Privacy Policy

This Privacy Policy describes how Foolproof Labs Inc (“Foolproof,” “we”, “us” or “our”) processes personal information that we collect through our digital properties that link to this Privacy Policy, including our website(s) and application(s) and software products (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.

We may generate tokens and interact with the public blockchain to provide services that support blockchain transactions, including services designed to enhance the security and speed of transactions. This Notice applies to those individuals who visit our Site and utilize our Services (“Visitors”).
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This Notice does not apply to third parties, including those that may be linked from [or support advertising accessible from or through] our websites. You should contact those parties directly to learn how they may use your information. This Privacy Notice does not apply to information that cannot be identified to any individual, household, or their devices.

Personal information we collect:

Information you provide to us. Personal information you may provide to us through
the Service or otherwise includes:

• Contact data, such as your first and last name, email address, phone number, and digital wallet.
• Profile data, such as the username and password that you may set to establish an online account on the Service, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, rewards programs, or polls, and any other information that you add to your account profile.
• Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
• Transactional data such as data obtained from a linked payment account (Linked Card or digital wallet) and information we obtain from other companies (Third Party Service Providers) related to the Services, including information about blockchain transactions such as merchant name, location, purchase amount, date and time, and applicable payment network (Coin/T oken/Card Payment Network). For clarity, our Third-Party Service Providers will not provide us with any 16 digit Linked Card account number. Please refer to the Third-party sources section below for details on our Third-Party Service Providers and links to their privacy policies for more information on how your digital wallet information is collected and processed by those providers.
• Marketing data, such as when you join our waitlist and your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content, such as profile pictures, photos, images, comments, questions, messages, works of authorship and creatorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted, edited, searched, tagged, and shared. Metadata also includes information that users can add or can have added to their content, such as keywords, tags, linked information, and other similar data.
• Financial data, such as your virtual currency or wallet accounts, stored value accounts, and associated details.
• Job application data, such as information you submit in connection with an application for a job (including information in a CV, resume or otherwise collected through the job application process).
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as social media platforms, public blockchain(s), and other publicly available sources.
• Third Party Service Providers, such as third-party services (e.g., Google (https://policies.google.com/privacy?hl=en-US) and Amazon Web Services Inc. (AWS) https://aws.amazon.com/privacy/) along with their affiliated companies) that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information, including transactions history and other financial data associated with your account on that third-party service that is made available to us based on your account settings on that service.
• Payment Networks related to the Service e.g., Coinbase, Visa Inc. (Visa), Mastercard Inc. (Mastercard), and American Express Company (Amex)) and their affiliated companies.

Other parties may collect personally identifiable information about your online activities over time and across third-party websites when you use our Services. We are not responsible, nor do we control, any personal information once collected by these parties. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.

Information we collect from third party sources. With respect to our Site and
Services, we may collect information from advertisers, affiliates, promotional partners, application providers. These and other third parties provide us information in connection with content, widgets, components, or other tools we offer. These third parties may collect information from these sources when you use our websites. The information third parties collect may be associated with your personal information or they may collect information about your online activities over time. They and we may use this information to provide you with interest-based advertising or other targeted content, and for other purposes (such as to better understand our Site’s audience).

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Location data only when you authorize (our mobile application/the Service) to access your device’s location.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations.

How we use your personal information
We may use your personal information for the following purposes or as otherwise
described at the time of collection:

Service delivery. We may use your personal information to:

Administer transactions related to the Service. Foolproof and its Third-Party Service Providers may use transactional data for the following purposes:

• to confirm a qualifying transaction for verification on whether you qualify for rewards;
• to share with the participating communities where a transaction occurred for the community to confirm a specific transaction occurred;
• to create a record of the transactional data and thereafter maintain and use data in connection with operating the Service;
• provide, operate and improve the Service and our business;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.
• To maintain, analyze, customize, measure, and improve our Services, which includes generating internal reports about the use of our Site.
• To monitor and enforce our legal terms or similar terms.
• For internal business reasons, including internal audits or investigations, company research, and insurance purposes.
• To otherwise operate our business
• For other purposes permitted by law or to which you consent.
• To provide customer support, such as replying to inquiries, handling complaints, and providing notices.
• To generate and provide a digital token (s) or enable our business customers to generate and provide you a digital token (s).
• For account management, finance, dispute resolution, and reporting purposes.
• To communicate with you by email and newsletter, including about products updates and offerings that we think they may be interested in.

