STAKING PRIVACY POLICY

Last modified: OCTOBER 30, 2024.

1. Introduction.

Shib Doggy Dao Foundation and its affiliates (collectively, “we,” “our,” or “us”) take protecting your privacy very seriously. This policy (this “Privacy Policy” or this “Policy”) describes the types of information we may collect from you or that you may provide when you visit our website located at [shib.io/staking] and any of its affiliated web, software and mobile-based platform offerings or applications or sub-pages (collectively, the “Platform”), and our practices and purposes for collecting, using, maintaining, and disclosing that information. This document supplements our Terms of Use and Cookie Policy, which are hereby incorporated for reference.

This Privacy Policy applies to information we collect:

• On the Platform; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website or affiliated web, software or mobile-based platform offerings or applications or sub-pages operated by any third party; or
• Any third party, including through any application or content that may link to or be accessible from or on the Platform.

Please read this Privacy Policy carefully to understand how we interact with your Personal Information (as defined below) and what we do with it. By clicking “I Agree”, you agree to this Privacy Policy.

2. Children Under the Age of 18.

Our Platform is 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 Platform. 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 Platform or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any [blockchain identity] or records related to you. If we learn we have collected or received Personal Information (as defined below) 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 [[email protected]].

3. The Kinds of Personal Information We Collect.

Personal information means any information about an individual who is identifiable by or in relation to such data (“Personal Information”).

We collect the following types of information from you, which includes Personal Information:

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

• Information by which you may be personally identified including information which you provide in relation to the creation and access of your account on the Platform, such as name, age, date of birth, gender, government ID, your email address, phone number, online usernames or account identifiers, or other identifiers by which you may be contacted online or offline, password, profile information or the other details of your interaction with our Platform.
• Information which you provide while carrying out transactions for the purchase of our Services (as defined in the Terms of Use). While making payment, we may redirect you to third party payment gateway/interfaces and at such third-party payment gateway/interfaces your billing details such as billing name and address, other payment instrument information (“Billing Information”) may be collected by such third party payment applications/interface. We do not collect or store such Billing Information on the Platform. You agree and acknowledge that your submission of Billing Information on the third-party payment gateway/interfaces is for processing payments for purchasing our Services and you hereby consent to providing such Billing Information for the same. Your submission of Billing Information on such portals will also be governed by the terms of such third party payment gateway/application's privacy policy and terms of use; and [your public key address or other public identifier related to your blockchain wallet or activity (including Ethereum Name Service “.eth” domain or similar domain services on other supported blockchain networks).]

For users in India: Where you provide us with your Aadhaar information as your government ID, we will not be sharing the same with third parties without your prior explicit consent. We do not retain your Aadhaar information for longer than required for the purposes set out in this Privacy Policy and will keep your Aadhaar information secure and confidential in accordance with applicable laws.

Information Collected Automatically: When using our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Information about the equipment, software, and configurations you use to access our Platform;
• Usage details, including the total time you spend on our Platform, the time you spend on each page and in what order those pages were visited and the internal links clicked, the general geographic location from which you access our Platform, which browser and operating system you are using to visit our Platform, and the referring website; and
• Performance details, including monitor page load times, CPU/memory usage, browser crashes and React component rendering.

We use certain technologies, including cookies, for automatic data collection. Please read our Cookie Policy for more information on our usage of these technologies, such as cookies on the Platform, including the purposes for which they are used.

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

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

• To present our Platform and its contents to you;
• To provide you with information, products, or Services that you request from us;
• To fulfill any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Platform or any products or Services we offer or provide though it;
• To allow you to participate in interactive features on our Platform;
• 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.

   We may aggregate or anonymise Personal Information so that it may no longer be used to   identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies (as set out in our Cookie Policy), and through other means described in this Privacy Policy. We will maintain and use anonymised information in de-identified form, and we will not attempt to re-identify the information, unless required by and strictly in accordance with law.

5. 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, for the purposes set out in this Privacy Policy;
• To contractors, service providers, and other third parties we use to support our Platform and Services;
• 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 payment and purchase purposes; or
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, or identifying malicious actors using our products, or related [blockchain communities] generally.  

We do not sell your Personal Information to third parties for monetary compensation.

6. Privacy & the Blockchain (if applicable)

A key feature of many blockchain technologies, including any blockchain on which our Services rely, is the transparency and public accessibility of on-chain transactions. This includes but is in no way limited to your public sending address (“public key”) and any other information that you choose to include. Additionally, information stored on-chain may be public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your public keys 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.

7. Third Party Service Providers

This Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which our Platform links, Event Organisers (as defined in the Terms of Use), [virtual digital asset service providers], and payment service providers. The inclusion of a link on our Platform does not imply that we or our affiliates endorse the practices of the linked website. We cannot, and do not, make any representations or warranties of any kind regarding the security of any third-party service or its data collection and security practices. Your use of third-party service providers in concert with us is solely at your own risk.

8. Data Security.

We have implemented reasonable security measures and appropriate technical and organisational measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure in accordance with applicable data protection laws.

We will retain your Personal Information for as long as necessary to fulfill the specified purposes for which we collected it for, including for the purposes of satisfying any requirements under applicable law. We will cease processing and delete your data when you withdraw your consent or request us to erase your data, unless retention is permitted or required by law.

The safety and security of your information also depends on you. Where you are using a third-party service to access certain parts of our Platform, you are responsible for keeping your password and other information confidential. This applies to any private keys you may use in relation to our Platform or our Services. We strongly encourage you not to share your access credentials with anyone for any reason.

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 Platform. 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 Platform.  

9. Special Disclosures for European Users.

Under the European General Data Protection Act, every user in the UK / EEA is entitled to the following:

• The right to access – You have the right to request copies of your Personal Information 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 Personal Information you believe is inaccurate. You also have the right to request that we complete any Personal Information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your Personal Information, under certain conditions.
• The right to data portability – You have the right to request we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.

If you 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 Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en;

For individuals in the UK: https://ico.org.uk/global/contact-us/;

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

For users in India:

Under data protection laws applicable in India, every user in India is entitled to the following:

• The right to access and review - You have the right to access and review information about the processing of your Personal Information by making a request, including for a summary of your Personal Information and the processing activities related to such Personal Information, the identities of third parties with whom your Personal Information has been shared along with a description of such Personal Information from us.
• The right to correction, completion and updating – You have the right to request that we correct any Personal Information you believe is inaccurate or misleading. You also have the right to request that we complete any Personal Information you believe is incomplete or update your Personal Information.
• The right to erasure – You have the right to request that we erase your Personal Information unless retention is required under applicable law.
• The right to grievance redressal – You have the right to have your grievances in relation to the processing of your Personal Information resolved in the manner set out in this Privacy Policy and under applicable law.
• The right to nominate – You have the right to nominate another individual to exercise your rights in relation to your Personal Information in case of your death or incapacity.

For all users:

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact our grievance officer in the manner set out below.

10. 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 Platform home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this Privacy Policy to check for any changes. By clicking “I Agree” upon being notified, you agree to any changes to this Privacy Policy.

11. What if I Have Questions or Grievances About This Privacy Policy?

If you have any questions or grievances about this Privacy Policy or how we handle your Personal Information, please send  a message to our grievance officer at:  

Contact details: [email protected]