PRIVACY & COOKIE POLICY

We collect personal data in connection with your visits to our Sites and use of our Services. This collection includes personal data that you provide in connection with the Services, personal data from third parties, and personal data that is collected automatically such as through the use of cookies and other technologies.

Personal Data Collected from You

We may collect the following categories of personal data submitted to us by individuals through the Services:

• Contact Information, including name, email address, social media handle, country or region and communication preferences. We use this information to fulfill your request, to communicate with you directly, and to send you communications in accordance with your preferences.

• Account Information, including username, email address, and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant Service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. 
• Identity Verification Information. We may use identity verification services provided by third-party providers to verify your identity documents, confirm your identity and protect against fraud and abuse. When you create an account therein, you may be asked to submit your name, birthdate, address, phone number, email address, government identification number and copies of government identification documents, along with a selfie image. Our designated third-party identity verification provider(s) may use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a “match.” 

• Messages and User Content. You may upload, or transmit audio, videos, images, data, or information through your communications with us or your communications with other users when you participate in chat, complete a submission, post in forums, or otherwise use the Services (collectively, “User Content“). We may collect this information, and information about this content, such as the date and time you created this content, along with other information about you, such as your username or email address. Please remember that we may, but have no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. Please note that some of your User Content may be publicly visible. For more information, please see our Terms of Use.
• Event, Meeting, and Webcast Information, including registration information, and contact information. In some instances, we may also record audio and/or video from our meetings and events. We use this information to administer and facilitate the Services. We may also feature video clips or screenshots on our Sites.

• Inquiry and Communications Information, including information provided in custom messages sent through the forms, to one of our email addresses, or via phone. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the Services.
• Program Information, including information provided to participate in one of our programs, or to apply for a grant, such as your name, email address, and any other information you choose to provide to us, such as information regarding your proposal. If you apply for a program on behalf of a business, we may also collect information about the business, such as company name, place of registration and operation, beneficiary owner(s), and license information. 
• Newsletter and Marketing Emails Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us. 
• Other Data You Share.  We also collect personal data at such other points on our Services so that we may provide the features or functionality of the Services and for other purposes described in this Policy.   

Personal Data Collected from Third Parties

We also obtain personal data about you from third parties. We may receive the same categories of personal data as described above from the following third parties:

• Other Users or Individuals who Use our Services: We may receive personal data about you from other users or other individuals who use our Services. 
• Social Media: When you use our Services through various social media networks, we may receive personal data about you that you permit the social network to share with third parties. The personal data we receive is dependent upon an your privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages.
• Service Providers: Our service providers that perform services solely on our behalf, may collect and share your personal data with us. The information may include name, residential address, contact information, demographic information, and information about your communications and related activities. We may use this information to administer and facilitate our Services communications with you.
• Ecosystem Partners: We may receive personal data about you from our ecosystem partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our Services.
• Information from Other Sources: We may also collect personal data about you that we do not otherwise have from, for example, publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. Such information may include contact information, social media account information, general location, domains, cryptocurrency wallet address and related information, the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information (including cryptocurrency assets), and interest-in-services information, employment-related information, and interest-in-services information. We may combine this information with the information we collect from you directly. We use this information to provide the Services, contact you, to process employment applications and job applicant screening, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

Additional Uses of Personal Data

We may use personal data we collect to: 

• Operate, maintain, and improve the Sites
• Fulfill or meet the reason for which the information was provided, such as to communicate with you, to respond to comments and questions and provide customer service;
• Manage our day-to-day operations; 
• Verify your identity and entitlement to Services;
• Communicate upcoming events, and other news about the Protocol and ecosystem;
• Register you for and provide you access to events and webcasts;
• Communicate with you, including via email and social media;
• Request you to complete surveys about our organization, organizations we partner with, and Services; 
• For marketing and advertising purposes, including to market to you or offer you through email information and updates we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
• Identify and analyze trends, usage, and activities in connection with the Sites;
• Test, enhance, update and monitor the Services, or diagnose or fix technology problems; 
• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
• Enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations and requirements; 
• Fulfill any other purpose for which you provide personal information; and
• For any other lawful purpose, or other purpose that you consent to.

