Privacy Policy
Last updated : February 14, 2024
This Privacy Policy (this “Policy”) describes how Polygon Labs UI (Cayman) Ltd. and its affiliates (“Polygon Labs”, “us” or “we”) may collect, use and disclose information in connection with your access and/or use of any Interface or Features. Your use of the Interfaces and Features is subject to this Policy as well as our Terms of Use and any documents and additional terms or policies that expressly incorporate the Terms of Use (collectively, the “Terms”). Please read this Policy and the Terms carefully to ensure you understand them. Capitalized terms not defined herein have the same meaning as in the Terms.
This Policy does not apply to any products, services, websites, or content offered or provided by third parties and Polygon Labs is not responsible in any way for those third party offerings; please review any separate privacy policies made available by those third parties.
We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.
Any modifications to this Policy will be effective upon our posting of the updated Policy. In all cases, your continued use of the Interfaces or the Features following the posting of any updated Policy indicates your acceptance of the updated Policy.
1. Information We Collect
a. Information You Give Us
When you access the Site, we may collect the following information:
- When you opt in to various programs, sign up to receive marketing information, send in support requests/provide feedback or otherwise voluntarily interact with us or the Interfaces:
- ~Contact information, such as name, email address, profile picture, user name, or social media information.
- ~Your preferences for receiving marketing information and communications from us.
- Your public wallet address when you connect your wallet to access certain Features
b. Information Collected Automatically
We may collect automatically certain limited information when you access, use, or interact with any Interface or Features, such as:
- Device type, browser type and version
- Operating system and version
- IP address
- Publicly available blockchain 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 Features; and aggregate location data across users including countries and regions from which users access the Site or Features
For information about how we use tracking technologies, please see our Cookie Policy.
c. Information Collected from Third Parties
We may receive additional information about you from third parties we work with (including contractors, collaborators, service providers, and analytics providers). This information may be combined with other information you provide to us or that we automatically collect.
2. How We Use Information
We may use information about you to:
- Provide, maintain, support and improve the Interfaces and Features and respond to inquiries related to the same;
- Comply with our legal and regulatory obligations, as or if necessary;
- Prevent, detect and investigate fraudulent, abusive or harmful activities;
- Allow you to personalize or personalize your experience with the Interfaces or the Features;
- Facilitate events and provide information to you about events;
- Provide support for the Interfaces and the Features, including resolving issues and responding to your questions and feedback;
- Comply with law if we have a legal obligation to collect, use or retain information about you or comply with legal requests like subpoenas or requests from government authorities;
- Analyze usage trends to permit access to the Interfaces or provide the Features;
- Enforce the Terms, this Policy and/or other policies; and
- Take certain actions that you have asked us to and provided consent for us to take.
You agree and acknowledge that we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
3. How We Share Information
We may share certain information about you with third parties, such as service providers, professional advisors, affiliates and others. We may share information about you with individuals and entities that provide services to us or help us operate the Interfaces or the Features, such as marketing, event hosting, logistics planning, analytics, email delivery, and database management services, as well as other professional service providers providing services to us. Any such sharing of information will be in accordance with this Policy.
We may share information with third parties when we enter into a business transaction, including mergers, acquisitions, reorganizations, or a sale or transfer of all or part of our organization or assets.
We may share information about you when we believe release is necessary to comply with law, enforce the Terms and other agreements with you, or protect the rights, property, or security of Polygon Labs, our agents and employees or users. This includes sharing information with other organizations for fraud prevention and detection purposes.
You may permit us to share your information with other entities or individuals of your choosing. Those uses will also be subject to the privacy policies of the entities or individuals receiving the information.
4. Location of Information
Please be aware that information collected through the Interfaces or the Features may be transferred to, processed, stored, and used in the Cayman Islands, and other jurisdictions. Data protection laws in the Cayman Islands and other jurisdictions where we have affiliates may be different from those of your country of residence. Your use of the Interfaces or the Features or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the Cayman Islands and other jurisdictions as set out in this Policy.
5. Access, Deletion, and Choice
If you need to update or delete certain information about you or your interactions with the Interfaces or the Features, you can contact us for assistance at [email protected].
You may have choices about the collection and use of information about you. You can choose not to provide certain information, but then you might not be able to use the Interfaces or Features.
- Communications: If you do not want to receive messages from us related to the Polygon ecosystem, please unsubscribe or adjust your communication preferences.
