PRIVACY POLICY
This Privacy
Policy ("Policy") governs your visit to https://www.nemo.ceo
(“Website”) and explains how we (“Nemo”, “we”, “us”
or “our”) collects, uses, and discloses information results from your
use of the Website, if offered, and any other related and connected platforms
and other online and offline interactions, including but not limited to any
sales, marketing, or events (collectively, the “Services”).
Your use
of our Services is subject to our Terms of Service, available here. By using the Services, you accept and agree to the
practices described in this Policy. If you do not agree with this Policy,
please do not use the Services or provide us with any information that
(directly or indirectly) identifies, relates to, describes, or is reasonably
capable of being associated, linked or linkable with a particular individual or
household, including any information that is subject to applicable data
protection laws (“Personal Information”).
Where
our operations may be subject to different privacy legislation,
we will seek to comply with all such applicable laws and regulations to the
extent that it is possible for us to do so. Where there is a conflict between
different systems of laws, we will, in most cases, comply with the system of law
that imposes a stricter standard on us.
Please note that if you do not provide the
Personal Information we request, or if you withdraw your consent to the
processing of your Personal Information, then you may be unable to use the
Services.
Categories of Personal Information.
While the Personal Information we collect varies depending upon the
circumstances such as the nature of the Services provided or used and our
interactions with individuals, we may collect the following categories of
Personal Information (subject to applicable legal requirements and
restrictions):
§ Name, contact information and other
identifiers: identifiers such as a name, username,
account name, Web3 wallet address, email address, social media account, blockchain
address, address, phone number, birth date and online identifier.
§ Customer records:
electronic customer records containing Personal Information. We may also
collect your payment information as well, but note this is processed by our third party payment processor.
§ Device information:
internet protocol (IP) address, web browser type, operating system version,
phone carrier and manufacturer, application installations, device identifiers,
mobile advertising identifiers, and push notification tokens.
§ Protected classifications:
characteristics of protected classifications under applicable law such as race,
sex, age, and disability.
§ Communications:
direct communication, web forms, online polls, or interactions with our blogs
and posts.
§ Commercial information:
including records of Services purchased, obtained, or considered, or other
purchasing or use histories or tendencies.
§ Usage data:
internet or other electronic network activity information including, but not
limited to, browsing history, search history, and information regarding a
consumer’s interaction with an internet website, application, or advertisement.
§ Location data:
location information about a particular individual or device, general location
information.
§ Profiles and inferences:
inferences drawn from any of the information identified above to create a
profile reflecting a resident’s preferences.
Sources of
Personal Information. We may collect Personal Information
about individuals:
§ Directly from you: such
as when you create an online account with us (the “User Account”),
communicate on the Services, connect Web3 wallet and provide email address, participate
in a transaction, participate in promotions we offer, register to receive
marketing and other communications from us, or contact us for customer support
purposes.
§ From third parties: such
as affiliate and other third parties, social media software, public records,
third-party providers of services to us, social networks and joint marketing
partners.
§ Related to your use of our Services:
including information we collect automatically when you use our Website or
interact with us, or information we derive about you and your preferences or
interests based on the Personal Information we collect and our interactions
with you.
Information We
Collect from You. We may collect Personal Information
from you related to:
§ Registration, accounts and profiles: when
you register for a User Account with us, we may collect your blockchain
address, Web3 wallet address, username and/or email address; if you chose to
connect third party services such as social media to your User Account, we may collect
the information about those third party services; we
may also collect additional information such as your preferences and payment
details.
§ Marketing, surveys and events: if
you sign up to receive news, updates, offers and other marketing communications
from us, or attend any events hosted by us, we may collect your name, contact
information, and information about your preferences.
§ Your communications and requests: when
you email us, call us, or otherwise send us communications, we collect and
maintain a record of your contact details, communications and our responses.
Information We
Collect from Third Parties. We may collect Personal Information
about you from third-party sources (which may be combined with other Personal
Information we have collected about you), such as:
§ Third-party accounts: if
you connect your third party accounts to your User
Account, we may collect certain personal information about you from those third
parties.
§ Purchases,
orders and payments: if you purchase asset or sign up for
certain Services, we may collect information in order to process your payment
such as your name, billing address, payment type, as well as credit card number
or other payment account details.
§ Social media: if
you choose to link, create, or log in to your User Account with a social media
service, we may collect your permission to access certain information from your
profile with that social media service. If you post or if you engage with a
separate social media service or interact with us on our page with any social
media service, we may collect Personal Information about you related to those
interactions.