We may collect information you provide to us and information about how you access and use the Services 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 about 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 our Sites, for example, the site from which you came and the site to which you are going when you leave our Sites, whether you open emails or click the links contained in emails, and other browsing behavior and actions you take on the Site.
• Information about how you use the Sites, 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 Sites and may record your mouse movements, scrolling, clicks and keystroke activity on the Sites 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 our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer 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 Sites; (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Sites;  (e) diagnose or fix technology problems; and (f)  otherwise to plan for and enhance our Services.

What is a cookie and what types of cookies do we use?

A cookie is a small piece of data, stored in text files that are stored on your browser or other device when websites are loaded in the browser. Cookies are used to “remember” you and your preferences when you visit our Sites either for a single visit (through a “session cookie”) or for multiple repeat visits (called a “persistent cookie”). A session cookie is deleted when you close your browser or after a short time. A persistent cookie is kept for a set period of time after which it expires and is deleted. 

We use session cookies and persistent cookies on our Sites to ensure consistent and efficient experiences for users of our Sites. Cookies also perform functions like allowing users to remain logged into the Sites, if applicable.

We use the following types of cookies for the following purposes:

• Necessary: These cookies are essential in order to enable you to use our Sites and their features. The information collected by these cookies relate to the operation of our Sites, for example, language detection, Sites scripting language and security tokens to maintain secure areas of our Sites.
• Performance and Analytics: These cookies collect anonymous information about how you use our Sites, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our Sites. They are also used to track details like the number of unique visitors and pageviews to improve user experience. Information collected by these cookies is used only to improve your use of our Sites and never to identify you. These cookies are sometimes placed by trusted third-party providers, such as Google Analytics.
• Functionality: These cookies remember choices you make, for example the country you visit our Sites from and any changes you have made to text size or other parts of web pages that you can customize, in order to improve your experience of our Sites and to make your visits more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other Sites.
• Third-Party / Embedded Content: These cookies enhance the experience of Sites users. These cookies allow you to share what you’ve been doing on our Sites with social media organizations such as Facebook and Twitter. We have no control over the information collected by these cookies.

Our Sites only automatically uses Necessary cookies to enable you to use our Sites and its features and ensure the functionality of our Sites. 

Upon your consent, the Sites uses Performance and Analytics, Functionality and Third-Party or Embedded Content cookies for the purposes of providing relevant content, analyzing our traffic, and providing a variety of features to you. You may withdraw your consent to the use of certain cookies (other than Necessary cookies) any time.

How do I disable cookies? 

Some internet browsers are automatically set up to accept cookies. If you want to change your cookie preferences or refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies.

Please note you may not be able to take advantage of all the features of our Sites if you delete or disable certain cookies, such as the Performance cookies.

What analytics tools do we use?

• Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“). Google Analytics uses cookies to analyze how you use our Sites. The information generated by the cookie about your use of the Sites is generally transmitted to and stored on a Google server in the USA.

We only use Google Analytics with activated IP anonymization. This means that your IP address will be shortened in member states of the European Union or the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. Google will use this information on our behalf to evaluate your use of the Sites in order to provide us with reports on the activities of users on our Sites and to provide other services related to the use of the Sites and internet usage. Furthermore, Google will transfer this information to third parties if required by law or if third parties process this data on behalf of Google. The IP address provided by your browser will not be merged with Google’s other data.

You may object to Google Analytics collecting the data with effect for the future by installing a deactivation add-on (https://tools.google.com/dlpage/gaoptout?hl=en) for your browser. Besides the possibility to install the deactivation add-on, there is another alternative to prevent Google Analytics from collecting the data. Please click on this link to deactivate Google Analytics. You thereby install a so-called opt-out cookie that prevents the tracking of data on our Sites. The function remains until the opt-out cookie is deleted. If the opt-out cookie has been deleted, it is sufficient to click on the link again.

• HubSpot: We may use HubSpot, a client relationship management (CRM) and marketing automation platform provided by HubSpot GmbH, Am Postbahnhof 17, 10243 Berlin, Germany (“HubSpot“). HubSpot provides us with tools for client relationship management (CRM), marketing automation, social media marketing, content management, web analytics, customer service and search engine optimization, among others. Information is generally stored on a HubSpot server in Ireland or another EU country but may eventually also be transmitted to and stored on a HubSpot server in the USA. If you use our Services, you consent to such transfer to the USA, if any.

To the extent that the GDPR applies, there is an adequacy decision on the EU-US Data Privacy Framework of the EU Commission (“DPF“). HubSpot in the USA is certified under the DPF, so that your personal data can be transferred from the EU/EEA to the USA without additional safeguards.