- Browser and Devices: The help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please see our Cookie Policy for more information.
For additional information related to certain jurisdictions, see Section 9 below.
6. Children’s Information
The Interfaces and the Features are intended for general users who are 18 years of age or older, and are in no way directed at children. We do not knowingly collect personal information from children. If you believe such information has been collected in error, please email [email protected] to notify us of this.
7. Retention of Information
We retain information collected in accordance with this Policy only for so as long as it is necessary to fulfill the relevant purposes described in this Policy, unless a longer retention period is required or permitted by law such as for tax, accounting, fraud prevention, investigative, and dispute resolution purposes, or to establish or defend a Claim. In some instances we may anonymize personal information about you such that it can no longer be used to identify you, in which case we can use such information indefinitely without further notice to you.
8. Notices
If you have any questions about this Privacy Policy, please Contact Us at:
Polygon Labs UI (Cayman) Ltd.
Legal Department
10 Market Street
Unit #2057
Camana Bay, Cayman Islands KY19006
If you interact with the Interfaces or the Features on behalf of or through your organization, then your information may also be subject to your organization’s privacy practices and you should direct privacy inquiries to your organization.
9. Additional Information for Certain Jurisdictions
California
If you are a California resident, you have certain additional rights with respect to personal information about you under the California Consumer Privacy Act of 2018 (“CCPA”).
We are required to inform you of:
- What categories of information we may collect about you, including during the preceding 12 months: See the section “What information do we receive from you or collect.”
- The purposes for which we may use your personal information, including during the preceding 12 months: See the section “How we use information.”
- The purposes for which we may share your personal information, including during the preceding 12 months: See the section “How do we share information.”
- In the preceding 12 months, we have not sold any personal information of consumers.
You have the right to request to know: (i) the categories of personal information we have collected about you in the last 12 months; (ii) the specific pieces of personal information we have about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we sold or disclosed in the last 12 months, if applicable; (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your personal information, if applicable. These rights are subject to limitations as described in the relevant law. We may deny your request if we need to do so to comply with our legal rights or obligations.
We will not discriminate against any user for exercising their CCPA rights.
You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent who does not submit proof that they have been authorized by you to act on their behalf.
If you would like to exercise any of these rights, please contact us (see “Contact Us” section).
European Economic Area, the United Kingdom, and Switzerland
If you are a data subject in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights with respect to your personal data pursuant to the General Data Protection Regulation of the European Union (“GDPR”) and similar laws. This section applies to you.
References to “personal information” in this Policy are equivalent to “personal data” as defined under GDPR.
Polygon Labs UI (Cayman) Ltd. is the controller of your personal information as covered by this Policy for purposes of GDPR. Our address is as follows: Polygon Labs UI (Cayman) Ltd., Legal Department, 10 Market Street, Unit #2057, Camana Bay, Cayman Islands KY19006.
We process your personal data in reliance on the legal basis below. Where the purpose of processing is:
- To provide and improve the Interfaces and the Features: We process your personal data as necessary to provide the Interfaces and the Features to you.
- To comply with the law: We process your personal data as necessary to comply with applicable laws and our legal obligations.
- For compliance, fraud prevention, and safety: We have a legitimate interest in processing your personal data, as described in this Policy, and our reasons for doing so outweigh any prejudice to your data protection rights. We also process your personal data as necessary to comply with our legal obligations.
- To send marketing communications; or for research and analytics: We have a legitimate interest in processing your personal data, as described in this Policy, and our reasons for doing so outweigh any prejudice to your data protection rights.
- With your consent: We process certain of your personal data with your consent. You may withdraw your consent at any time in the manner indicated when you provided consent to the collection of your personal data through your interactions with the Site.
You may: (i) ask whether we have any personal data about you and request a copy of such personal data; (ii) request that we update or correct inaccuracies in your personal data; (iii) request that we delete your personal data; (iv) request a portable copy of your personal data; (v) request that we restrict the processing of your personal data if such processing is inappropriate; and (vi) object to our processing of your personal data. These rights are subject to applicable law.
If you would like to exercise any of these rights, please contact us (see “Contact Us” section above). To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.
If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, please Contact Us above. You may also lodge a complaint with your local data protection authority.
To the extent we transfer your personal data outside the European Economic Area, we will do so in accordance with the terms of this Policy and applicable data protection law.