§ Other: we
may obtain Personal Information, such as demographic information or updated
contact details, from third parties; we may also collect information from
public records.
Information We Collect or Derive About You Automatically. We may collect
or derive Personal Information about your use of our Services, or other
interactions with us.
§ Website: We
and our third-party providers may use cookies, pixels, tags, log-files, and
other technologies to collect information about a user from their browser or
device, including, without limitation, your browser type, device type,
operating system, software version, phone model, phone operating system,
platform-dependent information, requested document, referring URL, date and
time of your visit, clickstream data (e.g., about the pages you view, links you
click and date and time stamps for your activities on our Website), and the IP
address associated with your transactions in the system. The information that
we collect automatically may be linked with other Personal Information we have
collected.
We will only
process your Personal Information where we have legal grounds to do so. We may
use Personal Information for a variety of purposes, including, without
limitation:
§ Providing support and services:
including to provide our Services, operate our Website and online services, and
interact with you on our Services; to respond to your inquiries; to provide
troubleshooting, fulfill your requests, process your payments and provide
technical support; and for other customer service and support purposes. Our
lawful basis is to fulfil any contractual terms with you.
§ Analyzing and improving our business:
including to better understand how users access and use our Services, to
evaluate and improve our Services and business operations, and to develop new
features, offerings, and services; to conduct surveys and other evaluations; to
monitor consumer interest in our Services; to troubleshoot problems that may
arise on the Services; to improve the accuracy of our customer database; to
increase our understanding of our customer and customer database; and for other
research and analytical purposes. Our lawful basis is our legitimate business
interests in understanding and improving our Services.
§ Personalizing content and experiences:
including to tailor content we send or display on our Website and other
Services and to otherwise personalize your experiences. To assist in these
purposes, as well as the other purposes identified in this Policy, at certain
times, we may create a profile relating to you in order to show you the content
that we think you might be interested in and to display the content according
to your preferences. Our lawful basis is: 1) our legitimate business interests
in offering a more personalized service; and 2) business improvement.
§ Advertising, marketing and promotional
purposes: including to reach you with more relevant ads
and to evaluate, measure and improve the effectiveness of our ad campaigns; to
send you offers or other information we think may interest you; to contact you
about our Services, or other information we think may interest you; and to
identify potential new customers. Our lawful basis is your consent to choose to
subscribe to any marketing (and you can unsubscribe at any time).
§ Securing and protecting our business:
including to protect and secure our business operations, assets, Services, network and information and
technology resources; to investigate, prevent, detect and take action regarding
fraud, unauthorized access, situations involving potential threats to the
rights or safety of any person or third-party, or other unauthorized activities
or misconduct. Our lawful basis is our legitimate business interests in
protecting our business and services.
§ Defending our legal rights:
including to manage and respond to actual and potential legal disputes and
claims, and to otherwise establish, defend or protect our rights or interests,
including in the context of anticipated or actual litigation with third
parties. Our lawful basis is our legitimate business interests in protecting
our business or our need to defend ourselves legally.
§ Auditing, reporting, corporate
governance, and internal operations: including
relating to financial, tax and accounting audits; audits and assessments of our
operations, privacy, security and financial controls, risk, and compliance with
legal obligations; our general business, accounting, record keeping and legal
functions; and related to any actual or contemplated merger, acquisition, asset
sale or transfer, financing, bankruptcy or restructuring of all or part of our
business. Our lawful basis is our legal obligations under relevant legislation
such as tax reporting and our legitimate interests in running our governance
programs.
§ Complying with legal obligations:
including to comply with the law, our legal obligations and legal process, such
as warrants, subpoenas, court orders, and regulatory or law enforcement
requests. Our lawful basis is compliance with applicable law.
§ For our legitimate business interests:
including our business interest in conducting and managing our business and
enabling us to give you the best service and the best and most secure
experience. We make sure we consider and balance any potential impact on you
(both positive and negative) and your rights before we process your Personal
Information for our legitimate interests. We do not use your Personal
Information for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by
law). Our lawful basis is this legitimate business interest.
Aggregate and
De-identified Data. We may de-identify information and
create anonymous and aggregated data sets and reports to assess, improve and
develop our business and Services, prepare benchmarking reports on our industry
and for other research, marketing and analytics purposes. De-identified
information is not Personal Information and we may use de-identified
information as allowed under applicable data protection laws.
We may combine
information from different sources. For example, we
may combine information that we have collected offline with information we
collect online, or we may combine information we get from a third-party with
information we already have.
