for additional information about data security with respect to your use of the Website or our software applications.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or our software applications.

To the extent required by Applicable Law (as defined in our Terms of Use), we will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable laws, including U.S. federal and state statutes on security breach notification) to you via email or conspicuous posting through the Website in the most expedient time possible and without unreasonable delay, as consistent with: (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

 

10. 10. Special Disclosures for European Users.

Under the European General Data Protection Act (“GDPR”), we are required to provide you with the legal bases upon which we may collect information from you in your use of the Website or our software applications. Whenever we collect personal information from you, we may do so on the following legal bases:

 

• • Your consent to such collection and use;

• • Out of necessity for the performance of a contract between us and you, such as your agreement to use our services or our products;

• • Our legitimate educational or business interest, including but not limited to the following circumstances where collecting / using personal information is necessary for:

• • Product development and enhancement—where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our customers, and to better understand how people interact with our Website or our software applications;

• • Communications, marketing and intelligence—including processing data for direct marketing purposes (subject to your right to opt out as provided below) and to determine the effectiveness of our promotional campaigns and advertising;

• • Fraud detection and prevention (crime prevention);

• • Industry watch-lists and industry self-regulatory schemes;

• • Enhancement of our cybersecurity, including improving the security of our network and information systems;

• • Compliance with our legal obligations; or

• General corporate operations and due diligence; Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purpose.

Under GDPR, every user is entitled to the following:

• • The right to access – You have the right to request for copies of your personal data from us. We may charge you a small fee for this service.

• • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

• • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

• • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

• • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

• The right to data portability – You have the right to request we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Ethos takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. If you make a request, we have one (1) month to respond to you. If you would like to exercise any of these rights, please contact us at support@ethos.io.

 

11. 11. Data Protection Rights Under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask us to delete your data, and not to share it. To exercise your data protection rights, you can ask us:

 

• • What personal information we have about you. If you make this request, we will return to you:
    • • The categories of personal information we have collected about you.
    • • The categories of sources from which we collect your personal information.
    • • The business or commercial purpose for collecting your personal information.
    • • The categories of third parties with whom we share your personal information.
    • • The specific pieces of personal information we have collected about you.
    • • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your information, we will inform you of that fact.
    • • A list of categories of personal information that we have disclosed for business purposes, along with the category of any other company we shared it with.
    • Please note, you are entitled to ask us to provide this information twice at any point in a rolling twelve (12) month period. When you make this request, the information we provide will be limited to the previous twelve (12) months.
     

• • To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

• To stop selling your personal information. If you submit a request to stop selling your personal information, we will stop selling it. If you are a California resident, to opt-out of the sale of your personal information, please email such request to support@ethos.io.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. In no circumstances we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) to support@ethos.io.

 

12. 12. Changes to Our Privacy Policy.

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. If someone does not agree with this Privacy Policy, they should refrain from using our website and platforms. Continued use of the Website or our software applications after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

 

13. 13. What If I Have Questions About this Privacy Policy?

If you have any questions about this Privacy Policy, please send a detailed message to support@ethos.io and we will try to resolve your concerns and provide further information.