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Privacy policy

Last Updated: July 1, 2022

This Privacy Policy should be read together with our Cookie Policy and Terms of Use

This Privacy Policy (“Privacy Policy” or “Policy”) sets forth how Blade Labs Inc. (together with Blade Labs DMCC, Blade Foundation Ltd. and our affiliates or subsidiaries, “Blade,” “we,” “us,” or “our”) will comply with the privacy laws and regulations applicable to Blade in connection with personal information collected through all of Blade’s related websites, mobile applications, downloadable software, products, services, including our plug-ins and browser extensions (collectively, the “Products”). This Policy also covers how and when Blade will collect, retain, process, share, and transfer users’ personal data, including nonpublic personal information (“NPPI”). 

The Blade Wallet is a non-custodial, self-sovereign Web3 portal –launched on the Hedera network – that equips individuals with the ability to manage their digital assets. Specifically, the Blade Wallet allows individuals to:

  • Store digital assets
  • Exchange digital assets
  • Connect to blockchain-based applications 

Blade does not take custody of any users’ digital assets. Users maintain their own cryptographic keys and retain exclusive access to their digital assets in the normal course of business.

The Blade Wallet is currently available as an internet browser extension.

Scope of this Policy

This Policy applies to Blade’s Products. This Policy applies to all Blade employees, regardless of tenure, position, or employment status. Where Blade engages with an unaffiliated third-party to perform services on behalf of Blade in relation to the Blade Wallet, Blade will ensure the third-party has suitable internal controls to meet this Policy. 

Definitions

Term Definition
Data Processing Data Processing means performing any operation or set of operations on data, including:

  • Obtaining, recording, or keeping data;
  • Collecting, organizing, storing, altering, or adapting data;
  • Retrieving, consulting, or using data’
  • Disclosing the information or data by transmitting, disseminating, or otherwise making it available; or 
  • Aligning, combining, blocking, erasing, or destroying data. 
Nonpublic Personal Information Personally identifiable financial information means any information that a User provides to Blade to obtain a financial product or service from Blade, information about a User resulting from a transaction involving Blade and the User, and other information obtained about a User in connection with Blade providing financial products or services to the User. 
Personal Data Any information about an identifiable individual. Examples of Personal Data include (but are not limited to):

  • Name, date of birth, and social security or other identity card number;
  • Contact information such as mailing address, email address, and phone numbers; 
  • Financial information such as credit card and account numbers; 
  • Transaction information; or
  • Health or medical information.
User An individual who downloads and/or uses the Blade Wallet.

 

Policy Standards

It is Blade’s policy to comply with all Privacy-related regulatory requirements applicable to Blade in connection with Blade’s Products. This Policy is intended to help Users understand:

  • What information we may collect about you
  • Justifications for engaging in Data Processing
  • How we secure information we collect
  • How to access and control your information
  • How we may transfer information we collect internationally
  • Other important privacy information

What information we may collect about you

We collect information about you when you provide it to us, either directly (for example, by email or social media channels officially operated by Blade), or through a third party, as well as information gathered during your tenure with Blade. We collect and use information for various reasons, including but not limited to:

  • To provide you with feedback on incidents (including, but not limited to, questions, bugs or complaints) you raise directly with us.
  • To provide you with updates on changes (including bug fixes, new features and revised content) where you have already engaged with us by raising an incident.
  • For job candidates, we seek specific consent on the application to assess candidate suitability for an open role, and to verify information provided during the recruitment process.
  • To perform accounting and other record-keeping functions.
  • To provide personnel, payroll, and other administration services.
  • To record your employment history with Blade.
  • To record any training, professional development, and performance metrics.
  • To exhibit your profile (name, picture, role) on our website team page.

Justifications for engaging in Data Processing

Some of the justifications for engaging in Data Processing include, but are not limited to:

  • The performance of a contract to which the data subject is a party;
  • Compliance with a legal obligation; or
  • For the legitimate interests of the data controller, unless such interests are overridden by the interests or rights of the data subject. 

How we secure information we collect

Blade will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of both electronic and manual data. Security measures will be reviewed from time to time, having regard to the technology available, the cost, and the risk of unauthorized access. 

How to access and control your information

You are entitled to request data held about you and Blade will, in most circumstances, provide this data within one month. In some cases, because of the complexity of the request or the number of requests being handled, Blade may require a further one month to provide this data. There is no charge for requesting this data. If you are requesting data, you should make a request in writing to policies@bladelabs.io, stating the exact data required. You are only entitled to access data about yourself and will not be provided with data relating to other people or third parties.

If Blade does not own or control the data you request, we will inform you.

How we may transfer information we collect internationally

Blade operates internationally, so it may be necessary in the course of business to transfer a person’s personal data within the organization. The transfer of such data is necessary for the management and administration of your data within the group. When this is necessary, the organization will take steps to ensure that the data has the same level of protection at all times. For more information, please contact us at policies@bladelabs.io.

Other important privacy information

Web browsing. By simply website you do not disclose, nor do we collect, personal data on you. All that we may know about your visit may be limited to technical data such as:

  • The logical address (or IP address) of the server you used to access this website.
  • The top-level domain name from which you access the internet (for example, .ie, .com, .org, .net).
  • The previous website address from which you reached us.
  • The type of web browser you used.
  • Web traffic data.

The technical data may be used for administrative and statistical purposes, and may be shared with our internet service provider. We may use this information to help us to improve our website. This technical data does not provide us with the personal data of visitors to our website.

Cookies. We use cookies to collect data to improve your experience. You can learn more about what cookies are and how we use them in the Cookies Policy

Your rights if you are a California resident

If you are a California resident, you have certain rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). This section applies to you.

We are required to inform you of: (i) what categories of information we collect about you, including during the preceding 12 months, (ii) the purposes for which we use your personal data, including during the preceding 12 months, and (iii) the purposes for which we share your personal data, including during the preceding 12 months. 

You have the right to: (i) request a copy of the personal information that we have about you; (ii) request that we delete your personal information; and (iii) opt-out of the sale of your personal information. You can limit the use of tracking technologies, such as cookies, by following instructions in the “Your choices” section. These rights are subject to limitations as described in the CCPA.

We will not discriminate against any consumer for exercising their CCPA rights.

If you would like to exercise any of these rights, please contact us at policies@bladelabs.io

Rights Under General Data Protection Regulation

If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. Blade aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data Blade holds about you and if you want it to be removed from our systems, please contact us at policies@bladelabs.io

In certain circumstances, you have the following data protection rights:

  • The right to access. You have the right to request information concerning the personal information we hold that relates to you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to your personal information being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
  • The right of restriction. You have the right to request that Blade restricts the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information Blade has on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Blade relied on your consent to process your personal information.


Please note that Blade may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU or EEA.

New Products and Jurisdictions

As Blade launches new products and services, Blade will review and update this Privacy Policy, and implement suitable procedures and internal controls to satisfy regulatory requirements applicable to Blade’s products and services.

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