Privacy Policy

This privacy policy (the “Privacy Policy”) explains how Firefly Labs Inc. (“Firefly”, “we”, “us” and “our”) collects, uses, and discloses information about you or the person or entity you represent (“you” or “your”) through its websites, web applications, and other online products and services (collectively, the “Services”) or when you otherwise interact with us. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

By using the Sites or the Services, you accept the terms of this Privacy Policy and our terms of service (the “Terms”), and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms. If you do not agree with any part of this Privacy Policy or our Terms, then please do not use the Sites or any of the Services.

1. Information We Collect

• (a) Information You Provide to Us

  We collect information you provide directly to us. For example, we collect information when you access or use the Services, fill out a form, engage in a transaction, request customer support or otherwise communicate with us. The types of information we may collect include your email address and any other information you choose to provide.

• (b) Automatically Collected Information

  When you access or use the Services, we automatically collect information about you, which may include the following:

  • (i) Contact Information: This may include your name, email address, physical address and country information.
  • (ii) Financial Information: This may include your blockchain protocol network address, cryptocurrency wallet information, transaction history, trading data and associated fees paid.
  • (iii) Transaction Information: This may include information about the transactions you make using the Services, such as the type of transaction, transaction amount and timestamp.
  • (iv) Correspondence: This may include your feedback, questionnaire and other survey responses and information you provide to our support teams, including via our help chat or social media messaging channels.
  • (v) Online Identifiers Log Information: We collect identifier and log information about your use of the Services, including username, geolocation or tracking details, the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
  • (vi) Usage Data: This may include conversion events, user preferences, crash logs and other data collected via cookies and similar technologies.
  • (vii) Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • (viii) Information Collected by Cookies and Other Tracking Technologies: We and third parties we authorize may use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see Section 9 below.
• (c) Information We Collect from Other Sources

  We may obtain information from other sources, including third parties, and combine that with information we collect through our Services.

• (d) Information We Will Never Collect

  We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.

• 2. How We Use Information

  We use the information we collect to provide, maintain, and improve the Services, including as described in the Terms. We may also use the information we collect to:

  • (a) send you technical notices, updates, security alerts and support and administrative messages, and to respond to your comments, questions and customer service requests;
  • (b) communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you, which may be provided by any means, including by e-mail, in-app notifications, push notifications and display advertising;
  • (c) personalize your experience when you visit or use the Sites or our Services;
  • (d) administer contests, promotions, surveys and other Service features;
  • (e) monitor and analyze trends, usage, and activities in connection with the Services;
  • (f) comply with applicable laws, lawful requests and legal processes, including responding to court orders or requests from regulatory authorities;
  • (g) generate aggregate or de-identified data and use such data for any lawful purpose, including research and analytics;
  • (h) testing, research, analysis, product development and improve your experience;
  • (i) detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Firefly and others;
  • (j) monitor and verify identity or service access, combat spam, malware or security risks;
  • (k) investigate and address user concerns;
  • (l) monitor and improve customer support responses and processes;
  • (m) perform internal operations necessary to provide the Services, including to troubleshoot software bugs and operational problems; and
  • (n) enforce our agreements with third parties and address violations of our Terms or agreements for other products or services.

• 3. Sharing of Information

  We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share information about you as follows or as otherwise described in this Privacy Policy:

  • (a) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including hosting, email and database services;
  • (b) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
  • (c) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Firefly or others;
  • (d) if we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person;
  • (e) to report suspected illegal activity;
  • (f) to investigate violations of our Terms, agrees for other products or services, or any other applicable policies;
  • (g) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company or bankruptcy transaction or proceeding;
  • (h) between and among Firefly and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • (i) with your consent or at your direction.

• 4. Advertising and Analytics Services Provided by Others

  We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Firefly and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (or http://www.youronlinechoices.eu/ if you are a resident of the European Economia Area).

• 5. Retention of Data

  We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. There is no single retention period applicable to the various types of personal information collected. Please contact us if you would like to delete any personal information we hold about you. We also reserve the right to continue to hold personal information about you to the extent it is required to be held by us by law, rule, or regulation

• 6. Security Measures

  We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity of, and to help protect information about you from, loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.

• 7. Disclaimer About Sharing Personal Information Online

  You acknowledge that when sharing personal information online, there is always a risk of data breaches, including data breaches in which third parties unlawfully access our systems or the systems of our third-party providers, which store personal information.

• 8. Limitation on Liability

  While we take measures to protect personal information, you agree that in no event will Firefly, its affiliates, and each of their respective shareholders, members, directors, officers, managers, employees, lawyers, agents, accountants, advisors, representatives, suppliers, and contractors (collectively, the “Company Parties”) be liable to you or any other person in any way in contract, tort (including negligence), civil liability or otherwise for any claims, damages, obligations, losses, liabilities, costs, debts or expenses (including but not limited to lawyer’s fees and disbursements), whether direct, indirect, special, economic, incidental, consequential, punitive or exemplary, including without limitation loss of revenue, data, anticipated profits or lost business, howsoever caused, including by way of negligence, arising from, related to or connect with the loss or theft of your personal information. You agree that if, notwithstanding the other provisions of this Privacy Policy, a Company Party is found to be liable for any claims, proceedings, liabilities, obligations, damages, losses or costs, such Company Party’s liability shall in no event exceed the amount you paid to us hereunder during the twelve (12) month period prior to the date on which such claim arose, if any

• 9. Transfer of Information to Other Countries

  We are based in the British Virgin Islands. However, we may transfer personal information to outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as customer service and support, marketing and analytics, data hosting or processing services, or similar services. Some of these service providers may be located outside of the British Virgin Islands, including the United States, and as a result your personal information may be processed in the United States or elsewhere outside of the British Virgin Islands, where local laws may permit foreign government and national security authorities to access personal information in certain circumstances.

• 10. Residents of The European Economic Area

  If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. Any reference to “personal information” in this Privacy Policy should be understood as referring to “personal data”, defined under the General Data Protection Regulation (“GDPR”) as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”

  
  (a) Legal Basis for Processing

  If you are a resident of the EEA, when we process your personal data we will only do so where we need to use your personal data to perform our responsibilities under our agreement with you (e.g., providing the Services you have requested). We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to the Services, and to provide, secure, and improve the Services. You have consented to the processing of your personal data for one or more specific purposes. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you wish, please contact us at the contact details indicated below.

• (b) Data Subject Requests

  If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below. Please note that the limitation or deletion of your personal data may mean we will be unable to provide our Services to you. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing.

• (c) Questions or Complaints

  If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.h tm.

• 11. Your Choices

  (a) Account Information

  You may update, correct, or delete information about you at any time by emailing us at [email protected]. Please note that we may retain cached or archived copies of information about you for a certain period of time.

• (b) Cookies

  Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

• (c) Promotional Communications

  You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations

• (d) Mobile Push Notifications/Alerts

  With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

• 12. Contact

  If you have any questions about this Privacy Policy, please contact us at: [email protected].