Mnemonic Privacy Notice

Effective Date: November 12, 2021
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Welcome! Mnemonic empowers developers to instantly access and build new applications on top of our cross-chain platform and APIs. This Privacy Notice explains how Mnemonic, Inc. (“Mnemonic”, “we”, “our” or “us”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our services, including our website https://mnemonichq.com/ and any other Mnemonic websites, applications, platforms, services, products, and other functionality offered on or through the online services (collectively, the “Services”). It does not address our privacy practices relating to Mnemonic job applicants, employees and other personnel.

‍Region-Specific Disclosures
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‍We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

‍Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@mnemonichq.com to submit such a request.
‍California: If you are a resident of the State of California in the U.S., please see our California Privacy Notice for additional California-specific privacy information.

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Our Collection of Personal Information

Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.

Personal Information Collected from Website Visitors and Developer Account Holders

We collect the following personal information submitted to us by visitors to our website and account holders:

‍Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a NevadaContact Information, including your first name, last name, email address, phone number, and communication preferences. This also includes information provided in order to subscribe to any of our newsletters (such as email address). resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@mnemonichq.com to submit such a request.
Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Services.
Developer Account Information, including username, password, payment and purchase history information, and any other information you provide to us. Please note we utilize third-party payment processors to process payments on our behalf. As such, any financial information in connection with Service payments is collected by the payment processors.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services) and location data (such as general geographic location based on the log data we or our third-party providers collect). Please note that our systems may also record personal information that you type into our Services even if you do not choose to submit it.

We and our third-party providers may use (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, “cookies”) to automatically collect this personal information.

For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

Personal Information from Third Parties and Other Sources

We also obtain personal information from third parties and other sources; which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

Single Sign-On: We may use single sign-on ("SSO") to allow a user to authenticate their account. We do this by using Google and/or OAuth authentication, a secure mechanism to give Mnemonic access to your account data without letting us know your password. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, including, for example, your username, password, name, email address, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Services, technical and security notices). Note Google’s Privacy Policy and Terms of Use apply to the registration and use of the Google SSO service. To view Google’s privacy policy, please visit https://policies.google.com/pr ivacy/.
Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
Service Providers: Our service providers that perform services solely on our behalf, such as payment processing and marketing providers, collect personal information and often share some or all of this information with us.
Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
‍Information from Other Sources: We may also collect personal information about individuals that we do not otherwise have from, including, for example, publicly available sources such as permissionless blockchains, customers, 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, NFT ownership information (e.g., account address, transfers of NFTs between accounts, the corresponding smart contracts transactions paid, and metadata describing each NFT and its properties as a digital asset), and interest-in-services information. We may combine some or all of this information with the information we collect from an individual directly. We use this information to provide the Services, contact individuals, to send advertising or promotional materials, or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

Our Use of Personal Information

We use personal information we collect to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested, including facilitating the access to our cross-chain platform and APIs and reporting information;
Manage our organization and its day-to-day operations;
Communicate with individuals, including via email, text message, social media and/or telephone calls;
Market our Services to individuals, including through email, direct mail, phone;
Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
Process payment for our Services;
Facilitate user benefits and services, including customer support through our command center services; Identify and analyze how individuals use our Services;
Conduct research and analytics on our client base and our Services;
Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
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 Service, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;
Defend, protect or enforce our rights or applicable contracts and agreements;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
Fulfill any other purpose for which you provide personal information; and
Comply with legal obligations.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

Our Disclosure of Personal Information

We disclose Personal Information in the following ways:

Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
Customer Service and Communication Providers: We share personal information 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 that perform business or operational services for us or on our behalf, such as website hosting, chat functionality services, infrastructure provisioning, IT services, analytics services, payment processing services and administrative services.
Customers and Business Partners: We may disclose personal information to our customers (e.g. developers), business partners, and other stakeholders for transactional and marketing purposes, including to promote their own products or services. In such instances, the processing of your personal information will be subject to the business partners’ privacy notice.
Online Advertising Partners: We also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see our Cookie Notice.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
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 information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our website or service-related publications.

Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Links to Third-Party Websites or Services

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 Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals 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.

‍Contact Us
‍If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@mnemonichq.com.
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Alternatively, inquiries may be addressed to:
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Mnemonic, Inc.
Attn: Privacy Department
2261 MARKET ST UNIT 47
SAN FRANCISCO, CA 94114

Mnemonic California Privacy Notice

Effective Date: November 12, 2021

Scope of Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For the purposes of this CA Notice, personal information does not include:

Publicly available information from government records;
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer;
Information excluded from the CCPA's scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Information relating to our employees, contractors and other Mnemonic personnel.

Collection of Personal Information

We collect personal information from and about consumers 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 of Personal Information” and “Our Use of Personal Information” sections of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your name, username and email address;
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your log-in credentials and phone number;
Commercial Information, such as NFTs purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, including your wallet address and related information;
Internet/Network Information, such as device information, logs and analytics data;
Geolocation Data, such as your approximate location based upon your IP address;
Sensory Information, such as photo, and recordings of any phone calls between you and Mnemonic;
Other Personal Information, including information you submit into the feedback form and any communications between you and Mnemonic, as well as information we receive or collect from social networking sites; and
Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit or use our Services, form blockchains, or from third parties that you permit to share information with us. Please see the “Our Collection of Personal Information” section of the Privacy Notice for more information about the sources of personal information we collect.

Disclosure of Personal Information

As described in the “Our Disclosure of Personal Information” section of our Privacy Notice, we share personal information with third parties for business purposes.

The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) our service providers and advisors; (iii) marketing and strategic partners; (iv) analytics providers; and (v) social networks.

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the “Collection and Use of Personal Information” section of this CA Notice, to third parties for a business purpose.

Your California Privacy Rights

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):

The Right to Access/Know	You have the right to 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: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information; The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and The business or commercial purposes for collecting or, if applicable, selling the personal information.
The Right to Request Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales	You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination	You have the right 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 our products and services or engage with you in the same manner.

How to Exercise your California Consumer Rights

To Exercise Your Right to Access, Right to Know or Right to Deletion

‍To exercise your Right to Access, Right to Know or your Right to Deletion, please submit a request by:

Emailing us at privacy@mnemonichq.com with the subject line, “California Rights Request”; or
Calling us at 415-390-6122‬.

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 account, 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 transaction on 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.

To Exercise Your Right to Opt-Out of Personal Information Sales

‍Unless you have exercised your Right to Opt-Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. These third parties may include:

Business Partners: We may share your personal information, including Identifiers, Commercial Information, Geolocation, and Internet/Network Information with our business partners for their business or commercial purposes. We may also share your personal information with other third parties who may have products or services we think you may enjoy.
Third-Party Advertising Networks, Social Media Companies and other Third-Party Businesses: we may share or all these third parties to collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our Services otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Services and advertisements on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research.

You do not need to create an account with us to exercise your Right to Opt-Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. This information may include, but not be limited to, your name, email, and social media account information. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

To opt out of data sales, please click on the link below:
‍Do not sell my personal information
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‍You may also opt out by using the Digital Advertising Alliance ("DAA") CCPA Tool. The DAA offers the CCPA opt out tool as a centralized place to opt out of the sale of personal information by all DAA participating businesses that are collecting your personal information across multiple websites and apps. To exercise your right to opt out from sales of this type of personal information, please visit https://optout.privacyrights.info. To make opt-out requests related to mobile apps on your device, you can download the appropriate app at https://www.privacyrights.info/appchoices. To learn more about how third parties collect information automatically on our website and the choices you may have in relation to those activities, please see our Cookie Notice.

‍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 or delete personal information, we require the following for verification purposes:

a power of attorney valid under the laws of California from you or your authorized agent; or
sufficient evidence to show that you have: provided the authorized agent signed permission to act on your behalf; and 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”: receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.