(As of September 11, 2023)
When you interact with our Site and/or avail of our Services made available in our Site, we may collect the following information which may include your Personal Data:
Personal Data, which may include your blockchain wallet address and other similar identifying number, symbol or information under applicable law, is collected when you use our Services or when you:
Deposit or stake digital assets; Withdraw digital assets;Send or deliver digital assets; and/orPurchase, sell or otherwise make trades with digital assets.
This is not an exhaustive list of how we collect Personal Data as we may also collect Personal Data from other companies or third parties. Services and Features
Operate, maintain, customize, measure, and improve our Services;Create and update user accounts;Improve user experience;Process transactions;Send information and marketing communications, including notices, updates, security alerts, promotions, surveys, news, events, and support and administrative messages; Create de-identified or aggregated data;Maintain safety, security and integrity of the Services;Provide customer support;Test, research, analyze, and develop products or services to improve user experience; andCompare the information against third-party databases and public records.
Sharing and Disclosure of Information
When you are no longer using our Services, we continue to share you information which includes, but is not limited to the following:
Contact details;IP addresses;Trading history;Blockchain wallet addresses and information; andConversion events.
We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your Personal Data from outside attacks or threats, loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, we do not provide any guarantee regarding the effectiveness of these protective measures or our ability to prevent other parties, acting unlawfully, from gaining access to your Personal Data. You are responsible for all activity on the Composable protocol relating to any of your network addresses or cryptocurrency wallets.
Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any digital assets held by your wallet address.
While you can choose freely whether or not you will provide Composable with your Personal Data, you may be unable to use the Services, or a portion thereof, until you have provided Composable with such information or data if it is necessary for your use or continued use of the Services.
Your data protection rights are not absolute and we may deny you your rights in accordance with the applicable data protections laws by providing you with the reason(s) for the denial of your request.
We store and retain Personal Data you have provided for as long as necessary for your continued use of the Services, pursuant to your contract with us, and in compliance with applicable laws and regulations.
Withdrawal and Deactivation
If you decide to withdraw your consent for Composable to use and/or disclose all your Personal Data, we will cease to collect your information unless there is a legal justification for the continued collection of your Personal Data. Further, we may not be able to continue providing our Services to you or continue any contractual relationship that is in place depending on the nature of your request. The withdrawal of your consent may result in the termination of any agreements with us and it may be considered as a breach of your contractual obligations or undertakings. In such instances, we reserve our legal right to pursue any remedies available at law or in equity. The withdrawal of your consent does not in any way affect the lawfulness of the collection of your data based on the consent given prior to the withdrawal.
The Services are intended for general audiences and are directed to users who are of legal age. Minors who lack the legal capacity under any applicable laws are generally not permitted to access or use our Services. Any person who becomes aware of or believes that a minor is using our Services should immediately contact us. We shall remove any information collected from the minor who may have used our Services without our knowledge to ensure compliance with applicable laws.
Applicable Law and Jurisdiction
Specific Disclosures and Notices
Specific Notice to California Residents (“CCPA Notice”)
The California Consumer Privacy Act of 2018 (“CCPA”) requires certain businesses to provide a CCPA Notice to explain how a company collects, uses, and shares Personal Data of California residents and the rights and choices offered regarding the handling of such data or information.
Privacy Practices. We will not sell your Personal Data or “personal information” as defined under the CCPA. Privacy Rights. The CCPA gives individuals the right to request information about how Composable has collected, used, and shared your personal information and gives you the right to request a copy of any information that we may have stored or maintained about you. You may also ask us to delete any personal information that we may have received about you. The CCPA limits these rights, for example, by prohibiting us from providing certain sensitive information in response to access requests and limiting the circumstances under which we must comply with a request for deletion of personal information. We will respond to requests for information, access, and deletion only to the extent that we are able to associate, with a reasonable effort, the information we maintain with the identifying details you provide in your request. If we deny the request, we will communicate this decision to you. You are entitled to exercise the rights described above free from discrimination.Submitting a Request. You can submit a request for information, access, or deletion to firstname.lastname@example.org.Identity Verification. The CCPA requires us to collect and verify the identity of any individual submitting a request to access or delete personal information before providing a substantive response.Authorized Agents. California residents can designate an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming their authority.
Additional Disclosures for European Union Data Subjects or Users
We will process your Personal Data for the purposes described above, as applicable. Our justifications and bases for processing your Personal Data include: (1) you have given consent to the process to us or our Service provides for one or more specific purposes; (2) processing is necessary for the performance of a contract with you; (3) processing is necessary for compliance with a legal obligation; and/or (4) processing is necessary for any legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
Your rights under the GDPR include the right to: (1) request access and obtain a copy of your Personal Data; (2) request rectification or deletion of your personal data; (3) object to or restrict the processing of your Personal Data; and (4) request portability of your Personal Data. Additionally, you may withdraw your consent to our collection at any time. Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control.
To exercise any of your rights under the GDPR, please contact us at email@example.com. We may require additional information from you to process your request. Please note that we may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even after a data subject request in accordance with our legitimate interests, including to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
Access and Acceptance