Last Modified: March 20, 2020

Tari Labs Privacy Policy

Tari Labs ("Company", "we", "our", or "us") recognizes that people who use our website and/or mobile applications (collectively, the "Services") value their privacy. This privacy policy (the "Policy") describes how the Services made available by Tari Labs collect, use, share, and store personal information of users of the Services. This Policy applies to the Services on or in which it is posted, linked, or referenced.

By using the Services, you accept the terms of this Policy and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our User Agreement, which governs your use of the Services. The User Agreement contains provisions that limit our liability to you and require you to resolve any dispute with us via arbitration on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR USER AGREEMENT, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message or offline.

If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.

WHAT WE COLLECT

Self-Custody of Personal and Transaction Data

We offer the Services to enable you to self-custody your Tari and similarly seek for you to self-custody your personal information and transaction history. Accordingly, the information we collect about you is very limited and generally for the purpose of providing and improving the Services we offer to you.

Active Collection of Information

We may collect certain information that you voluntarily provide to us which may contain personal information. For example, if you opt in to receiving communications from Tari Labs via email, we may collect your name and email address. We retain this information until you ask to be unsubscribed from our list(s). If you purchase any products from Tari Labs, we may collect shipping information (such as name and mailing address) from you in order to ship the products to you. We do not sell or otherwise transmit any such actively-collected personal information to third parties other than to third party service providers discussed in Section 4.

Passive Collection of Information

When you use the Services, some information about your visit is automatically collected. This information includes your IP address, access times, browser type and language, and referring web site addresses. We collect this information to troubleshoot technical issues, understand how visitors use the Services, provide an experience relevant to the general location associated with your IP address, and to make improvements to our website.

If you arrive at our website by clicking a link, then we may capture information that tracks your visit from that link.

USE OF PERSONAL INFORMATION

To provide the Services

We will use your personal information in the following ways:

  • To enable you to access and use the Services.
  • To optimize your user experience.
  • To provide and deliver products and services that you may request.
  • To measure interest in and develop the Services, diagnose technical problems and to generally administer the Services.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

To communicate with you

We use your personal information to provide you with information regarding the Services if you sign up for our mailing list.

We may use or share your personal information with your consent, such as when you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

For compliance, fraud prevention, and safety

We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

SHARING OF PERSONAL INFORMATION

We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

Affiliates

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Business Transfers

We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Compliance with Laws and Law Enforcement; Protection and Safety

We may share personal information for legal, protection, and safety purposes.

  • We may share information to comply with laws.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Professional Advisors and Service Providers

We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Services on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers. We will only provide these third parties with your personal information to the limited extent necessary to deliver the services.

We will obtain consent for such sharing with service providers where legally required. We enter into written agreements with these third-party service providers requiring them to provide the same level of protection for your personal information as provided under this Policy and limiting their use of your personal information to the specified services provided on our behalf. Such service providers include:

  • Shopify. We use Shopify's e-commerce platform to facilitate your purchases made from our website. Shopify stores your data on a secure server behind a firewall and encrypts your credit/debit card information in compliance with PCI DSS standards. You can review Shopify's privacy policy at shopify.com/legal/privacy. Shopify is certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.
  • Substack. We use Substack to send newsletters and related communications when you sign up for a newsletter subscription. You can review Substack's privacy policy at https://substack.com/privacy.
  • Twilio. We use Twilio to send SMS/text messages when you sign up for SMS notifications. You can review Twilio's privacy policy at https://www.twilio.com/legal/privacy. Twilio is certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.
  • Matoma. We use Matoma to track usage of the Services. You can review Matoma's privacy policy at https://matomo.org/privacy-policy/.

Other

You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.

We may also share aggregated and/or anonymized data with others for their own uses.

INTERNATIONAL TRANSFER

The Company has offices, affiliates and service providers both inside and outside of the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

EU users should read the important information provided below about transfer of personal information outside of the European Economic Area (EEA).

HOW INFORMATION IS SECURED

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our User Agreement, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider 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.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any user credentials or other form of authentication involved in obtaining access to password protected or secure areas of any of the Services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

INFORMATION CHOICES AND CHANGES

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Tari Labs aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information.

If you wish to be informed about what personal information we hold about you and if you want it to be removed from our systems, please contact us at [email protected].

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

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. T he right to object. You have the right to object to our processing of your personal information. The right of restriction. You have the right to request that we restrict the processing of your personal information. The right to data portability. You have the right to be provided with a copy of the information we have 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 Tari Labs relied on your consent to process your personal information.

Please note that we 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 information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.

CONTACT INFORMATION

We welcome your comments or questions about this Policy, and you may contact us at: [email protected].

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

ELIGIBILITY

If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.

NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

NOTICE TO EU DATA SUBJECTS

Personal Information

With respect to EU data subjects, "personal information," as used in this Privacy Policy, is equivalent to "personal information" as defined in the European Union General Data Protection Regulation (GDPR).

Sensitive Data

Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal information), including identification of your race or ethnicity on government-issued identification documents.

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described below. If you have questions about the legal bases under which we process your personal information, contact us at [email protected].

Use of data

We uses the collected data for various purposes:

  • To provide and maintain the Services;
  • To notify you about changes to and/or news and information about the Services;
  • To allow you to participate in interactive features of the Services when you choose to do so
  • To provide customer support;
  • To gather analysis or valuable information so that we can improve the Services
  • To monitor the usage of the Services;
  • To detect, prevent and address technical issues; and
  • To provide you with news and general information about other goods, services and events which we offer that are similar to those that you have already used.

If you are from the European Economic Area (EEA), Tari Labs' legal basis for collecting and using the personal information described in this Privacy Policy depends on the information we collect and the specific context in which we collect it.

Tari Labs may process your personal information because:

  • We need to perform a contract with you;
  • You have given us permission to do so;
  • The processing is in our legitimate interests and it is not overridden by your rights; and
  • To comply with the law.

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).

Retention of data

Tari Labs will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Tari Labs will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

YOUR RIGHTS

Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct. Update or correct inaccuracies in your personal information.

Delete. Delete your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restrict. Restrict the processing of your personal information.

Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfer

Please be aware that your personal information will be transferred to, processed, and stored in the U.S. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy.

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.