Arnac is a technology provider, and its Product and services are intended to assist customers to hold and manage their digital assets, connect to decentralize applications (DApps), and manage their transactions. For the avoidance of doubt, Arnac is not a custodian of your digital assets.
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
(i) We Process the following Personal Information:
A. Information You Provide Directly to Us. We collect Personal Data you provide directly to us, including:
B. Automatic data collection. We may automatically collect certain information through your use of the Product, such as cookie identifiers and other device identifiers, analytic tools, log files and tracking technologies (“Technologies”) that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Product.
(ii) We Process Personal Information for the following purposes:
C. To provide you with the Product. Arnac will use your information to provide the Product, including: (i) to allow you to download and install the Dashboard, Mobile Application and Browser Extension; (ii) to allow you to make use of the Product; (iii) to allow you to create your admin user and to generate regular users and administer their privileges, (iv) to allow you to administer your wallet, your keys, addresses, and digital assets; (v) to allow you to administer your transactions, an in particular to process, authenticate (e.g., via the Mobile Application), allow you to sign, send to the blockchain, and monitor your transactions (when activated and requested by you, for example, in the context of initiating transactions through the Browser Extension or initiating transfers through the Dashboard), (vi) to allow you to connect your wallet to decentralized applications (e.g., Uniswap, Compound, OpenSea); (viii) to communicate with you, provide you with support and maintenance; and (x) to personalize your experience with the Product.
2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
2.1. Data stored by Arnac: The data stored by Arnac will, in order to allow the functioning of the Product.
2.2 Data stored on the blockchain: Transactions that you perform through Fordefi’s Product will be sent to the blockchain. These transactions and their associated data will be stored on the blockchain perpetually, without any way for deletion, since the blockchain is a decentralized and open-source network. Please note that, given the nature of the blockchain, the effectiveness of the security measures depends on the efforts of a decentralized network of miners, validator nodes and proof-of-stake participants, among other participants in the blockchain network.
2.3. IF YOU DISAGREE WITH THIS SECTION 2, PLEASE DO NOT USE OUR PRODUCT.
3. HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal Data as follows:
3.1. Data stored by Arnac:
a) With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
b) We may use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation:
c) To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
d) If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
e) In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
f) Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
3.2. Data stored on the blockchain: The information stored on the blockchain will be shared with anyone accessing the blockchain network, since the blockchain is a decentralized and public protocol, which could include parties that are located outside from your country or jurisdiction. Please note these parties may be located in countries and jurisdictions that do not approach or protect your privacy rights as in your jurisdiction. In any event, please note that sharing data with such parties is necessary for providing the services at hand.
3.3. IF YOU DISAGREE WITH THIS SECTION 3, PLEASE DO NOT USE OUR PRODUCT.
4. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
4.1. Data stored by Arnac: Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
4.2. You can exercise your rights by contacting us at firstname.lastname@example.org. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.3. Data stored on the blockchain: IMPORTANT NOTE: TRANSACTIONS THAT YOU PERFORM THROUGH FORDEFI’S PRODUCT WILL BE SENT TO THE BLOCKCHAIN. THESE TRANSACTIONS AND THEIR ASSOCIATED DATA WILL BE STORED ON THE BLOCKCHAIN PERPETUALLY, WITHOUT ANY WAY FOR DELETION, SINCE THE BLOCKCHAIN IS A DECENTRALIZED AND OPEN-SOURCE NETWORK.
4.4. IF YOU DISAGREE WITH THIS SECTION 4, PLEASE DO NOT USE OUR PRODUCT. We and our services do not perform any processing activity for the purposes of making automated decisions or profile you in any manner.
5. USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. We do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at email@example.com.
6. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
7. LOG FILES. We use log files. We use such information to analyze trends, administer the Product, track users’ movement around the Product, and gather demographic information.
8. ANALYTIC TOOLS
9. CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org.
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