This privacy policy (“Privacy Policy“) explains how the Shardeum Foundation, a Switzerland foundation (“Shardeum,” “our,” “we,” or “us”) collects, uses, and discloses information about you when you access or use https://shardeum.org (the “Site”) and any websites, software, technologies, features, and any other online products and services (collectively, the “Services”) provided or made available by Shardeum or any of its affiliates or subsidiaries.
Except as otherwise required by law, by using our Site or Services, by accepting our Terms and Conditions (at https://shardeum.org/terms-conditions/), or by providing some other form of implied or express consent, you accept this Privacy Policy in full without limitation. Your use of the Site and Services is subject to this Privacy Policy as well as our Terms and Conditions
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Site or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
A. Data We Collect
i) Information collected automatically, including:
Category
Description
App, browser, and device information
Information about the device, operating system, and browser you’re using; other device characteristics or identifiers (e.g. plugins, the network you connect to); IP addresses.
Product usage and analytics information
Shardeum uses third-party analytics services to gather information about how users interact with the website. This includes pages visited, links clicked, time spent on pages, what you view, how you use our Site and Services, and other usage metrics.
Diagnostic information
Information about how our Site and Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports.
Log Files
Standard web server logs collect data like your IP address, browser type, Internet Service Provider (ISP), date and time stamps of your visits, referring and exit pages, and the clicks you make.
Cookies and similar technologies
See Section D for additional information on what data is collected using cookies and similar technologies.
Location data
With your consent, Shardeum may collect approximate location information based on your IP address, through our mobile applications, or precise location data to provide location-based features and services.
ii) Information provided to us, including:
Category
Description
User information
Name, email address, encrypted password, postal address, phone number, company affiliation, attachments and documentation shared directly with Shardeum or through any account registration processes, and other information you provide to us.
Reference material
Newsletter subscriptions, blockchain eBooks, and any other information meant for informational or educational purposes.
User feedback
Suggestions, submissions, survey responses, feedback and other ideas or information you provide to us.
User content
Information, data, messaging, referrals, and content of any nature that you submit or otherwise upload to the Site or Services.
Sanctions screenings
Any information we collect related to verifying your identity and sanctions compliance, including but not limited to your name, domicile, government identification numbers, date of birth, and any other information or documentation you provide in connection with verifying your identity and sanctions compliance.
Preferences
The settings and preferences you select or modify when using the Site and Services.
iii) Information from other sources, including:
Category
Description
Shardeum affiliates and subsidiaries
We may obtain information about you, such as basic customer information, transaction information and product usage information from our affiliates or subsidiaries as a normal part of operations.
Analytics providers
Information about your usage and interactions when using the Site and Services (including information prior to account creation, in some cases).
Sanctions screenings
Shardeum may utilize third-party services to collect and store your name, domicile, government identification numbers, date of birth, and any other information or documentation you provide in connection with verifying your identity and sanctions compliance.
Marketing and advertising partners
Information related to advertising and marketing efforts, including in some instances what marketing content you viewed or the actions you take on our Sites or Services.
Third-party services have their own privacy policies that govern how your information is collected, used and shared. See Section F for additional information regarding third parties.
iv) Publicly available information, including:
Category
Description
Blockchain data
We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, smart contracts, transaction amounts, wallet addresses and other information available via any public blockchain.
Wallet information
Wallet addresses, integrations that you select, transitions you engage in, and other information connected to any crypto wallet that you control or engage with.
Transactional information
Any purchases, transactions, returns, trading, the date of any transaction, and other transaction information available via any public blockchain.
B. How We Use Data
To provide, operate, maintain, customize, develop, personalize, expand and improve our Site and Services including any features or technologies therein
To comply with any laws or regulations we may be subject to.
To provide customer support and respond to inquiries, surveys and feedback.
To promote the safety, security and integrity of the Site and Services, to investigate suspicious activity, to protect the Site and Services, to debug any issues, and to investigate any violations of law or violations of the rights of Shardeum or others.
To determine your legal eligibility to use certain products or features.
For our legitimate interests including but not limited to personalizing the Site and Services, engaging in advertising, research and development, and other lawful purposes.
To provide communications, updates, notices or other information related to the Site and Services.
To monitor and analyze trends, usage and activities in connection with the Site and Services.
To aggregate and/or de-identify data for research, reports, analytics or other summaries.
To enable our vendors and contractors to assist us and provide services.
