Privacy Policy
Last updated: June 2023
This privacy policy (“Policy”) describes how Revelator, Inc. (“Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal information of users of its app (the “App”). This Policy applies to the App, applications, products and services (collectively, “Services”) on or in which it is posted, linked, or referenced.
By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.
What we collect
We get information about you in a range of ways.
Information You Give Us. Information we collect from you may include:
- Identity information, such as your first name, last name, username or similar identifier, title, date of birth and gender;
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username and password, interests, preferences, feedback and survey responses;
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;
- Financial information, such as your credit card or other payment card details;
- Transaction information, such details about purchases you make through the Service and billing details;
- Usage information, such as information about how you use the Service and interact with us;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
- Financial information, such as bank account number and bank routing number; financial assets holdings; and
- Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions.
Further Information You Give Us In Relation to the Services. Further information we collect from you in relation to our Services may include:
- Further identity information, such as your country of birth, nationality, social security number, place of birth, employer and occupation;
- Passport and/or photo ID for identity verification purposes;
- Information required to comply with anti-money laundering (AML) laws and know-your-customer (KYC) requirements (such as nationality and place of birth);
- Source of funds for participating in token launches; and
- Information that you give us in relation to your purchased token holdings, such as earnings received from staking, and the number of tokens in your wallet.
Information Automatically Collected. We may automatically record certain information about how you use our App (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our App to which a user browsed and the time spent on those pages or features, the frequency with which the App are used by a user, search terms, the links on our App that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
We may use cookies, local storage or similar technologies to analyze trends, administer the App, track users’ movements around the App, and to gather demographic information about our user base as a whole. Users can control the use of cookies and local storage at the individual browser level. If you disable or refuse cookies, please note that some parts of the App may become inaccessible or not function properly.
Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any App that asks you to enter your private keys or wallet seed.
Use of personal information
To provide our service
We will use your personal information in the following ways:
- To enable you to access and use the Services
- To provide and deliver products and services that you may request.
- To process and complete transactions, and send you related information, including purchase confirmations and invoices
- To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (AML) laws
and know-your-customer (KYC) requirements), lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and
our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also
use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our
App, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal
activity.
Sharing of personal information
We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:
- Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates (i.e. our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.
- Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes.
- We may share information to comply with laws,including KYC and AML requirements.
- We may share information to respond to lawful requests and legal processes.
- We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
- We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- Professional Advisors and Service Providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as bill and credit card payment processing, customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
- Other. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.
We may also share aggregated and/oranonymized data with others for their own uses.
How information is secured
We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
Information choices and changes
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to [email protected]. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
Eligibility
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the App and subsequently we will delete that information.
Marketing communications and sharing
You may instruct us not to use your contact information to contact you regarding services, promotions, surveys and special events that might appeal to your interests by contacting us using the information below. You can also opt out by following the instructions located at the bottom of any commercial emails messages you may receive.
Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you, such as service-related announcements (e.g., if our Services are temporarily suspended for maintenance).
Or, if you have downloaded our mobile application and enabled push notifications on your mobile device, we may send you alerts and notifications through push notifications, for example, to communicate status updates on our Services. However, you may choose to disable these notifications (except for the initial notification intended to verify your identity).
Third party links and app
This Privacy Notice does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate app to which our App links. The inclusion of a link on our App does not imply that we or our affiliates endorse the practices of the linked app.
Co-branded app
In the event that our App links to other apps that include our branding, this Privacy Notice does not apply to those other apps. Visitors to those apps are advised to carefully read the notices on those individual apps.
Changes to this privacy policy
We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the App (or as otherwise indicated at the time of posting). In all cases, your continued use of the App or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Data Protection officer
We have appointed a Data Protection Officer based on professional qualities and expert knowledge of data protection law and practices. The Data Protection Officer is tasked with ensuring that we always comply with our responsibilities under applicable data protection legislation.
Contact details of the Data Protection Officer:
Email: [email protected],
or write to the DPO:
FAO Data Protection Officer
Relevator, Inc.
Contact us
We welcome your comments or questions about this Policy, and you may contact us at:
Email: [email protected],
or write to us at:
Relevator, Inc.
Notice to california residents
Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