If you submit any Personal Information
relating to other people to us, you represent that you have the authority to do
so and have informed that other person about the contents of this
Policy.
We may share or
disclose the Personal Information we collect as follows:
§ Service providers: We
may disclose Personal Information with third-party service providers who use
this information to perform services for us, such as hosting providers,
auditors, advisors, consultants, customer service and/or support providers.
§ Advertising and Marketing Partners: We
may share Personal Information with third parties that provide advertising,
campaign measurement, online analytics, and related services. These third
parties may receive or access browsing and/or other data about your use of the
Services, in order to help us better reach individuals with relevant ads and/or
measure our ad campaigns, and/or to better understand how individuals interact
with our Services overtime. We may also transfer Personal Information we
collect and/or join together with other businesses to bring selected
opportunities to customers or potential customers.
§ Subsidiaries, affiliates, and business
partners: We may share your Personal Information with
our affiliated companies; they may use such Personal Information for the
purposes set out in this Policy.
§ Legal compliance: We may be required to share Personal
Information in response to a valid court order, subpoena, government
investigation, or as otherwise required by law. We also reserve the right to
report to law enforcement agencies any activities that we, in good faith,
believe to be unlawful. In addition, we may share certain Personal Information
when we believe that doing so is reasonably necessary to protect the rights,
property and safety of our company and/or others.
§ Business transfers: We
may disclose and/or transfer Personal Information as part of any actual or
contemplated merger, sale, transfer of assets, acquisition, financing and/or
restructuring of all or part of our business, bankruptcy or similar event,
including related to due diligence conducted prior to such event where permitted by law.
§ Protect our rights: We may disclose
Personal Information where we believe it necessary to respond to claims
asserted against us, to enforce or administer our agreements and terms, for
fraud prevention, risk assessment, investigation and/or to protect the rights,
property or safety of Nemo or our affiliates, partners, clients, customers
and/or others.
Aggregated
and De-identified Data. We may share aggregate or
de-identified information with third parties for research, marketing,
advertising, analytics and/or other purposes.
Our Services are
restricted for users of legal age and children under the age of 18 are not
allowed to use our Services. Nemo does not knowingly collect or maintain
Personal Information from children we actually know at the time of collection
are under the age of 18. Should we discover that we have collected Personal
Information online from a child who is under 18, we will promptly delete that
Personal Information.
The security of
your Personal Information is important to us. We have put in place safeguards
to protect the Personal Information we collect from unauthorized access, use
and disclosure, and we take steps to ensure that all of our employees, agents,
contractors and other third parties have similar adequate measures in place. We
also have procedures to deal with any suspected Personal Information breach,
and we will notify you and any applicable regulator when we are legally
required to do so. However, we cannot guarantee that unauthorized access,
hacking, data loss, or other breaches will never occur. We urge you to take
steps to keep your Personal Information safe, such as choosing a strong
password and closing your web browser when finished using the Services.
For other users. If we transfer
your Personal Information to countries outside of your home country, we will
take steps to comply with the requirements for such transfer in your home
country as required by relevant law.
The Services may
from time to time contain links to various websites operated by third parties.
This Policy does not apply to third-party websites that are accessible through
the Services, unless such website directs users or visitors to this Policy.
When you click on one of these links, you will be transferred out of the
Services and connected to the website of the organization or company that
maintains that website. Even if an affiliation exists between us and a
third-party website, we exercise no control over linked websites. Each of these
linked websites maintains its own independent privacy and data collection
policies and procedures. We encourage you to read the privacy policies of those
other websites to learn how they collect, use, share, and secure your
information before providing any Personal Information.
Except to the
extent prohibited by law, and subject to this Policy, we will retain and use
your Personal Information no longer than is needed for the fulfillment of the
purpose for which it was collected. As soon as it is reasonable to assume your
Personal Information is no longer needed or required, we will cease to retain
your Personal Information, or remove the means by which the data can be
associated with you.
This Policy is
kept under regular review and may be updated from time to time. When we make
changes to this Policy, we will change the "Last Updated" date above.
If a material change is made to this Policy, we may provide notice to you by
posting notice or via email. You are advised to review this Policy periodically
for any changes. Changes to this Policy are effective when they are posted on
this page.
It is important
that the information we hold about you is accurate and current. Please keep us
informed as soon as possible if your Personal Information changes or is
inaccurate during your relationship with us by using the contact details set
out below.
If you have any
concern about our privacy practices, please contact us by email support@nemo.ceo.