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PRIVACY POLICY

Revised: July 19, 2023

This privacy policy sets out how Suku Labs, Inc. (“SukuLabs,” “we,” “us,” or “our”) uses and protects any information that SukuLabs receives when you use its services, including, but not limited to SukuLabs’ platform, Suku Wallet, SukuPay, Sukuthis, various websites, SMS, APIs, email notifications, applications, buttons, widgets, ads, commerce services and other covered services provided by SukuLabs and its affiliated companies (collectively, the “Services”), and any information, text, links, graphics, photos, audio, videos, or other materials or arrangements of materials uploaded, downloaded, stored, transmitted through or appearing on the Services.

We may change this policy from time to time by updating this page.

WHAT WE COLLECT

  1. Data collected on the basis of consent
  2. Contact and Personal Information.  Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data), which we can use for any purpose.  
  • Name
  • Contact information including email address and phone number
  • Information about your company
  • Any other information that you send to us through a form or email
  1. Information that you provide to us
  • Name, email address, phone number, or other contact information
  • Company affiliation, title, role, or other company information
  • Contents of emails
  • Your interests in our products or Services
  1. Data collected on the basis of legitimate interest
  2. Website viewing behavior
  3. We collect information on how our website is used that does not contain any personally-identifying information. We may use this information for any purpose, including but not limited to understanding our website performance, the most interesting pages, browsing behavior, and other purposes.
  4. Financial information which may include your wallet, billing and payment details or other payment-related information.
  5. Transaction Data which may include details about payments to and from you and other details of your transactions with us.
  6. B2B website behavior

We may collect B2B information from website visitors for a legitimate B2B purpose.

  • Name, email address, and phone number
  • Company name
  • Title and/or role within the company
  • Pages viewed
  • Date and time of viewing
  • Time spent on pages and total time on site

HOW WE COLLECT YOUR INFORMATION

We use different methods to collect information from and about you including through:

  • Direct interactions. You may give us information about you by filling in forms or by communicating with us by text, e-mail, or otherwise. This includes information you provide when you register for an account, subscribe to one of our newsletters or other communications, conduct a search, place an order, engage in a promotional event, complete a survey, or when you contact us about one of our websites, products, or services. We may also collect information when you respond to our request to voluntarily provide information regarding your personal or professional interests, demographics, experience with our products, and contact preferences.
  • Automated technologies or interactions. As you interact with our websites or websites employing our cookies, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, web beacons, and other similar technologies. Our Cookies section contains more information and options to control or opt-out of certain data collection or uses.
  • Third parties or publicly available sources. We may receive information about you from third parties including, for example, our affiliated companies, business partners, sub-contractors, analytics providers, and service providers. If you enter a co-branded promotion, that is being sponsored by Solo and another party, our co-sponsor may provide us with information about you.
  • User contributions. You also may provide information to be published or displayed (“posted”) on public areas of the websites or transmitted to other users (collectively, “User Contributions”). For example, if you review one of our products, then your product review may be made available on public areas of our websites.  

CHILDREN’S DATA

We do not direct our websites to minors, and we do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us using our Contact email addresses below.  

WHAT WE DO WITH THE INFORMATION WE GATHER

We require this information to provide you with Services, and in particular for the following reasons:

  • We may use the information you provide us to verify your identity and comply with laws concerning financial fraud or counter-terrorist financing.  
  • We may use the information to improve our products and Services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or mail. We may use the information to customize the website according to your interests.
  • We use the information you share with us to understand your interest in our company and our products or Services.
  • To use data analytics to improve our website, products or services, marketing, customer relationships, and experiences.
  • To carry out our obligations and enforce our rights.
  • We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the website.  

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our service in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better service, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

Third-Party Cookies

We use third-party services which may place cookies on your computer with your consent or for a legitimate purpose.

DISCLOSURE OF YOUR INFORMATION

We may share non-personal information without restriction. We may share your personal information:

  • For a legitimate purpose to any member of our corporate group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries, and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To our business partners who provide services on our behalf that you request but who may also use the information we provide for their own commercial purposes. For example, some of our advertising partners may use information to market other parties’ products and services to you.
  • To public or government (including enforcement) authorities.
  • To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.
  • If we offer a co-branded promotion, to our co-sponsor.
  • To fulfill the purpose for which you provide it, including use of services such as AWS, Polygon and Opensea, whose privacy policies you are responsible for reviewing and accepting.
  • For any other purpose as may be permitted by law or that we describe when you provide the information.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce our Terms of Use and other agreements with you.
  • To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.
  • To investigate suspected violations of any law, rule or regulation, or the terms or policies for the website.

We do not pass your information to anyone else apart from our business services partners as necessary to provide you with the products and services you have requested. We do not use your information for individual profiling without your permission.

