MINA PROTOCOL

Privacy Policy

Last Updated: May 9, 2023

This Privacy Policy (“Policy“) describes how Mina Foundation, Inc. (“Foundation”,  “Company”,we”, “us” or “our” ) collects, uses, shares, and otherwise processes personal information in connection with minaprotocol.com site (the “Site”) that was created to provide information regarding Mina Protocol. This Policy also applies to any of the other websites that post this Policy. This Policy does not apply to websites that post different statements.

Who we are

Mina Foundation, Inc. is a public benefit corporation serving the Mina Protocol (the “Protocol”) and its ecosystem. You may contact us through email [email protected].


What Personal Information We collect and How We Use It

We get personal information about you in a range of ways.

Information You Give Us

  • Contact Information, including email address, and communication preferences. We use this information to fulfill your request, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
  • Inquiry and Communications Information, including information provided in custom messages sent through the forms or to one of our email addresses. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.

Information We Get From Others 

We may get information about you from third parties. We may add this to information we get from this Site.

  • Service Providers: Our service providers that perform services solely on our behalf regarding the Site, such as customer service and marketing providers, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, and information about your communications and related activities. We may use this information to administer and facilitate our services, our communications with you, and our marketing activities.
  • Other Users or Individuals who Interact with the Site: We may receive your information from other users or other individuals who interact with the Site. 

Additional Uses of Personal Information

We use your personal information as follows:

  • to operate, maintain, and improve this site.
  • to fulfill or meet the reason the information was provided.to communicate with individuals, to respond to comments and questions and provide customer service.
  • to send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.
  • to communicate upcoming events, and other news about the Protocol and ecosystem.
  • to provide and deliver services Site user’s request.
  • to identity and analyze trends, usage, and activities in connection with the Site.
  • to improve and customize services to address the needs and interests of the user base.
  • to test, enhance, update and monitor the Site, or diagnose or fix technology problems.
  • to help maintain the safety, security and integrity of the Site, technology assets and business.
  • to enforce Terms of Use, to resolve disputes, to carry out obligations and enforce rights.
  • to prevent, investigate or provide notice of fraud or unlawful or criminal activity.
  • to provide notification change of services, terms of use, policy. 
  • to meet other legitimate purposes, including to meet legal, regulatory, or other compliance obligations.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy notice will govern how we may process the information provided at that time. 


How We Use Cookies and Other Tracking Technology to Collect Information

We may collect information you provide to us and information about how you access and use the Site when you visit our sites, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Such information may include, but is not limited to

  • Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. 
  • Information about the way you access and use Site, for example, the site from which you came and the site to which you are going when you leave the Site, whether you open emails or click the links contained in emails, and other browsing behavior and actions you take on the Sites.
  • Information about how you use the Site, such as the pages you visit, the links you click, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Site and may record your mouse movements, scrolling, clicks and keystroke activity on the Site and other browsing. 
  • Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address. 
  • Analytics information. We may collect analytics data or use third-party analytics tools to help us measure traffic and allow us to improve your customer experience. 

All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve the Sites, advertising, communications and user service.  We may also use this information the data collected through tracking technologies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our Site; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website;  (e) diagnose or fix technology problems; and (f)  otherwise to plan for and enhance the Site.

We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Site, as some features may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and perform certain functions with it.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

Sharing of Personal Information

We may also share, transmit, disclose, grant access to, make available to provide personal information with and to third parties, as follows:

  • We may share personal information with your consent or direction. For example, you may let us share personal information with a third party for their own marketing uses. Those uses will be subject to their privacy policies.
  • We may share personal information with other companies under common ownership and control as Foundation. These companies will use your personal information in the same way as we can under this Privacy Policy.
  • We may share personal information with third parties who assist us in providing services and facilitating our communications with individuals that submit inquiries.
  • We may share personal information with other third-party service providers that perform operational services in related to the Site, such as website hosting, infrastructure provisioning, identity verification services, IT services, analytics services. 
  • 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 health and safety of us or others, such as in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
    • We may also share personal information where otherwise required by applicable law.
  • We may share information with those who perform operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.

Control over Your Information

You may control your information in the following ways:

  • Email Communications Preferences. You can stop receiving email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications.
  • Modifying or Deleting Your Information.  If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly. We may not be able to modify or delete your information in all circumstances.

 

Data Retention

We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with legitimate interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.


Links to Third-Party Websites Or Services

This Site may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.


Children’s Personal Information

Our Site is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

If you are under the age of 18 and you want to remove your name or comments from the Site or publicly displayed content, please contact us directly at [email protected]. If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).


CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”) affords residents certain rights with respect to their personal information. If you are a California Resident, please refer to this section for additional California-specific privacy information.

We collect personal information from and about users for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the What Personal Information We collect and How We Use It section of this Privacy Policy.

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law). You have the right to (i) request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity; (ii) request the deletion of personal information we have collected from you, subject to certain exceptions; (iii) request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of the consumer’s personal information. (iv) direct us not to sell or share personal information we have collected about you to third parties now or in the future. (v) not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you services or engage with you in the same manner. California residents that have an established business relationship with us have the right to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

 

HOW TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS

Please submit a request by emailing us at [email protected] with the subject line, “California Rights Request”; 

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your residence, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last interaction with the Site. 

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

 

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf. 

For requests to know, delete, or correct personal information, we require the following for verification purposes: 

  1. a power of attorney valid under the laws of California from you or your authorized agent; or 
  2. sufficient evidence to show that you have:
    1. provided the authorized agent signed permission to act on your behalf; and
    2. verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. 

For requests to opt out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.


Changes To This Privacy Policy.

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

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