SSV NETWORK – PRIVACY POLICY
Last Updated: March 12, 2023
Introduction
Welcome to the SSV Network site (www.ssv.network) a website-hosted user interface (the "Site") for the SSV Network. The Site provides interface-only access to and information about the SSV Network, a distributed and non-custodial infrastructure for proof-of-stake validation (the “Platform”). The Platform is built, maintained, and governed by the SSV community (the “Protocol”, and the "DAO", respectively). The Site is operated by Coin-Dash Ltd and its affiliates (collectively, "Company", “we”, “our”, or “us”).
We are committed to protecting the privacy of anyone who accesses and uses the Site. We have published this Privacy Policy ("Policy") to outline our practices with respect to collecting, processing, and disclosing the information collected from anyone who uses, accesses, or interacts with the Site ("Users", "You", "Your"). By accessing or using the Site, you agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue using the Site.
This Policy applies to you in addition to the Site's Terms of Service[YS1] . We encourage you to read these Terms and Policy carefully before using the Site.
Please be mindful that the Site offers interface access to the Platform, which is operated by the DAO, and also may include “hyperlinks” to other third parties sites. The Company is not responsible in any way for the privacy practices on the Platform or other third parties sites and advises you to review the privacy policies on those linked sites before using them.
If you have any questions or wish to exercise your rights and choices, please contact us at the email set forth in the "Contact Us" section below.
What types of data do we collect?
While you are using the Site, we collect and process your Personal Data ("Personal Data"). For the avoidance of any doubt, and pursuant to the definition provided by The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC ("General Data Protection Regulation", "GDPR"), "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Please note that the processing of your Personal Data could be, in certain cases, required to allow the maintenance of the Site or to respond to one of your inquiries. This is especially the case when you decide to directly contact, for example via mail or through the use of a website form. In any case, we will specify to you when and where such a processing activity of your Personal Data is non-optional.
Furthermore, in the event that you would have to communicate us Personal Data of a third party, you commit yourself to make sure that this Data Subject has been duly informed of the processing activity over his or her Personal Data pursuant to the provisions of this present Privacy Policy.
This section sets out the types of data collected from you.
Identification information
When you are using the Site, we process some of your contact and identification information. This includes your wallet address and username.
We also collect some information from the device you are using to access the Site that can indirectly identify you, including your location data, IP address, browser type and version, device, OS version and plug-ins.
Communication information
When you send us an email or contact us via the Site, we collect the Personal Data you provided us. This may include your name, email address, company name, country of origin, phone number, address, and any other information that you chose to share with us.
Usage information
When you visit our website, we collect technical information about your interaction with the Site. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), browser type and version, as well as other information which relates to your activity through the Site.
We may also utilize Tracking Technologies (defined below), including cookies, pixels, beacons, local storage, and similar technologies. Further information regarding the use of Tracking Technologies will be described in Section 8 below.
Why do we process your Personal Data?
The above-mentioned collected data is processed for the hereafter listed purposes and legal bases.
In any case, please note that we won't process your Personal Data for any incompatible purpose with the operation of the Site and its improvement.
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Purpose |
Legal basis |
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Performance of services through operating and maintaining the Site. |
The legal basis for this processing activity is the performance of our contractual obligations towards our users. |
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Promotion, development, and improvement of our offer of services, especially through the use of data analytics, marketing, and advertising tools. Please note that if you do not want us to use or share your Personal Data for advertising or marketing purposes, you may opt out of certain Tracking Technologies, following the instructions laid down in Section 8. |
The legal basis for this processing activity is our legitimate interest and business purpose to develop the reach of the Site and promote tailored services, content, and advertisements that better fit users' interests. |
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Efficiency of our customer support services such as answering inquiries, questions and globally developing our client community. |
The legal basis for this processing activity is our legitimate interest and business purpose to offer an efficient and complete customer experience to users and potential users. |
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Compliance with applicable laws. |
We may be legally required to collect, retain, or share your Personal Data in order for us to remain compliant with regulatory obligations. |
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Managing a potential or current litigation. |
The legal basis for this processing activity is our legitimate interest to defend our rights and interests in courts. |
With whom do we share your data?
We share your Personal Data with various persons in specific situations as described below:
- Group members and affiliates: we may share your information with various relevant affiliates of the Company related to the Site.
- Partners: we may share your information with our partners and IT service providers for the purpose of operating and maintaining the Site.