• Hotjar: We use Hotjar, a web analytics service provided by Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta (“Hotjar“), to better understand the needs of the Sites visitors and for optimization, marketing purposes and the interest-based design of the Sites. 

Information about how you use the Sites is generally transmitted to and stored on a Hotjar server in the EU, but may also be transmitted to and stored on a Hotjar server outside the EU, in which case Hotjar declares that it endeavors to put in place additional safeguards to protect personal data.

With Hotjar, your activities and movements on the Sites may be tracked. Technical details about the device and browser you are using, the country from which you are accessing the Sites, and your preferred language may be collected.

Hotjar stores this information in a pseudonymized user profile. The information is neither used by Hotjar nor by us to identify individual users nor is it combined with other data about individual users. Areas of the Sites that display personal data about you or third parties are usually hidden and therefore not traceable by Hotjar or us at any time.

If you do not want Hotjar to collect your data, you can prevent this by installing the “Do Not Track” header provided by Hotjar (https://www.hotjar.com/policies/do-not-track/).

• Web Beacons: We, or our third-party partners, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels) which helps us understand what content is effective, for example by counting the number of users who have visited these pages, and to understand usage patterns. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded on web pages, ads, and e-mail. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you.

We will only use your personal data if and to the extent that applicable law allows and, where necessary, rely on a variety of legal bases to process your personal data for the above purposes, including if:

• it is necessary for the performance of a contract with you;
• it is necessary in connection with a legal obligation;
• we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms; or
• you have given your consent at the time of collecting your data (which you can withdraw at any time thereafter).

We may share, transmit, disclose, grant access to, make available, and provide personal data about you with and to third parties (in compliance with the applicable legal requirements), as follows: 

• Foundation Entities: We may share personal data with entities affiliated with us, particularly when we collaborate in providing the Services.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Blockchain Participants: Holdings and transactions associated with your crypto wallet address are publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public. Through the use of the Services, we display blockchain information and other data associated with the recipient transaction wallet.  
• Marketing Providers: We coordinate and share personal data with marketing providers in order to communicate with individuals about the Services we make available. 
• Customer Service and Communication Providers: We share personal data with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers (e.g., accountants, auditors, legal and other professional advisers) that perform business or operational services for us or on our behalf. 
• Other Users: If you participate in one of our online communities or forums, we may disclose your account username to other users, as well as any other information you choose to provide and make public.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger or acquisition. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.  
• Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and competent authorities, including tax authorities and courts (in Switzerland and abroad): 
  • in connection with the establishment, exercise, or defense of legal claims; 
  • to comply with laws or to respond to lawful requests and legal process; 
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  • to detect, suppress, or prevent fraud; 
  • to protect the health and safety of us and others; or 
  • as otherwise required by applicable law.

• With Your Consent: We may disclose personal data about you to certain other third parties or publicly with your consent or direction. For example, with an your consent or direction we may post your testimonial on our Sites or service-related publications.

In connection with the disclosures described in Section IV., we may transfer your personal data to the following countries that offer adequate protection pursuant to the FADP and GDPR: Member states of the European Economic Area and the United Kingdom. 

Under certain circumstances, we may also transfer your personal data to the following countries, which do not offer adequate protection pursuant to the FADP and/or the GDPR: USA and potentially other countries (if necessary for the respective processing purpose, e.g. for IT services). To the extent such countries do not offer adequate protection, the transfer is secured by appropriate safeguards (such as Standard Contractual Clauses) or based on a statutory exemption (e.g., if you have given your consent to the transfer, if the transfer is directly connected with the conclusion or performance of a contract with you or if the transfer is necessary for the establishment, exercise or enforcement of legal claims before a foreign authority). Within the scope of the GDPR, you may ask us for a copy of the relevant safeguards by contacting us as indicated at the beginning of this Policy.

