Personal Data

Categories of Personal Data We Collect

Users

Categories of Personal Data that we collect about Users and how we share it:

Online Identifiers

• Examples: Email, Phone number, Wallet address, Social Media information including user name, first and last name, profile picture

• Third parties with whom we disclose: Service Providers, Business Partners

Device/IP Data

• Examples: IP address, IP-based location information,Type of device/operating system/browser used to access the Services

• Third parties with whom we disclose: Developers, Service Providers, Analytics Providers

Web Analytics

• Examples: Referring webpage/source through which you accessed the Services

• Third parties with whom we disclose: Service Providers, Analytics Providers

Device/IP Data

• Examples: IP address, Type of device/operating system/browser used to access the Services

• Third parties with whom we disclose: Service Providers, Analytics Providers

Other

• Examples: Referring webpage/source through which you accessed the Services

• Third parties with whom we disclose: Service Providers, Analytics Providers

Geolocation Data

• Examples: Any other data you may choose to provide in your communications with us.

• Third parties with whom we disclose: Service Providers

Developers

Categories of Personal Data that we collect about Developers Users and how we share it:  

Contact Data

• Examples: Email, Phone number

• Third parties with whom we disclose: Service Providers

Payment Data

• Examples: Payment card type, Full number of payment card, Last 4 digits of payment card

• Third parties with whom we disclose: Stripe Inc., Privy’s parent company, as payment processor 

Device/IP Data

• Examples: IP address, IP-based location information,Type of device/operating system/browser used to access the Services

• Third parties with whom we disclose: Service Providers, Analytics Providers, Business Partners

Web Analytics

• Examples: Referring webpage/source through which you accessed the Services

• Third parties with whom we disclose: Service Providers, Analytics Providers

Other

• Examples: Any other data you may choose to provide in your communications with us.

• Third parties with whom we disclose: Service Providers

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

From You:

• When you provide such information directly to us.

• When you create an account or use our interactive tools and Services.

• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

• When you send us an email or otherwise contact us.

• When you use the Services, such information is collected automatically.

• Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).

• If you use a location-enabled browser, we may receive information about your location through IP-address-based data, but we do not store such data.

• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

From Third Parties:

• From analytics, security, and cloud infrastructure service providers, when you interact and engage with the Services

• From Business Partners when you use a third party service to authenticate you or log you in to the Services.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services:

• Analyzing how you interact and engage with the Services

• Providing Customer Support for the Services 

• Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles

• Providing you with the products, services or information you request

• Meeting or fulfilling the reason you provided the information to us

• Providing support and assistance for the Services

• Improving the Services, including testing, research, internal analytics and product development

• Personalizing the Services, website content and communications based on your preference.

• Doing fraud protection, security and debugging

• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws

• Marketing the Services

  • Marketing and selling the Services to Developers and Business Partners 

    
    

• Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Privy or the Services.

  • Sending emails and other communications according to your preferences.

    
    

• Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations under applicable laws, regulations, court orders or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

  • Protecting the rights, property or safety of you, Privy or another party.

  • Enforcing any agreements with you.

  • Responding to claims that any posting or other content violates third-party rights.

  • Resolving disputes. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Disclose Your Personal Data

• We disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include: 

  • Hosting, technology and communication providers.

  • Analytics providers, security and fraud prevention consultants.

  • Support and customer service providers. 

  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include companies that track how users interact with the Services.

  • Business Partners. These parties partner with us in offering various services, and included parties that you authorize, access, or authenticate with, such as social media

  • Other users specifically authorized by You

    
    

To see our list of Service Providers (subprocessors), click here:

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze usage trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data—usually text files—placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, such as Privy’s End Users with whom you may have a relationship.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Datadog, Inc. (“Datadog”) uses cookies in connection with its services. Datadog’s ability to use and disclose information about your visits to the Services is subject to the Datadog Terms of Use and the Datadog Privacy Policy.

  
  

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by looking at the “options” or “preferences” section of your browser’s menu. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at [email protected].

U.S. Resident Rights

Certain states provide their residents with additional rights relating to personal data. These additional rights vary by country and region and may include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to us;

• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;

• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;

• the right to opt out of the sale or sharing of your Personal Data; and

• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

  
  

Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. We will not discriminate against you for exercising your rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. If there are any conflicts between this section and any other provision of this Privacy Policy and your rights as a resident of a particular U.S. state, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, including by using the same identifier (e.g., email address) to send the request as the initial identifier used to create your Privy account and using the designated multifactor authentication system associated with your account, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request via email at [email protected].

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

European Union and United Kingdom Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Privy will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected]. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

• Payment Data

• Device/IP Data

• Profile or Contact Data

• Online Identifiers

• Other

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

• Web Analytics

• IP Location Data

• Other

We may also de-identify or anonymize Personal Data to further our legitimate interests. Examples of these legitimate interests include (as described in more detail above):

• Providing, customizing and improving the Services.

• Meeting legal requirements and enforcing legal terms.

• Completing corporate transactions.

  
  

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by contacting us at [email protected].

• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information by reaching out at [email protected].

• Erasure: You can request that we erase some or all of your Personal Data from our systems.

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

• Right to File Complaint: You have the right to lodge a complaint about Privy's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.