Privacy Policy
LAST UPDATED: April 20, 2020
The following policy applies to prospective members and members doing business in and regulated by Asian market regulators.
Welcome to the website "Site", of Provenance Blockchain, Inc. ("Provenance", "we" or "us"). Provenance respects your ("you", "your) privacy, and is committed to treating and protecting the personal data you provide to us in accordance with all applicable laws.
This Privacy Policy (the "Policy"), explains how we may collect, use and share your personal and other data, via your access to and use of the Site and the Services as defined in our Terms of Service as well as your rights concerning our data practices.
Before you submit any information to the Site, please review this Policy carefully and contact us with questions (see "Information Access and Choice" ). By using the Services and providing us with your personal data, you agree to the data practices and contents described in this Policy, including that we may collect, process, use, transmit internationally and share your personal data in the ways described herein.
If you do not agree with the terms of this Policy, please do not use the Services.
As part of our Terms of Service, we may make changes to this Policy from time to time at our sole discretion and will post the amended Policy on this page and indicate the date this Policy was 'Last Revised' above. You are responsible for checking on the latest terms of the Policy any time you use the Services. You understand and agree that your continued use of the Site and/or the Services after we have made any such changes constitutes your acceptance of the changes to this Policy.
This Policy is incorporated into and forms part of our Terms of Service, which you have agreed to in order to use our Services at: provenance.io/asia/terms. Any defined terms used in this Policy will have the same meaning as the equivalent defined terms in the Terms of Service, unless otherwise defined in this Policy.
Types Of Personal Data We Collect
When you interact with our Services, including when you contact us, or become a member, we may:
- collect information you voluntarily give us that alone or in combination with other information could be used to identify you (see examples in table below);
- receive certain information about your visit, use or interactions with the Services; and/or
- collect personal data from third parties.
We may collect, use, store, process and transfer different kinds of Personal Data about you and may continue to collect the below categories of information. For purposes of this Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to you. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
The table below includes non-exhaustive examples of the different categories of information we may collect.
| Categories Of Personal Data | Examples |
|---|---|
| Identity, Profile and Contact Personal Data | Your name, postal address, email address, account name, phone number, government issued identification number, driver’s license number, passport number or other similar identifiers |
| Characteristics of Protected Classifications | Age, gender and marital status |
| Unique and Online Identifiers | Your IP address, device IDs, browsing history, search history, and information on your interaction with a different website |
| Internet or Other Electronic Network Activity Information | Your settings, interaction with applications, advertisements or device information, including the name of the device and operating system, cookies and pixel tags, your city of login, the domains you come from (e.g., google.com, yahoo.com, etc.), and which browsers you used to access and visit our Site (e.g., Firefox, Chrome, etc.) and other data that your browser automatically sends. The types of information we collect depends on type of device used and its settings, which may indicate information on peak hours of Site visits, number of people visiting, broad geographical information and Site navigation patterns. |
| Internet or other electronic network activity information | Browsing history, search history, settings, and information regarding an individual’s interaction with an internet website, application, or advertisement, device information, including name of device and operating system, cookies and pixel tags, city of login, and other data that your browser automatically sends |
| Audio or Video Footage or other Visual Information | Any photographs, audio or video recordings, including any telephone conversations |
| Professional or Employment Information | The name of your employer or other information about your profession or place or work |
| Financial and Transaction Personal Data | Encrypted bank account details, payments to and from you, your orders of products/services from us |
| Marketing Preferences | Your preferences in receiving marketing from us and third parties and your communication preferences |
| Aggregated Personal Data | We may aggregate the information that we collect and use such aggregated data for commercial statistical, and market research purposes, including sharing it with affiliates, third parties and business partners. This data may include location information derived from your IP address or mobile device |
| Information from Publicly Available Sources or Personal Data | We may also collect personal data from third parties, such as parties that interact with us, including other financial institutions, product sponsors, business partners and contacts, service providers, background check companies, recruiters or referral sources, subscription information or analytic services, public sources, government records and sources, and other parties that interact with us or store information on our systems |
In addition, we may draw inferences about you based on the information you provide, such as individual preferences or characteristics, and we may collect and use information as described to you when collecting the information. We may also receive Personal Data that individuals provide to use or store on our system.
Cookies And Tracking
Cookies. In operating the Site and the Services, we may use a technology called "cookies". A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze usage more accurately. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
In order to personalize your use of the Site, we use local shared objects, also known as Flash cookies, to display content based upon what you view. Flash cookies are different from browser cookies (discussed above) because of the amount and type of information they generate, and how they store that information. Cookie management tools provided by your browser will not remove Flash cookies.
When you visit the Site or view one of our emails, we will use pixel tags or "clear" gifs to track links and/or similar technology to note some of the pages you visit on our Site and to personalize your experience. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.
Analytics and Tracking Technologies. We may, and we may allow third-party service providers, to use cookies (as noted above) or other tracking technologies (e.g., Google Analytics), to help us understand your use of our Site and collect information about your browsing activities over time and across different websites.
For more information on how Google uses this data, go to www.google.com/policies/privacy/partners. Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.
