Cert Technology Ltd. ("Company" "we", "us", or "our") is committed to protecting your privacy, this policy describes our practices regarding Personal Data (as defined below) that we may collect, use, and share in connection with our websites, mobile apps, and other software provided on or in connection with our services, as described in our Terms of Use (collectively, the "Service"). Where this Privacy Policy uses the term "NFT" it 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 and where this Privacy Policy uses the term "Digital Pass" it means a digital card integrated into the users Apple and/or Google wallet and subject to the terms of use and privacy policy of the relevant wallet, Apple or Google, as the case may be.
"Personal Data" means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. "Anonymous Data" means data, including aggregated and de-identified data, from which you cannot be readily identified. We collect Personal Data and Anonymous Data as described below.
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including, without limitation, publicly available information from the blockchain and other non-publicly available information:
We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets' providers. We may add this to the data we have already collected from or about you through our Service.
We collect data from activity that is publicly visible and/or accessible on blockchain networks with which you may interact as you use the Service. This may include blockchain addresses and information regarding use of Digital Passes, purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us. Provision of this kind of data by users of blockchain networks is typically necessary to enable those networks to collect and record the transaction information necessary for them to function. The collection of that data is configured by the third party which originated the relevant network and we are unable to change or amend the way that any individual network operates or records transaction data.
We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.
We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.
We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Company; (c) to protect or defend the rights or property of Company or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.
Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
To use our Service effectively, depending on the Service you will also need Google or Apple wallets or a digital wallet provided by another third-party (many such services are available and we do not recommend or require any particular vendor) which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider, including Google and Apple, will be governed by the applicable terms of service and privacy policy of that third party, and you should read them carefully to ensure that you understand how they are likely to process your data. Please note that we are unlikely to be able to assist you with any queries or concerns that you may have which relate to processing of your Personal Data by the provider of a digital wallet, including Google and Apple.
You have several choices regarding the use of information on our Services:
You can view, access, edit, or delete your Personal Data for certain aspects of the Service via your Settings page. You may also have certain additional rights:
We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Service if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it (but please note that this does not apply to Personal Data which you have permitted to be stored on a blockchain network).
Company implements reasonable and appropriate physical, administrative and technical safeguards to help us protect your personal data from unauthorized access, use and disclosure, and to maintain accuracy and ensure the appropriate use of your information. Where appropriate, these safeguards include encryption. However, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. We believe that we have put in place appropriate physical, electronic, and managerial procedures to help safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. 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. For avoidance of doubt, you are responsible for the security of your digital wallet and Digital Pass, and we urge you to take steps to ensure they each are and remain secure. If you discover an issue related to your wallet, please contact your wallet provider.
We do not intentionally gather Personal Data from visitors who are under the age of 13. Our Terms of Service require all users to be at least 18 years old. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address indicated in Section 13 below.
If you are a non-UK user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and/or it may be transferred to, stored and processed in other countries, where laws regarding processing of Personal Data may be less stringent than the laws in your country. As a result, where the personal data that we collect through or in connection with the Services is processed in other countries, we will take steps to ensure that the information receives the same level of protection as if it remained within your home country. By providing your Personal Data, you consent to such transfer.
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at www.certhis.io and www.snapss.io . The date the Privacy Policy was last revised is identified at the end of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at [email protected] or [email protected] .
If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined in this GDPR Addendum (the "GDPR Addendum").
For this GDPR Addendum, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to identify a person, and "processing" generally refers to actions that can be performed on data such as its collection, use, storage or disclosure.
The Company will usually be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we may be the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Where applicable, this GDPR Addendum is intended to supplement, and not replace, our Privacy Policy. If there are any conflicts between the GDPR Addendum and the other parts of the Privacy Policy, and you are a resident of the EU, United Kingdom, Lichtenstein, Norway, or Iceland, the provision that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected] or [email protected] .
We currently collect and otherwise process the kinds of Personal Data listed above in Section 1 of our Privacy Policy.
We receive the Personal Data in the ways and for the purposes listed above in our Privacy Policy. We will only process your Personal Data if we have a lawful basis for doing so. Under the GDPR, the lawful basis we rely on for processing this information are:
In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. You can remove your consent at any time. You can do this by contacting us via email at [email protected] or [email protected] with the subject line "GDPR Request."
We process certain categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. These categories of Personal Data are:
We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
Our legitimate interests are:
We may be required to disclose Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Sections 2-3 of the Privacy Policy explain how we share your Personal Data with third parties.
Section 9 of the Privacy Policy explains how we protect your Personal Data. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us via email at [email protected] or [email protected] .
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected] or [email protected] . You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
If you have any concerns about our use of your Personal Data, you can make a complaint to us at [email protected] or [email protected] with the subject line "GDPR Request."
You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, the information that we have collected, including Personal Data, may be transferred to the surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Data as set forth in this GDPR Addendum.
The Services are hosted and operated in the United States ("U.S.") through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to a data processing agreement incorporating the modernized standard contractual clauses for the transfer of Personal Data to third countries promulgated by the European Commission on 4 June 2021, a copy of which can be obtained at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
If, in the future, we intend to process your Personal Data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Addendum, and the "Effective Date" at the bottom of this page will be updated accordingly.
Please reach out to [email protected] or [email protected] for any questions, complaints, or requests regarding this GDPR Addendum, and include in the subject line "GDPR Request."
