DeFi Notifications Privacy Policy

Last Revised: October 12, 2021

Hexa Foundation Ltd. (CC)  and its affiliates (“Hexa”, “we” or “us”) respect the privacy of users of our DeFi Notifications application (the “App”) and related services (“User” or “you”) and are committed to protect the personal information that their Users share with us. We believe that you have a right to know our practices regarding the information we may collect, receive and use when you visit and/or use the App.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use (“TOU”), into which this Privacy Policy is incorporated by reference.

This Privacy Policy and the ToU into which this Privacy Policy is incorporated relate solely to the App and its use. Use of any other platform or website provided by Hexa is subject to the applicable terms of service of such platform or website.

1.                   Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE APP, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE APP.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

2.                   Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a.       Non-identifiable and anonymous information (Non-personal Information). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the App. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the App (including , type of operating system, User's preferences 'click-stream' or searches on the App, type and version of browser, keyboard language, screen resolution, etc.

b.      Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature. We do not currently plan on collecting or storing any of your Personal Information through the use of the App. Our third party analytics services may collect the User’s IP address primarily for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

Personal Information may be gathered if any personal details are provided consciously and voluntarily by the User in any contact made with us, including through any contact form which may be available through the App, which may include, inter alia, the User's name, country, company/organization name, the User's position in the company/organization, his/her e-mail address and telephone number. Once your contact details are received by us, our representatives may contact you for further communication. Our representative may collect additional Personal Information from you in the course of such communications.

The functionality of the App does, however, require you to provide a blockchain wallet address that is utilized to generate your list of potential push notifications. You may use your own wallet address or a wallet address that is not owned by you. This wallet address will be collected and stored by us and associated with your push notification preferences. If you do utilize your own wallet address, this will be collected and stored on the App together with your notification preferences.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the TOU and the Privacy Policy.

3.                   How Do We Collect Information on Our Users?

There are a few methods that we use:

a.          We collect information through your entry and use of the App. In other words, when you are using the App we are aware of it and may gather, collect and store the information relating to such usage.

b.          We collect information which you decide to provide us voluntarily. For example, we collect Personal Information when you fill in any contact, subscription or registration forms available on the App.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

4.                   What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:  

Personal Information is collected in order to:  

5.                   Sharing Information with Third Parties

Hexa will not share any Personal Information it collects with any third party, other than in the following circumstances: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of Hexa, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Hexa, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure.

Note, that we collect, hold and/or manage Personal Information through Hexa's authorized third parties vendors of certain products or services (such as, hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.    

For avoidance of doubt, Hexa may use Non-personal Information and transfer and disclose it to third parties at its discretion.

6.                   Deletion or Modification of Personal Information

In any event, if for any reason you (or any person) wish to delete or modify Personal Information, please send us an e-mail with adequate detail of your request to: hello@defi.org and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of the App may remain on our servers indefinitely.

7.                   Minors

The App is intended for Users over the age of eighteen (18). Therefore, Hexa does not intend and does not knowingly collect Personal Information from children under this age. We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the App.

8.                   Security

We take reasonable measures to maintain the security and integrity of our App and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The Personal Information is hosted on Google servers which provide advanced strict security standards (both physical and logical). In addition we employ highly secure services design and implementation using encryption and architectures mechanisms. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. HEXA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.    

9.                   Third Party Service Providers

While using the App we may be using third party service providers, who may collect, store and/or process the information detailed herein. Hexa uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information.

10.               Cookies and Other Tracking Technologies. 

When you access or use the App, we or our third party service providers may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies”), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized third party service providers may use both session cookies (which expire once you close the App) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you disable or erase cookies, your online experience may be limited. Cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. Hexa does not control such third party service providers.

11.               International Data Transfer

In order to provide the App, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

12.               Direct Marketing

You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products, services and platform. You may withdraw your consent by sending a written notice to Hexa’s e-mail address that appears in the App or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

13.               Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App and any information collected therein. Hexa reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the App and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our App or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.

14.               Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: notifications@defi.org.