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Privacy Policy

Effective as of September 19, 2023

This Privacy Policy describes how Claim Digital Assets Inc. (“Claim,” “we”, “us” or “our”) processes personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, email address, and phone number.
  • Profile data, such as the username and password that you may set to establish an online account on the Service, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
  • Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
  • Transactional data such as data obtained from a linked credit or debit card(Linked Card) and information we obtain from other companies (Third Party Service Providers) related to the Services, including information about transactions such as merchant name and location, purchase amount, date and time, and applicable payment network (Card Payment Network). For clarity, our Third Party Service Providers will not provide us with your 16 digit Linked Card account number. Please refer to the Third-party sources section below for details on our Third Party Service Providers and links to their privacy policies for more information on how your Linked Card information is collected and processed by those providers.
  • Marketing data, such as when our join our waitlist and your preferences for receiving our marketing communications and details about your engagement with them.
  • User-generated content, such as profile pictures, photos, images, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
  • Financial data, such as your virtual currency or wallet accounts, stored value accounts, and associated details.
  • Job application data, such as information you submit in connection with an application for a job (including information in a CV, resume or otherwise collected through the job application process).
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as social media platforms, public blockchain(s), and other publicly available sources.
  • Third Party Service Providers, such as third-party services (e.g., Google (https://policies.google.com/privacy?hl=en-US), Plaid Technologies Inc. (Plaid) (https://plaid.com/legal/), and PayPal Inc. (PayPal) (https://www.paypal.com/us/legalhub/privacy-full), along with their affiliated companies) that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information, including transactions history and other financial data associated with your account on that third-party service that is made available to us based on your account settings on that service.
  • Card Payment Networks related to the Service (e.g., Visa Inc. (Visa), Mastercard Inc. (Mastercard), and American Express Company (Amex)) and their affiliated companies.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Location data when you authorize (our mobile application/the Service) to access your device’s location.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

  • Administer transactions related to the Service. Claim and its Third Party Service Providers may use transactional data for the following purposes:

    o  to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for rewards;

    o  to share with the participating merchants where a transaction occurred for the merchant to confirm a specific transaction occurred;

    o  to share your Linked Card information with the Card Payment Network so that network knows you enrolled and to identify qualifying purchases; and

    o  to create a record of the transactional data and thereafter maintain and use data in connection with operating the Service;
  • provide, operate and improve the Service and our business;
  • establish and maintain your user profile on the Service;
  • facilitate your invitations to friends who you want to invite to join the Service;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.

Marketing. We, our service providers and our third-party advertising partners may collect and use your personal information to send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

To manage our recruiting and process job applications. We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment statistics.

Compliance and protection. We may use your personal information (including, but not limited to, transactional data) to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To personalize your experience. We may use your personal information to personalize certain features and content for you, for example, we may use information about you to alert you to or share details about specific rewards that you may be eligible for or may be otherwise of interest to you.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and analytics. In addition to the other uses included in this section, we may use the below technologies for the following purposes:

  • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as 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.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as digital asset management services, hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Claim or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other users and the public. Your profile and other user-generated content (except for private messages) may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Unlink Linked Card or opt-out of Services. You can unlink you card(s) and opt out ofthe services at any time through the “Settings” section of your profile; under the “Linked Card” section you can choose to remove a card or cards by clicking the remove button beside the Linked Card(s) you wish to remove. Once you confirm removal, the card will be unlinked from your account and all transaction monitoring associated with Claim will be ceased.

Delete your content or close your account. You can choose to delete certain content through your account. You may delete your account at any time. This is accessed through the “Settings” section of your profile, under the “Preferences” section you can delete your account by clicking the “Delete Account” button.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Contact Information

Claim Digital Assets Inc.
50 Milk St, 16th Floor
Boston, MA 02109
Email: hello@claim.co