Privacy Policy
Last updated: January 13, 2023
We at NFEX respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy (the “Policy”) describes how NFEX Limited and its affiliates (“NFEX,” “we,” “us” or “our”) may collect, use and disclose information, and your choices regarding this information when you access our services which include our content on our website or any successor websites, pages, features, or content we own or operate (collectively, the “Site(s)” or the “Services”).
“NFT(s)” in this Privacy Policy means (a) non-fungible token or similar digital item implemented on a blockchain (such as the Ethereum blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data.
Please read this Policy carefully before using the Services. You may contact us at contact@nfex.io if you have any questions about this Policy.
Applicability of This Policy
This Policy applies to the Sites and the Services (in each case, as defined in the Terms of Use). If you do not agree with the terms of this Policy, do not access or use the Services, the Sites, or any other aspect of our business.
What Personal Information We Collect
Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide us, information which is collected about you automatically, and information we obtain from third parties. This definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy.
Information you provide to us: To access our Services, we’ll ask you to provide us with some important information about yourself. This information is either required by law, necessary to provide the requested services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.
When you interact with our Services, we may collect:
Contact Information, such as your name, email address, physical address and country information. Financial Information, such as your Ethereum network address, cryptocurrency wallet information, transaction history, trading data and associated fees paid.
Transaction information, such as information about the transactions you make on our Services, such as the type of transaction, transaction amount, and timestamp.
Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat or social media messaging channels.
Online identifiers, such as username, geo location or tracking details, browser fingerprint, operating system, browser name and version, and IP addresses.
Usage and Diagnostics Data, such as conversion events, user preferences, crash logs, device information and other data collected via cookies and similar technologies.
Information We Get from Others. We may get information about you from other sources as required or permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from this Site in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.
Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of our Sites, including our mobile applications, and collect information about the use of the Services, as well as about our interactions with you. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, device information, date or time stamp, and clickstream data, and information about interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may not function properly.
Public information observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain address and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.
How We Use Information
We use your information in accordance with your instructions, including any applicable terms in the Terms of Use, and as required by applicable law. We may also use the information we collect for:
Providing Services and Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as we described in the Terms of Use. This includes using information to:
operate, maintain, customize, measure, and improve our Services, and manage our business;
create and update user accounts;
process transactions;
send information, including confirmations, notices, updates, security alerts, and support and administrative messages; and
to create de-identified or aggregated data.
Safety and Security. We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
monitor and verify identity or service access, combat spam, malware or security risks;
perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other products or services; and
comply with applicable security laws and regulations.
Customer Support. We may use information we collect to provide customer support, including to:
direct questions to the appropriate customer support person;
investigate and address user concerns; and
monitor and improve our customer support responses and processes.
Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes and develop new features and products relating to our Services.
Legal and Regulatory Compliance. We may verify your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications about our Services features promotions, surveys, news updates, and events, and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at contact@nfex.io.
How We Share and Disclose Information
We may share your information in the following circumstances:
With Your Consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
To Comply with Our Legal Obligations. We may share your information:(a) to cooperate with government investigations;(b) when we are compelled to do so by a subpoena, court order, or similar legal procedure;(c) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person;(d) to report suspected illegal activity; or (e) to investigate violations of our Terms of Use, agreements for other products or services, or any other applicable policies.
With Service Providers or Other Third Parties. We may share your information with service providers or other third parties who help facilitate business and compliance operations, such as marketing and technology services.
During a Change to Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may share aggregated or anonymized data with other persons for their own uses.
Data Retention
We store your information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of our personal information are described below:
Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g., to prevent a known fraudulent actor from opening a new account).
Recording of our telephone calls with you may be kept for a period of up to six years.
Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
Notwithstanding the above, you can view, access, edit, or delete your Personal Information for certain aspects of the Service via your settings pages. We cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.
Security
We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure and require our third-party service providers to have appropriate safeguards. No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure. You are responsible for all activity on the NFEX protocol relating to any of your Ethereum work addresses or third-party wallets.
