This Privacy Policy (“Privacy Policy”) describes how Archway Services Ltd. and its affiliates (“Archway”, “we,” “us,” or “our”) may collect, use and disclose information, and your choices regarding this information. Please read this document carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information in accordance with the applicable law.
1. Applicability of this Policy
This Privacy Policy applies to your use of Archway’s website or web applications, (altogether the “Site”) and related services (collectively, the “Services”).
This Privacy Policy does not apply to your use of the Archway Protocol and/or software, which is open source and maintained by a distributed network. However, if you access the Archway Protocol-related content from a hyperlink on our Site, we may collect the information described in the “Information We Collect Automatically” section below in connection with your use of the Site.
If you do not agree with the terms of this Privacy Policy, do not access or use the Site, Services or utilize any other aspect of our business. By using the Site and Services, you agree to this Privacy Policy.
2. What We Collect
We collect information, including personal information, from you when you register on our Site, subscribe to a newsletter or mailing list, respond to a survey, fill out a form, submit a request, or otherwise when you enter information on or use our Site or Services.
Information We Collect Directly From You.
The information we collect from you depends on how you use our Services. Information we collect may include:
- Identity Information: when you use the Services, we may collect information such as your name, e-mail address, mailing address, and phone number. Where necessary, we may be required by applicable law to collect information to verify your identity, such as government-issued identification documentation.
- Contact Information: If you contact us or if you subscribe to receive updates from us about new features available on our Site or through the Services, we collect records and copies of your correspondence, including e-mail addresses and other contact information.
- Marketing Information. Your preferences, including preferences for receiving marketing communications from us and how you interact with our marketing communications.
- User Communications. Personal opinions and information you share with us when you contact us with questions, ask for support, provide Feedback, respond to surveys, or any other information you provide to us directly or indirectly through your interactions with us.
- Social Media Information. Your unique handle or identifier and other profile information when you interact with us through social media channels.
Information We Collect Automatically.
Cookies. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies to record your preferences, track the use of our Sites and mobile apps, and collect information about the use of the Services, as well as about our interactions with you. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, and information about your interactions with the communications we send to you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may not function properly.
Blockchain Data. Public blockchain data including blockchain addresses and crypto-asset transaction information related to those blockchain addresses.
Aggregate Data. Analytics about aggregate numbers of users and usage types (i.e., number of page views, event counts, and aggregate acquisition metrics), and information such as how many users in the aggregate are using certain protocols with assistance of Services; and aggregate location data across users including countries and regions from which users access the Services or the Site.
3. How We Use Information
We use your information in accordance with your instructions, and as required by applicable law. We may also use the information we collect for:
Providing Services and Features
We may use the information we collect to provide, personalize, maintain and improve our products and Services. This includes using information to:
- To present our Site and their contents to you, or to provide you with access to the Services;
- To provide you with information, products, or services that you request from us;
- Operate, maintain, customize, measure, and improve our Services, and manage our business;
- Create and update user accounts;
- Communicating with you, including responding to your requests or inquiries and for customer service purposes;
- To notify you about changes to our Services, or any products or services we offer or provide through the Services;
- Marketing and advertising our Services and expertise and for other marketing, advertising, and promotional purposes, such as to contact you about products or services we think may interest you;
- To manage the security and operation of our Site, networks and systems, including to prevent, detect, and investigate fraudulent, abusive, or harmful activities;
- To create de-identified or aggregated data in order to analyze, develop, improve and optimize the Site and Services;
- Any other purposes, as allowed by law or with your consent.
Research and Development:
We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes and develop new features and products relating to our Services.
Legal and Regulatory Compliance:
We may verify your identity to determine your eligibility to access the Services by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
4. How We Share & Disclose Information
We may share your information in the following circumstances:
With Your Consent: For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their own privacy policies.
To Comply with Our Legal Obligations: We may share your information: (A) to cooperate with government investigations; (B) when we are compelled to do so by subpoena, court order, or similar legal procedure; (C) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person; (D) to report suspected illegal activity; or (E) to investigate violations of our User Agreement or any other applicable policies.
With Services Providers: We may share your information with service providers who help facilitate business and compliance operations such as marketing and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us.
During a Change to Our Business: If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data: We may share aggregated and/or anonymized data with others for marketing, advertising, research, or other purposes.
Analytics Providers/Advertisers: We may share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Typically, this information is collected from you through cookies and other tracking technologies on our Site.
5. Your Rights
You have the right to request a copy of your information, to object to our use of your personal information (including for marketing purposes), where applicable, to correct your personal information, to request the deletion or restriction of your personal information, or to request your personal information in a structured, electronic format.
Depending on where you are located, you may have certain rights in connection with your personal information that we obtain. These rights vary depending on your jurisdiction. To learn more about your rights, see:
Appendix A for CCPA rights if you are a California resident.
Appendix B for GDPR rights if you are located in the EEA or United Kingdom.
6. Data Retention
We will retain your personal information on file for as long as necessary for the purpose of processing your data. Please note that in certain cases, legal or regulatory obligations require us to retain specific records for a longer period of time.
7. Security
We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure. No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure. You are responsible for all activity on the Archway protocol relating to any of your network addresses and/or cryptocurrency wallets.
