Version: 2 november 2023
This Policy is based on applicable relevant legislation on protection of personal data of the Netherlands, the General Data Protection Regulation of the EU, and other applicable relevant European laws.
The controller of data processing is PROxID BV, a legal entity being incorporated under the laws of the Netherlands. As a data controller, PROxID BV shall be responsible for processing and storing of your personal data.
In accordance with the legislation governing the protection of personal data, we may process your personal data on the following legal bases: (i) contract account: we process your personal data when such processing is required to complete the contract account which you have concluded); (ii) consent: we process your personal data when you have given consent for the specific purposes of processing, and you are always entitled to revoke that consent; (iii) legitimate interest: we process your personal data when Ciphers.me has a legitimate interest in processing; (iv) the law: when processing is necessary for the fulfillment of legal obligations.
In most cases, you provide us with personal data on a voluntary basis. The provision of personal data is mandatory in certain cases. It is obligatory to provide only the personal data that we collect based on the requirements of the legislation.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
(1) Information You Provide Us.
- We may collect Personal Data from you, such as your name and display name, e-mail and mailing addresses, Ethereum, Concordium and/or other wallet address, and Ciphers.me password when you create an account to log into our network (“Account”).
- If you use our Services on your mobile device, we may collect your phone number and the unique device id number.
- Our Service lets you store preferences like how your content is displayed, your location, safe search settings, notification settings, and favorite widgets. We may associate these choices with your ID, browser or mobile device, and you can edit these preferences at any time.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, Polygon, Ethereum, Concordium and/or other wallet address, and other requested information if you contact us via e-mail regarding support for the Services. We may also collect Personal Data at other points in our Service that state that Personal Data is being collected.
(2) Information Collected via Technology.
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Information Collected by Our Servers. To make our Service more useful to you, our servers (which may be hosted by a third party service provider within the European Union) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, Polygon, Ethereum, Concordium and/or other wallet address, wallet type, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
(3) Information Collected from Third Party Companies.
We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Service. These third-party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Service in order to improve it. We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
identify you as a user in our system;
- provide improved administration of our Service;
- provide the Services you request, including but not limited to facilitating your transactions through wallets;
- improve the quality of experience when you interact with our Service;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- send you e-mail notifications related to actions on Service
respond to your inquiries related to employment opportunities or other requests;
- in any other way we may describe when you provide the Personal Data;
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Ciphers.me by and Ciphers.me partners. At any time you can opt-out on the newsletters with offers and promotional materials.
We may use your Personal Data to contact you about our own and third parties’ goods and services that may be of interest to you.
- Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
(4) Disclosure of Your Personal Data.
- Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Service; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Ciphers.me.
- Other Disclosures. We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent. We do not sell your Personal Data.
You have several choices regarding the use of information on our Services:
- If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.
You can view, access, edit, or delete your personal data of the Service via your account page. You can also opt out from receiving marketing communications from us by using the opt-out link on the communication, or by visiting your account settings page. We may retain an archived copy of your records as required by law or for legitimate business purposes.
- Data Access. You can access your Personal Data on your profile page.
- Data Erasure. You may request that Ciphers.me delete your personal data by contacting us and including "Please delete my Personal Data" in the subject line. Ciphers.me will verify your ability to access that email, then delete the Personal Data associated with your email address.
- Data Correction. You can modify your Personal Data on your profile page.
Notwithstanding the aforementioned you have the following rights regarding the personal data processing:
(a) Access to personal data: You may request information from Ciphers.me whether we are processing your personal data, and if we do, you can request access to your personal data and information about the processing (which data is processed and from where this data originated);
(b) Correction of personal data: you may request from Ciphers.me to correct or complete your incomplete or inaccurate data being processed;
(c) Restriction of the personal data processing: you may request from Ciphers.me a restriction of the processing of your personal data (when, for example, checking accuracy or the completeness of your personal data);
(d) Deletion of personal data: you may request from Ciphers.me to delete your personal data (we cannot delete those personal data that we keep on the basis of legal requests or contractual relation);
(e) Printout of personal data: you may request from Ciphers.me to provide you with the personal data that you have provided us with in a structured, widely used and machine-readable form;
(f) Revocation of consent: you have the right to withdraw consent as to the use of your personal data, which we collect and process on the basis of consent, at any time. The revocation of the consent has no negative consequences, but it is possible that Ciphers.me will no longer be able to provide you with certain services;
(g) Objection to the processing of personal data: You have the right to object to the processing of your personal data when processing is for direct marketing purposes or in the event of transmitting your personal information to third parties for the purposes of direct marketing. You can also object processing when your data is used for direct marketing purposes using customized or individual offers ("profiling");
(h) The right to data transmission: you have the right to request the printout of personal data that you have provided us with.