To carry out any other purpose described to you at the time the information was collected, or as you otherwise consent to at the time of collection.
C. How We Share Data
To our third party service providers, identity and compliance providers, analytics providers, hosting providers, agents, affiliates and subsidiaries to assist in providing, delivering and improving the Site and Services.
To comply with our legal obligations such as compliance requirements, or when compelled by litigation, regulatory proceedings, subpoena, court order or other legal proceeding.
To prevent harm to users, Shardeum, the Site or Services, and to detect fraud, perform audits, and to enforce our agreement and policies, including our Terms and Conditions.
To protect against, investigate, and stop fraudulent, unauthorized or illegal activity, and to address security risks, software bugs and anything else that could harm Shardeum, the Site or Services.
We may transfer or share your data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business change transaction.
For legitimate purposes, while maintaining the privacy of the data, including to our lawyers or other professional advisors, or as otherwise needed to protect and manage our legitimate interests.
Consistent with any consent you provide us from time to time.
We may also share aggregate or de-identified information that cannot reasonably be linked to you or used to identify you, but only in accordance with applicable law.
D. Cookies
Like many other websites, we use cookies and other tracking technologies (such as pixels, APIs, tags, web beacons and other software) (collectively, “Cookies“). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). These technologies are used by most website and app providers to let users navigate between pages efficiently, ensure security of the webpage or application, understand how their websites are used, remember user preferences and generally improve the user experience.
There are also additional tools available to manage third party cookies. You can visit the DAA’s opt-out portal available at http://optout.aboutads.info/, the DAA of Canada’s opt-out portal available at https://youradchoices.ca/en/tools, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/ or or through your mobile device settings, where available and the DAA’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices
You have the right to accept or reject Cookies (except Cookies for necessary purposes).
You can view Cookies, manage your Cookie settings and withdraw consent at any time directly on the Site by visiting the footer upon first login
We use Cookies for the following purposes:
Necessary purposes – Necessary Cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These Cookies do not store any personally identifiable data. Necessary Cookies are essential for our Site and Services to function and therefore cannot be switched off. They are usually only set in response to actions made by you on the Site or Services. These also include Cookies we may rely on for security purposes, such as to prevent unauthorized access. You can set your browser to block or alert you about these Cookies at any time, but that may cause some features of our Site or Services to not work.
Functional purposes – Functional Cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features. Functional Cookies enable remembering the choices you make and to tailor our Site and Services to your preferences.
Analytics purposes – Analytical Cookies are used to understand how visitors interact with the Site and Services. These Cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, and other use and performance information. Analytics Cookies count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around, and may help resolve any errors or issues that occur on the Site or Services.
Performance purposes – Performance Cookies are used to understand and analyze the performance of the Site and Services which helps in delivering a better user experience for the visitors.
Advertisement purposes – Advertisement Cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.
Other purposes – Other Cookies may be utilized from time to time for various other purposes related to Shardeum and the Site and Services.
We may use Cookies and similar technologies third-party vendors provide to collect additional information. This information enables us to provide the Site and Services, to monitor and improve the user experience, to enhance and personalize your experience, and to track certain activity. We encourage you to consult the cookie settings and privacy policies of any third-party partners whose cookies may be in use.
The length of time a Cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session Cookies will only stay on your device until you close your browser. Persistent Cookies are set to automatically expire after a defined duration (for example, a few days, weeks or months).
The way we use Cookies may change from time to time to reflect, for example, changes to the Cookies we use or for other operational, legal or regulatory reasons. You should revisit this page and utilize our Cookie preferences feature to keep yourself updated.
E. Blockchain Privacy
Your use of any blockchain or digital assets may be recorded in a publicly viewable manner. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. The data recorded on many blockchains are open to public viewing and forensic analysis which may lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data. As blockchains are decentralized networks not controlled by Shardeum, we are not able to erase, modify, or alter personal data on such networks. We cannot edit or delete information that is stored on a public blockchain. Information such as your transaction data, blockchain wallet address, assets held by your address and other information may be publicly viewable and is completely beyond our control.
F. Third-Party Providers
We may integrate technologies or features operated or controlled by other parties into parts of the Site or Services (“Third-Party Services”). For example, the Site or Services may include features or links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with Third-Party Services, including when you leave the Site or Services, those parties may independently collect, use and share information about you. You use of Third-Party Services are subject to such third-party’s own terms and privacy policies which govern your use of those services, products or features, which you should review and accept, and if you do not accept such third-party terms or privacy policies you should not use such Third-Party Services.
