This Privacy Policy (“Privacy Policy”) describes how Archway Services Ltd. and its affiliates (“Archway”, “we,” “us,” or “our”) may collect, use and disclose information, and your choices regarding this information. Please read this document carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information in accordance with the applicable law. If you do not agree with the terms of this Privacy Policy, do not access or use the Site, Services or utilize any other aspect of our business. By using the Site and Services, you agree to this Privacy Policy.
1. Applicability of this Policy
This Privacy Policy applies to your use of Archway’s website or web applications, (altogether the “Site”) and related services (collectively, the “Services”).
This Privacy Policy does not apply to your use of the Archway Protocol and/or software, which is open source and maintained by a distributed network. However, if you access the Archway Protocol-related content from a hyperlink on our Site, we may collect the information described in the “Information We Collect Automatically” section below in connection with your use of the Site.
2. What We Collect
Information We Collect Directly From You.
The information we collect from you depends on how you use our Services. Information we collect may include:
- Identity Information: when you use the Services, we may collect information such as your name, e-mail address, mailing address, and phone number. Where necessary, we may be required by applicable law to collect information to verify your identity, such as government-issued identification documentation.
- Contact Information: If you contact us or if you subscribe to receive updates from us about new features available on our Site or through the Services, we collect records and copies of your correspondence, including e-mail addresses and other contact information.
- Marketing Information. Your preferences, including preferences for receiving marketing communications from us and how you interact with our marketing communications.
- User Communications. Personal opinions and information you share with us when you contact us with questions, ask for support, provide Feedback, respond to surveys, or any other information you provide to us directly or indirectly through your interactions with us.
Information We Collect Automatically.
Cookies. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies to record your preferences, track the use of our Sites and mobile apps, 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, date/time stamp, and clickstream data, and information about your interactions with the communications we send to 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. More information about how this Site uses is outlined in the Cookies section of this Policy.
Blockchain Data. Public blockchain data including blockchain addresses and crypto-asset transaction information related to those blockchain addresses.
Aggregate Data. Analytics about aggregate numbers of users and usage types (i.e., number of page views, event counts, and aggregate acquisition metrics), and information such as how many users in the aggregate are using certain protocols with assistance of Services; and aggregate location data across users including countries and regions from which users access the Services or the Site.
3. How We Use Information
We use your information in accordance with your instructions, 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. This includes using information to:
- To present our Site and their contents to you, or to provide you with access to the Services;
- To provide you with information, products, or services that you request from us
- Operate, maintain, customize, measure, and improve our Services, and manage our business;
- Create and update user accounts;
- Communicating with you, including responding to your requests or inquiries and for customer service purposes;
- To notify you about changes to our Services, or any products or services we offer or provide through the Services;
- Marketing and advertising our Services and expertise and for other marketing, advertising, and promotional purposes, such as to contact you about products or services we think may interest you;
- To manage the security and operation of our Site, networks and systems, including to prevent, detect, and investigate fraudulent, abusive, or harmful activities.
- To create de-identified or aggregated data in order to analyze, develop, improve and optimize the Site and Services;
- Any other purposes, as allowed by law or with your consent.
Research and Development:
We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us 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 to determine your eligibility to access the Services 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.
4. Use of Cookies and other Identifiers
We use cookies and similar tools to enhance your user experience, provide our Services, and understand how users interact with our Services so we can make improvements, including to enable our Site to recognise your browser or device. We use operational cookies and similar tools (collectively, "cookies") to provide our Services, for example:
- Recognising you when you sign-in to use our Services.
- Providing customized features and services.
- Preventing fraudulent activity.
- Improving security.
- Keeping track of your preferences.
- We also use cookies to understand how users use our Services so we can make improvements.
Google Analytics
Our Site uses Google Analytics cookies for the purpose set out above. You may exercise choices regarding the use of cookies from Google Analytics by accessing https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
5. How We Share & 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 own 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 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 User Agreement or any other applicable policies.
With Services Providers: We may share your information with service providers who help facilitate business and compliance operations such as marketing and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us.
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, 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 and/or anonymized data with others for marketing, advertising, research, or other purposes.
Analytics Providers/Advertisers: We may share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Typically, this information is collected from you through cookies and other tracking technologies on our Site.
6. Your Rights
If you are located in the EEA or the UK, you have certain rights in relation to your personal information, you are entitled to certain legal rights in relation to your Personal information.
- Right to Access: you have the right to request access to any of your personal information that we hold, and to obtain information about the processing of that data.
- Right to Correct: we will take steps in accordance with applicable legislation to keep your personal information accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal information corrected (that is, rectified).
- Right to Erasure: you are entitled to have your personal information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal information is unlawfully processed.
- Data Portability: where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party, and the personal information is processed by automated means, you have the right to receive all such personal information which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to Restriction of Processing: you may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your personal information where permitted or required by applicable law.
- Right to Withdraw Consent: in the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.
7. Legal bases for processing
If you are an EEA resident, Archway processes your personal information on the following legal bases under the General Data Protection Regulation (“GDPR“):
- where we have your consent;
- where use of your personal information is necessary to perform our obligation under a contract with you;
- where use of your personal information is necessary for our legitimate interests or the legitimate interest of others; and
- where use of your personal information is necessary to comply with a legal obligation.
8. Data Retention
We will retain your personal information on file for as long as necessary for the purpose of processing your data. Please note that in certain cases, legal or regulatory obligations require us to retain specific records for a longer period of time.
9. Security
We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure. 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 Archway protocol relating to any of your network addresses and/or cryptocurrency wallets.
10. Notice Concerning Children
Our Services are not designed for people under eighteen (18) years old. If we discover that a person under thirteen (18) has provided us with personal information, we will delete such information from our systems.
11. Changes to this 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.
12. 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 [email protected] or at our mailing address at:
Archway Services Ltd.
Floor 4, Banco Popular Building, Road Town, Tortola
British Virgin Islands, VG1110