8. Notice Concerning Children
Our Services are not designed for people under eighteen (18) years old. If we discover that a person under thirteen (18) has provided us with personal information, we will delete such information from our systems.
9. Changes to this Policy
If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Sites.
10. Contact Us
Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at [email protected] or at our mailing address at:
Archway Services Ltd.
Floor 4, Banco Popular Building, Road Town, Tortola
British Virgin Islands, VG1110
Appendix A
Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA Notice to California residents to explain how we collect, use and share their personal information, and the rights and choices we offer California residents our handling of their personal information.
CCPA Scope and Exclusions:
This CCPA Notice apply only to California residents whose interactions with us are limited to:
- Visiting our consumer websites; and
- Signing up for email alerts.
This CCPA Notice does not apply to the personal information we collect, use or disclose about:
- Representatives of businesses that seek to obtain our products or services, or to provide products or services to us.
Privacy Rights:
The CCPA grants individuals the following rights:
- Information: You can request information about how we have collected, used and shared your personal information during the past 12 months. For details about the personal information, we have collected over the last 12 months, including the categories of sources, please see the What We Collect section of this Policy. We collect this information for the business and commercial purposes described in the How We Use Information section of this Policy.
- Access: You can request a copy of the personal information that we maintain about you.
- Deletion: You can ask us to delete the personal information that we collected or maintain about you.
- Right to Opt-out of the Sale of Information: You have the right to opt-out of the sale of personal information we have collected about you.
- Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising any of your CCPA rights. We do not treat individuals differently for exercising any of the rights described above.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination.
Sharing Information:
We share the information collected with third-party service providers such as suppliers, vendors, business partners (e.g., advertising partners, consultants) to operate our business and provide the Services. We do not sell personal information as the terms “sell” and “personal information” are defined by the CCPA.
Appendix B
General Data Protection Regulation (“GDPR”) Information for EEA/UK Residents
Legal Bases for Processing Personal Information
All processing and use of your personal information is justified by a "legal basis" for processing. In the majority of cases, processing will rely on one of the following legal bases:
- Contract performance: The processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as to fulfill an order for Services or to provide product information you have requested;
- Compliance with laws: The processing is necessary for us to comply with a relevant EEA or UK legal obligation, such as keeping accounting records;
- Legitimate interests: The processing is in our legitimate business interests; which are not overridden by your interests and fundamental rights; or
- Consent: You have consented to the processing.
We use the personal information we collect for the following purposes, relying on the legal bases set forth below:
- Legitimate interests in promoting our Services in order to grow our business: To present our Sites and their contents to you, or to provide you with access to the Services including for marketing and advertising our services and expertise and for other marketing;
- Legitimate interests in improving our Sites, products and Services in order to grow our business: To analyze, develop, improve and optimize the use, function and performance of our Sites, products and Services;
- Legitimate interests in protecting our assets such as Sites, networks and systems: To manage the security and operation of our Sites, networks and systems, including for preventing, investigating and identifying any fraudulent or illegal activity;
- Legitimate interests in optimizing efficiencies and return on investment: To plan or realize an acquisition, merger, investment, asset transfer (whether as part of a bankruptcy or insolvency proceeding or otherwise);
- Contract performance: To provide you with information, products, or Services that you request from us, including responding to your requests or inquiries in relation to the Services;
- Compliance with laws: To verify your identity and determine your eligibility to access the Services as required by the applicable law;
- Compliance with laws: Complying with applicable EEA or UK laws, rules, regulations, and legal processes, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
Transfers of Personal Information
If your personal information is transferred outside the EEA or UK (whether within the Archway group or to third parties), we will take steps to ensure that your personal information receives the same level of protection as if it remained within the EEA or UK, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses. For transfers of personal information among Archway group affiliates we have put in place European Commission approved Standard Contractual Clauses. Your personal information may be transferred to, including but not limited to, the United States or the Cayman Islands, which do not benefit from a decision of the European Commission determining that the country provides adequate protection to personal information. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA or UK by contacting us as set out in the Contact Us section of this Policy.
Your Rights
You are entitled to certain legal rights in relation to your Personal information.
- Right to Access: you have the right to request access to any of your personal information that we hold, and to obtain information about the processing of that data.
- Right to Correct: we will take steps in accordance with applicable legislation to keep your personal information accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal information corrected (that is, rectified).
- Right to Erasure: you are entitled to have your personal information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal information is unlawfully processed.
- Data Portability: where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal information is processed by automated means, you have the right to receive all such personal information which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to Restriction of Processing: you have the right to restrict our processing of your personal information (that is, allow only its storage) where:
- you contest the accuracy of the personal information, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the personal information;
- where we no longer need your personal information for the purposes of the processing, but you require such personal information for the establishment, exercise or defense of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
- Where your personal information is subject to restriction, we will only process it with your consent or for the establishment, exercise or defense of legal claims.
- Right to Object to Processing (including profiling): you can object to our processing of your personal information based on our legitimate interests. We will no longer process your personal information unless we can demonstrate an overriding legitimate purpose.
- Right To Object To Direct Marketing (including profiling): you have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.
- Right to Withdraw Consent: in the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.
Exercising Your Rights
To exercise any of the rights above, please contact us as noted in the “Contact Us” section in this Privacy Policy.