- Compliance with laws and law enforcement entities: we may disclose your personal data to government bodies, law enforcement officials, courts, or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual's Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
- Professional advisors: we may share personal data with our attorneys, accountants, auditors, financial and other professionals who provide professional and corporate services to the Company.
- Merger and acquisitions: We may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.
EU and UK residents
This section addresses the specific rights applying to residents of the EU or residents in other jurisdictions that afford the below rights.
Your rights
The European and UK Data protection legal framework grants any European or UK Data Subject various rights over its processed data, especially:
- To receive confirmation as to whether or not your Personal Data is being processed, and access your stored Personal Data, together with supplementary information.
- To withdraw, at any time, your consent to the processing activity, when it was initially based on this very consent, without harming the legality of the prior processing activity.
- To receive a copy of Personal Data you directly volunteer to us in a structured, commonly used, and machine-readable format.
- To request a rectification of your Personal Data that is in our control.
- To request the erasure of your Personal Data.
- To object to the processing of your Personal Data.
- To request to restrict processing of your Personal Data.
- To request the transfer of your Personal Data.
- To determine what to do with the processed Personal Data after the death of the Data Subject.
- To lodge a complaint with a supervisory authority.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
To exercise any of the above-mentioned Data Subject's rights, please directly address your request to: info@ssv.network.
Transfer of data outside the EU or the UK
Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy. However, we will only transfer your data to data recipients that are either (i) located in the European Economic Area (the “EEA”), either (ii) non-located in one of the EEA countries but rather in one that has been approved by the European Commission as providing an adequate level of data protection, or (iii) entered into legal agreements ensuring an adequate level of data protection following the definition approved by the European Commission the European applicable legal framework and the European Court of Justice relevant case-law, or the UK Information Commissioner's Office ("ICO"), as applicable, regarding data protection and privacy.
California, Virginia and Colorado Residents
This section address the specific rights applying to residents of California, Virginia, Colorado, or other jurisdictions that afford the below rights. This section is based on the California Consumer Privacy Act of 2018 (“CCPA”), Virginia Consumer Data Protection Act ("VCDPA") and Colorado Consumer Privacy Act ("CPA"), (collectively, "US Regulations")
Selling of Personal Information
We do not “sell” the personal information we collect (as such a term is defined in the US Regulations) for monetary value.
Your rights
As a resident of any of the US Regulations' jurisdiction we grant you various rights regarding the Personal Information we collect, especially the following:
- To request information regarding how we have collected, used and shared your Personal Information during the past 12 months.
- To access your information, by requesting a copy of your Personal Information.
- To delete the Personal Information, we maintain about you.
- If, in the future, we will sell your Personal Information, you will have the right to opt out. In such case, there will publish a "Do Not Sell My Information" link in the App.
- To receive non-discriminatory treatment for the exercise of your privacy rights.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
To exercise any of the above-mentioned Data Subject's rights, please directly address your request to: info@ssv.network.
You may empower an "authorized agent" (as defined in the US Regulations) to submit requests on your behalf, subject to a written authorization.
How do we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data.
While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud, or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Site or acted inappropriately, please contact us directly through the contact details available below.
Retention
We will retain your Personal Data for as long as necessary to operate our Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
Our use of Tracking Technologies
When you visit our Site, we use cookies, pixels, beacons, local storage, and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation on the Site, improve the Site's features, perform analytics and customize your experience.
What types of Tracking Technologies do we use?
When you use or access the Site, we use the following categories of Tracking Technologies:
(a) Strictly Necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access the Site or take certain actions. These Tracking Technologies are essential to enable you to navigate around and use the features of the Site. We do not need to obtain your consent in order to use these Tracking Technologies.
(b) Functionality Tracking Technologies: these Tracking Technologies allow the Site to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged in) and support other features of the Site;
(c) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit to the Site), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research, and performing statistics (based on aggregated information).
How and by whom Tracking Technologies are stored on your device?
We store Tracking Technologies on your device when you visit or access the Site– these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on the Site– these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit to our Services or repeat visits.
How can you manage your Tracking Technologies?
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include: changing your browser settings; you may also install a browser extension, such as Disconnect or Ghostery, to block third party tracking cookies on our website. However, please note that certain features of the website may not work properly or effectively if you delete or disable cookies.
To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies. However, please remember that by deleting or blocking cookies, some of the features of our Services may not work properly or effectively.
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:
European Interactive Digital Advertising Alliance (EU)
Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on the Site (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use the Site after any revisions become effective, you agree to be bound by the updated Policy.
Further Information
If you have any further questions regarding the data collection, or how we use it, please contact us by email at info@ssv.network.