How We Use Your Personal Data
We will only use your Personal Data for the purposes for which we collected it. In the past 12 months, we may have collected and used Personal Data for the following purposes:
| Item | Purpose Of Personal Data Collection |
|---|---|
| 1 | To process and facilitate transactions and maintain accounts. |
| 2 | To operate, maintain, and improve the Site, products, and Services. This includes use of personal and other information to support delivery of our services under contract, assist with service requests, monitor for errors, remedy security or technical issues, and analyze website and application performances. |
| 3 | To communicate with you, respond to comments and questions, verify your identity and permission access, and provide customer service. |
| 4 | To send information including confirmations, technical notices, updates, security alerts, and administrative messages. |
| 5 | To communicate system updates, upcoming events, and other news and information about products and services offered by us. For instance, we may contact you to inform you about important services-related notices, such as privacy and policy updates or changes in our terms of service. |
| 6 | For statistical and business operations and planning purposes. |
| 7 | To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. |
| 8 | To comply with applicable laws, legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties. This includes assisting law enforcement and investigations conducted by governmental or regulatory authorities. |
| 9 | To improve, provide, and deliver products and services. |
| 10 | Any other purposes you have provided the information for or any incidental business purposes related to the above. |
We may also continue to collect and use Personal Data for these purposes for a reasonable period after your relationship with us has ended or changed. We do not sell any Personal Data or personal information collected by us to any other entity.
How We Share Personal Data
We may share your Personal Data with the following classes of persons.
In addition to the below, you may from time to time permission other users of Provenance to access your data, and we will act according to your instructions.
| Classes Of Persons With Whom We May Share Your Personal Data | Reason For Sharing Personal Data With These Persons |
|---|---|
| Business Transfers | As we develop our business, we might sell or buy businesses orassets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy, or similar event, Personal Data may be part of the transferred assets and may otherwise be shared with business partners and non-affiliates for the purposes of carrying out such transactions. |
| Affiliates, Non-Affiliates and Business Partners | We may also share your Personal Data with our affiliates and non-affiliates and our business partners for business purposes, including the processing of transactions. |
| Agent, Consultants, Vendors, and Service Providers | Like many businesses, we sometime hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. |
| Legal Requirements | We may also disclose your Personal Data to regulators/government agencies, or if required to do so by law,or in the good faith belief that such action is necessary to: |
- comply with a legal obligation or a court order;
- assist law enforcement or investigations by authorities;
- protect and defend our rights or property;
- prevent fraud;
- act in urgent circumstances to protect the personal safety of users of the Services or the public; or
- protect against legal liability. |
Information Access And Choice
You can contact us at +1 415-842-2588 or privacy@provenance.io Opens a new window. to do the following at any time:
See what Personal Data you provided through the Services and how such Personal Data is held by us. Access, obtain, change or correct any Personal Data you provided through the Services. Express any concern you have about our use of your Personal Data. Request we cease to collect, process or use your Personal Data. Request we delete your Personal Data Where you have asked for access or deletion of your Personal Data, we will endeavour to respond to requests as soon as practicable, and in any event generally not more than within 40 days after receipt of your request.
Do Not Track Signals
Our Site currently does not respond to "Do Not Track" (DNT) signals and operates as described in this Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Policy.
Age Limitations
The access to and use of our Services by anyone younger than 18 years old is prohibited and we do not knowingly collect the Personal Data of children under the age of 18. If you are under the age of 18, please do not access or submit any Personal Data through the Site.
We encourage parents and legal guardians to monitor their children’s internet usage to help enforce our Policy. If you learn that anyone younger than 18 has unlawfully provided us with Personal Data, please contact us in accordance with the "Information Access and Choice" section below and we will take steps to delete such information.
Links To Other Websites
This Policy only applies to information collected by Provenance through our Site. Our Site may contain links to other websites, apps or online services not operated or controlled by Provenance ( "Third Party Sites" ). The policies and procedures described in this Policy do not apply to Third Party Sites. Any data that you provide to such Third Party Sites will be governed by those Third Party Site’s’ relevant terms and conditions.
By providing links to Third Party Sites or services, we do not imply that we endorse or have reviewed such websites or services. Please contact those sites directly for information about their data practices and policies.
Security
You use the Services at your own risk. We will use reasonable endeavours, including technical and administrative measures, to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail and other communications sent to or from us in connection with the Services may not be secure. Therefore, you should take special care in deciding what information you send to us.
International Transfer Of Data
As we are based in the United States, if you use our Site or Services from outside the United States, your information will be transferred to the United States. We may use or share your Personal Data with our affiliates or other persons set out in this Policy in other jurisdictions including Singapore. This may involve disclosing, transferring, storing, processing and/or handling your Personal Data outside of the country where it was collected. If it is illegal to access our Site or transfer your Personal Data to the United States, please do not use our Site or Services.
How Long We Will Retain Your Personal Data
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or other requirements and we will take practicable steps to delete the Personal Data that is no longer needed by us.
If you would like to have further information about our data retention policies, please contact us in accordance with the "Information Access and Choice" section above.
Contact Information
If you have any questions, comments or suggestions about how we collect, use or disclose your Personal Data or this Policy or if you would like to exercise your rights relating to your Personal Data which we retain) you can contact us at +1 415-842-2588 or privacy@provenance.io Opens a new window.. You may also contact us at our address: Provenance Blockchain, Inc. 237 Kearny Street, #122, San Francisco, CA 94108.