G. Data Retention
We retain data as needed to provide our Site and Services, to comply with legal obligations, and to protect our legitimate interests. While retention requirements vary by country and type of data, our internal retention policies are based on how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Site and Services, whether we are required to hold the information to comply with our legal obligations, and other information preservation requirements and considerations. We also keep certain information where necessary to protect the safety, security and integrity of our Site and Services. Data collected by Third-Party Services are subject to their own data retention policies. Subject to this Section G, we delete information that is no longer needed, or when you exercise a lawful request for deletion of your data.
H. Security
We implement and maintain appropriate administrative, physical, and technical security safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee, ensure or warrant the security of any information or data. You are responsible for all of your activity on the Site and Services, including but not limited to the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys. We accept no liability for any information or data transmitted via the internet.
I. Children’s Privacy
The Sites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information or data through the Sites or Services. If a user submitting personal information is suspected of being younger than 18 years of age, we will require the relevant user to stop, and will take steps to delete that individual’s information as soon as possible. If you are a parent or guardian of a person under the age of 18, and you become aware they have provided personal information or data to us, please contact us at [email protected] and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. For additional information on COPPA protections refer to the Federal Trade Commission’s website.
J. Switzerland and European Union (EU) Privacy
The Shardeum Foundation, a Switzerland foundation, is the operator of any website published by the Shardeum, including, but not limited to the Site and Services and any affiliated subdomains or webpages. As the operator, we take the protection of your personal data very seriously. We collect, process, and use your personal data in accordance with this Privacy Policy and in compliance with the Swiss Federal Act on Data Protection (“FADP”), the Swiss Ordinance to the Federal Act on Data Protection (“OFADP”), and the General European Data Protection Regulation (“GDPR”). For any matters related to data protection or exercise of your rights related thereto, you may contact us using the contact information below in Section K.
To the extent provided under law, you may have the following rights:
Right to Confirmation – You have the right to obtain confirmation from Shardeum as to whether or not personal data concerning you is being processed.
Right to Access – You have the right to obtain from Shardeum free information about your personal data stored at any time and a copy of this information. Furthermore, you will have access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from Shardeum rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected directly from you, any available information as to their source; and
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
Right to Rectification – You have the right to obtain from Shardeum, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to Erasure (Right to be Forgotten) – You have the right to obtain from Shardeum the erasure of personal data concerning you as soon as possible, and Shardeum shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;
The personal data has been unlawfully processed;
The personal data must be erased for compliance with a legal obligation in accordance with the applicable law to which Shardeum is subject; and/or
The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
Right to Restrict Processing – You have the right to obtain from Shardeum restriction of processing where one of the following applies:
the accuracy of the personal data is contested by you, for a period enabling Shardeum to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and requests instead the restriction of their use instead;
Shardeum no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/or
the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of Shardeum override those of the data subject.
Right to Object – You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. Shardeum shall no longer process the personal data in the event of the objection, unless Shardeum can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims.
Rights to Data Portability – You have the right to receive the personal data concerning you, which you provided to Shardeum, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, where technically feasible, without hindrance from the controller to which the personal data have been provided, where:
the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
the processing is carried out by automated means.
Rights Related to Automated Decision-Making and Profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between you and Shardeum, or (2) is not authorized by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent. If the decision (X) is necessary for entering into, or the performance of, a contract between you and Shardeum, or (Y) it is based on your explicit consent, Shardeum shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.
Right to Withdraw Consent – You have the right to withdraw your consent to processing of your personal data at any time.
If you wish to exercise any of the rights mentioned above, you may contact us using the contact information below in Section K. We may require additional information from you to process your request.
We are entitled to transfer your personal data to third parties abroad or internationally for the purposes of the data processing described in this Privacy Policy. This includes but is not limited to: affiliates, agents, subsidiaries, and third-party service providers. They are obliged to protect data privacy to the same extent as we ourselves. If the level of data protection in a given country does not correspond to the FADP/OFADP and GDPR data protection levels, we will require protection of your personal data corresponding to the FADP/OFADP and GDPR at all times.
For more information on FADP, OFADP and GDPR, you may refer to:
If you have questions or concerns regarding this Privacy Policy, or if want to exercise any of the rights mentioned herein, please contact us at [email protected].