In relation to the processing of your personal data, you may have the right under applicable data protection law to:

• access: you can ask us whether we process your personal data, and if so, how we do so;
• correction: if you consider that the personal data which we process relating to you is incorrect or incomplete, you can ask us to correct or complement it;
• object: if we rely on our or a third party’s legitimate interest to process your personal data, and you consider your interest in us not doing so weighs more heavily, you can object to our processing (regarding cookies through which certain personal data may be collected, you can block the setting of such cookies at any time by changing the settings in your browser accordingly; see Section III. above). You can also object to our processing of your personal data for direct marketing;
• erasure: if you consider that we process your personal data without legal justification or the data was collected when you were still a minor, you can ask us to erase your personal data;
• restrict processing: if it is unclear whether there is a legal justification for the processing of your personal data (for instance, after you have objected to such processing), you can ask us to restrict the processing while the situation remains unclear;
• data portability: insofar as the processing of your personal data is based on a contractual necessity or on your consent, you can ask us to provide you with your data in a structured, commonly used and machine-readably format; and
• withdraw your consent: i.e., to revoke your consent to the extent you have previously given such consent to any specific purpose of processing of your personal data. This will not affect the lawfulness of any processing carried out before you have withdrawn your consent (or any processing based on any legal basis other than your consent) and it may mean that we will no longer be able to provide our Services to you. 

In case you wish to exercise any of these rights, please directly contact us at [email protected]. We will evaluate your request and provide you with an answer and its justification no later than is required by law. Please note that we may refuse or limit these rights in accordance with applicable data protection law.

You will not, in general, have to pay a fee to exercise any of these rights. However, we may charge a fee for access to your personal data if the relevant data protection legislation allows us to do so, in which case we will inform you as required by the law.

If you feel we have not handled your query or concern to your satisfaction, you also have the right to lodge a complaint with or notify your local supervisory authority (see Section X. below).

We have implemented appropriate technical and organizational security measures to protect your personal data from loss, misuse, alteration or destruction. Despite these security measures, we cannot completely eliminate the security risks associated with data processing.

We will usually store the personal data we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable laws. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire.

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

In general, we will retain your personal data as follows:

• Sites: Your personal data collected through our Sites will be processed for as long as required to enable the requested access, secure the stability and integrity of the relevant systems or required to perform the analysis. Thereafter, it will be deleted or anonymized.
• Cookies: Cookies will be stored on your device for the time period required to achieve the related purpose and will thereafter be deleted by your browser.   
• Communication, Account Information, and User Content: Your personal data used to communicate with or uploaded or transmitted by you will be deleted after responding to / completing your inquiry or upon deletion of your account if and to the extent (i) we are not legally obliged to retain such personal data (e.g. for accounting or document retention purposes), and (ii) we do not have an overriding or legitimate interest to retain such personal data for documentation, quality assurance or similar business purposes or for the assessment or exercise of, or defense against, legal claims.
• Business Development: We generally keep your personal data used for business development or marketing purposes for as long as necessary to achieve the respective purposes. Such personal data will be deleted thereafter if and to the extent (i) we are not legally obliged to retain such personal data (e.g., for accounting or document retention purposes), and (ii) we do not have an overriding or legitimate interest to retain such data for documentation, quality assurance or similar business purposes or for the assessment or exercise of, or defense against, legal claims. 

Once retention of the personal data is no longer necessary for the purposes outlined above or otherwise required, we will delete or anonymize the personal data.

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data 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 data either directly or by other means. If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 16, we will promptly delete that personal data.

If you are under the age of 18 and you want to remove your name or comments from our Sites or publicly displayed content, please contact us directly at . 

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 data 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).

If you believe that our processing of your personal data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the competent data protection authority. 

The data protection authority in Switzerland is the Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Berne, Switzerland (https://www.edoeb.admin.ch). Based on your residence, you may have the possibility to lodge a complaint with the appropriate data protection authority of your place of residence.

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

This Policy does not form part of any contract with you, and we may amend it from time to time. The version published on our Sites is the version that currently applies. All changes shall be effective from the date of publication unless otherwise provided.

If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email to [email protected].

The 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 Our Collection And Use of Personal Data section of our 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 user’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).

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 our Services. 

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.

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.

Privacy Settings

Opt Out of Google Analytics Tracking

You may object to Google Analytics collecting the data with effect for the future by installing a deactivation add-on (https://tools.google.com/dlpage/gaoptout?hl=en ) for your browser. Besides the possibility to install the deactivation add-on, there is another alternative to prevent Google Analytics from collecting the data. It is particularly interesting for users of mobile devices. Please click on this link to deactivate Google Analytics. You thereby install a so-called opt-out cookie that prevents the tracking of data on our website. The function remains until the opt-out cookie is deleted. If the opt-out cookie has been deleted, it is sufficient to click on the link again.