LINKS TO OTHER SERVICES

Our Services may contain links to other services of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those linked services. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to each service visited.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the service, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing to the destination in the Contact Us section below.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

If you believe that any information we are holding on you is incorrect or incomplete, please email to the destination in the Contact Us section below. We will correct any information found to be incorrect.

YOUR RIGHTS AND CHOICES

Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.

OPT-OUT

You may opt-out of data collection and processing by choosing the appropriate privacy settings on our website or by making a request through our Contact Us section below. We will honor the request to opt-out unless a legal exception applies. Opting out of sharing your personal information with us also may discontinue your participation in the Services.

ACCESSING, UPDATING AND DELETING YOUR INFORMATION

If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, you can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of 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 or negatively affect the information’s accuracy.

COOKIES AND AUTOMATIC DATA COLLECTION TECHNOLOGIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”) updated by the Consumer Privacy Rights Act (“CPRA”), requires us to provide the following notice to California residents.

This notice does not apply to employment-related information of California-based employees, job applicants, contractors, or similar individuals. Where noted in this notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B information”) from some of its requirements.

Sharing your personal information for commercial or other purposes

We have not shared any of your personal information with business partners and other third parties in a manner that is likely to be considered to be a “sale” under the CCPA.

Your right to know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide access rights to B2B information.

Your right to obtain a copy of your personal information

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you a copy of your personal information that is responsive to your request.

We do not provide portability rights to B2B information.

Your right to delete your personal information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We do not provide deletion rights to B2B information.

Your right to opt-out of the sale of your information

We may share information with third parties in a way that is considered a “sale” under the CCPA. Where that is the case, we will comply with California “Do Not Sell” requirements.

OTHER CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please see the Contact Us section below.

NEVADA PRIVACY RIGHTS

Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.

EUROPEAN USERS - GDPR PRIVACY RIGHTS

This GDPR Privacy Notice is a supplement to our Privacy Policy and concerns certain personal data we have collected about residents of the countries in the European Union, consisting of the European Economic Area, Switzerland, and to the extent that the United Kingdom is no longer a member of the European Union, the United Kingdom (the “EU” or the “European Union”). It explains why we have that information, how we use and handle it, and your rights to that information, all as required by the European Union’s General Data Protection Regulation (“GDPR”).

Cross Border personal data transfers.

Your personal data may be transferred to and stored at our servers located in the United States. The United States has personal data privacy laws that are different from your country. While the United States has not received an adequacy decision from the European Union Commission, we will ensure that it is protected in a manner that is consistent with how your personal data is protected if it was processed in your country.

Legal Bases for Processing

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 in the table below. If you have questions about the legal bases under which we process your personal information, contact us at labs@suku.world.

Processing Purpose

Legal Basis

To provide our service

Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Service.

To communicate with you
To optimize our platform
For compliance, fraud prevention, and safety
To provide our service

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).

To comply with law

We use your personal information to comply with applicable laws and our legal obligations, including anti-money laundering (AML) laws and know-your-customer (KYC) requirements.

With your consent

Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at privacy@consensys.net.

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.

What are my personal data rights?

You have the following rights concerning your personal data that we hold and process that you can exercise at any time:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct personal data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the personal data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the personal data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to judicial review – in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the process below.

All of the above requests will be forwarded on to other parties holding and processing your personal data where appropriate.

PERSONAL DATA REQUESTS

HOW TO EXERCISE YOUR CCPA RIGHTS

To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by either contacting us at the email in the Contact Us section.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

HOW TO EXERCISE YOUR GDPR RIGHTS

To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by contacting us using the information in the Contact Us section.  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 privacy@consensys.net or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Who may submit requests?

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

If you are a resident of California, you may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

How often can you submit requests?

You may make a CCPA consumer request twice within a 12-month period. You may make a GDPR personal data request once within a 12-month period.

Response timing and format

We make every attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity easily.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

Who do I contact if I have an issue with my personal data that you hold?

Please see our Contact Us section below.

How do I make a complaint about how my personal data is being held or processed?

If you wish to raise a complaint on how we handle your personal data, you can contact our Privacy Officer using the information in the Contact Us section below.

EXCEPTIONS

We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance), GDPR, or other governing authority. In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

QUESTIONS, DISPUTES AND CHANGES

Your use of SukuLabs' Services and any dispute over privacy is subject to this Privacy Policy and our Terms of Use. If you have any concerns about your privacy with respect to SukuLabs' Services, please contact us with a complete description, and we will try to resolve it.  You also have the right to contact your local Data Protection Authority. We reserve the right to update and revise this Privacy Policy from time to time. Please review this Privacy Policy regularly to ensure that you are aware of its terms.  Any use of SukuLabs' Services after an amendment to our Privacy Policy constitutes your acknowledgement and acceptance of the revised or amended terms to the fullest extent permitted by law.

CONTACT US

For privacy-related requests you may contact us at one of the following:

  • By Email: labs@suku.world
  • By Mail: Attn: Privacy Officer, 3250 NE 1st Avenue, Miami, FL 33137

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