Age Limitations
To the extent prohibited by applicable law, we do not allow use of our Services or Sites by anyone younger than 18 years old. If you learn that anyone younger than 18 years old has unlawfully provided us with personal data, please contact contact@nfex.io and we will take steps to delete such information, close any such accounts, and, to the extent possible, prevent the user from continuing to use our Services.
Third-Party Links and Sites
We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with these other parties, including when you leave the Site, those parties may independently collect information about you and solicit information from you. You can learn more about how those parties collect and use your data by consulting their privacy policies and other terms.
Third-Party Wallets
To use our Service, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.
Changes to This Privacy Policy
If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Sites.
Online Tracking Opt-Out Guide
Like many companies online, we use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies-such as cookies and web beacons-to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest- based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies or trackers.
Platform opt-outs. The following advertising partner offers opt-out features that let you opt-out of use of your information for interest-based advertising at https://adssettings.google.com. You can learn more about how Google uses your information by reviewing Google’s privacy policy at https://policies.google.com/privacy.
Advertising industry opt-out tools. You can also use the opt-out options set forth below to limit use of your information for interest-based advertising by participating companies. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use( Digital Advertising Alliance: http://optout.aboutads.info; Network Advertising Initiative: http://optout.networkadvertising.org/ ).
Privacy Practices
We do not “sell” the personal information we collect for monetary value (and will not sell it without providing a right to opt out). Like many companies, we may use third-party cookies for our advertising purposes. If you would like to learn how you may opt out of our use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide section of this Policy.
Additional Disclosure for Our Consumers and Customers (“Additional Disclosure”)
This Additional Disclosure governs our collection, use and sharing of personal information that users provide to us to initiate or complete the process of trading on the NFEX protocol. To the extent there are conflicting provisions between this Additional Disclosure and other sections of this Policy, this Additional Disclosure will govern.
The types of personal information we collect and share can include:
Contact details
IP addresses
Trading history
Digital Asset balances and wallets
Conversion events
Notwithstanding anything to the contrary in this Policy, when you are no longer our customer, we continue to share your information as described in this Additional Disclosure.
Reasons We Can Share Your Personal Information
We need to share users' personal information to operate certain aspects of the NFEX protocol and our business. Whether we share your personal information, the reasons for which we share your personal information and whether you can limit this sharing include the following:
We share users’ personal information for our everyday business purposes, such as to process and match your orders and respond to court orders and legal investigations. You cannot limit our sharing of this information.
We share users’ personal information for our marketing purposes, such as to offer our products and services to you. You cannot limit our sharing of this information.
We do not share users’ personal information for joint marketing with financial companies.
We do not share users’ personal information for our affiliates’ everyday business purposes
We do not share users’ personal information for our affiliates to market to you.
We do not share users’ personal information for our affiliates’ everyday business purposes.
We do not share users’ personal information for our affiliates to market to you.
We share users’ personal information for nonaffiliates to market to you.
How Does NFEX Protect Personal Information?
We care about the security of your information. To protect your personal information from unauthorized access and use, we use security measures that comply with applicable laws. These measures include computer safeguards and secured files and buildings. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.
How Does NFEX Collect Personal Information?
We collect your personal information, for example, when you deposit Digital Assets in the NFEX protocol, make trades using the NFEX protocol, or withdraw crypto assets and/or NFTs from the NFEX protocol.
We may also collect your personal information from other companies.
Why Can’t Limit All Sharing?
Applicable laws give you the right to limit only (a) sharing for affiliates’ everyday business purposes, (b)affiliates from using your information to market to you, and (c) sharing for nonaffiliates to market to you.
State laws, regional laws and individual companies may give you additional rights to limit sharing.
As used in this Additional Disclosure section, “affiliate” refers to companies related by common ownership or control; “nonaffiliates” refer to companies no related by common ownership or control; and “joint marketing” refers to a formal agreement between non-affiliated financial companies that together market financial products or services to you.
Contact Us
Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at contact@nfex.io.
Last updated