Please note that we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our services, content and advertising.
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Research and development. We may use your personal information for research and
development purposes, including to analyze and improve the Service and our business.
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Marketing. We, our service providers and our third-party advertising partners may
collect and use your personal information to send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
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To manage our recruiting and process job applications. We may use personal
information, such as information submitted to us in a job application, to facilitate our
recruitment activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment statistics.

Compliance and protection. We may use your personal information (including, but not limited to, transactional data) to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To personalize your experience. We may use your personal information to personalize certain features and content for you, for example, we may use information about you to alert you to or share details about specific rewards that you may be eligible for or may be otherwise of interest to you.
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With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
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To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and analytics. In addition to the other uses included in this section, we may use the below technologies for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
• Choices. You have a number of choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly or at all as a result.

How We Secure Information. We are committed to maintaining measures to protect the security of your information. Of course, despite these measures, no network or system is ever entirely secure, and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf.
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

How we share your personal information

We may share your personal information with third parties including the following parties and as otherwise described in this Privacy Policy or at the time of collection, or as permitted or required by law, or as directed or authorized by you. For example, we may disclose your information to:
Affiliated third-parties. If you are a Visitor on our Site, we may share your information with advertisers and other promotional partners. We may share reports and insights about the way you are interacting with their content.
Protection by third-parties for the purposes of fraud protection and detecting
fraudulent transactions or other illegal activity. These other companies may use your personal information subject to their own privacy practices.
Third-parties you interact with. To those third parties you interact or transact with
when using our Services. These may include public blockchains, our business
customers, parties to transactions you complete, and others with whom you choose to interact when using a digital token issued by us or one of our business customers. They, and not Foolproof, are responsible for how they use your information when you transact with these parties or use us to support your transactions.
Our professional advisors. Any professional advisor who provides legal, compliance,
accounting, banking, consulting or other professional service to us.
For compliance. To comply with our legal obligations or to protect our interests,
property or legal rights, or those of our customers or third parties.
Linked Entities. We may share some or all of your information with our parent
companies, subsidiaries, joint ventures, or other companies under common control with us.
Misc. Legal. For other legal purposes, such as to enforce our terms and conditions, or to exercise or defend legal claims.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as digital asset management services, hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Linked third-party services. If you log into the Service with, or otherwise link your
Service account to, a social media or other third-party service, we may share your
personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Authorities and others. With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms.
Business transferees. Acquirers and other relevant participants in business
transactions (or negotiations of or due diligence for such transactions) involving a
corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Foolproof or our affiliates (including, in connection with a bankruptcy or similar
proceedings).
Other users and the public. Your profile and other user-generated content (except for private messages) may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to content you create and information you have entered, if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.
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We may disclose aggregated or deidentified information that does not identify any
individual without restriction.
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Please note that transaction and other related information describing your use of certain Foolproof services may be recorded on a public block chain. Public block chains are shared ledgers which have recorded historical transactions between you and other third parties. We are not responsible for how your information is used or shared on the public block chain. Because block chains are operated by third parties, Foolproof is not able to erase, modify, control, or otherwise alter your personal information on such public ledgers.

Your choices
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. You may send us an email at gm@foolproof.xyz to request to correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal
requirement, cause the information to be incorrect, or prevent the provision of our
Services.
Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track”
signals to the online services that you visit. We currently do not respond to “Do Not
Track” or similar signals. To find out more about “Do Not Track,” please visit
http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your
social media account or other third-party social platform option, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Unlink Connected Digital Wallets and Linked Card or opt-out of Services. You can
unlink your connected digital wallet, and any associated card(s) (if applicable) and opt out of the services at any time through the “Settings” section of your profile; under the “Linked” section you can choose to remove a connection by clicking the remove button for the item you wish to remove. Once you confirm removal, the asset will be unlinked from your account and all transaction monitoring associated with Foolproof will be ceased.
Delete your content or close your account. You can choose to delete certain content
through your account. You may delete your account at any time. This is accessed
through the “Settings” section of your profile, under the “Preferences” section you can delete your account by clicking the “Delete Account” button.
Other sites and services
The Service may contain links to websites, mobile applications, and other online
services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and
integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a
parent or guardian of a child from whom you believe we have collected personal
information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Updates to this Privacy Policy
We may update this Privacy Notice from time to time to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the bottom of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the primary email address specified in our records. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.