This Privacy Policy (“Policy”) describes how Supererogatory Corp. and its directly or indirectly controlled affiliates (“Supererogatory,” “we,” “us,” or “our”) may collect, use, and disclose information, and your choices regarding this information. Please read this Policy carefully and contact us with questions at legal@supererogatory.io.
Applicability of This Policy
This Policy applies to our Services, which include our websites and mobile applications featuring this Policy (collectively, the “Sites”), the services and tools we provide on or make available via our platform, any interaction with Supererogatory's APIs or other user interfaces relating to issuances of our tokenized assets, bridging or conversion tools made available for your use, insights, or subscribing in or managing blockchain-based smart contracts or any other features or content we own or operate or third-party applications or smart contracts relying on such Supererogatory interfaces or smart contracts, and related services, including but not limited to blockchain-based tokens that are generated or transferred by or otherwise interact with any such smart contracts (collectively, the “Services and Tools”). If you do not agree with the terms of this Policy, do not access or use the Services and Tools, Sites, or otherwise interact with our business.
This Policy does not address our privacy practices relating to Supererogatory job applicants, employees, and other personnel. This Policy is also not a contract and does not create any legal rights or obligations. We may also choose or be required by law to provide different or additional disclosures relating to the processing of your information, which should not be interpreted as limiting the terms of this Policy.
What We Collect
The categories of information we collect depend on how you interact with us and our Services and Tools. Supererogatory collects information that individuals provide directly to us, information we collect automatically when individuals interact with us, and information we collect from third-party sources and other organizations.
Information You Provide
We may collect the following information you provide directly to us in connection with our Services and Tools:
- Contact Information, such as your name, email address, physical address, and communication preferences.
- Financial Information, such as your blockchain addresses, blockchain wallet information, asset holdings, transaction history, and associated fees paid.
- Transaction Information such as information about the transactions you make on or using our Services and Tools, such as the type of transaction, transaction amount, and timestamp.
- Background Information for KYC and other regulatory customer diligence requirements, which may include collection of your passport, photos, bank account statements, assets, utility bills, proof of income, incorporation documents, and tax ID and verification information.
- Interaction Information, such as the information you submit through your interactions with us, including feedback, communications, inquiries, questionnaires and other survey responses, your use of the Services and Tools, and information you provide to our first- and third-party support teams, including via our help chat.
Information We Collect Automatically
As is true of many digital platforms, we and our third-party providers may also collect certain information from an individual's device, browsing actions, and site usage patterns automatically when visiting or interacting with our Services and Tools, which may include:
- Online Identifiers, such as geo location/tracking details, browser fingerprint, mobile carrier, MAC address, user settings, mobile ad identifiers, Internet service provider, operating system, browser name and version, personal IP addresses, 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.
- Usage Data, such as the electronic path taken to our services, through our services, and when exiting our services, as well as information pertaining to usage and activity on our services (including pages visited, links clicked, content interacted with, and duration and frequency of the activities).
- Location Information, such as IP-derived location, used at the city level for fraud detection, customer support and product improvement purposes.
- Cookies and Other Tracking Technologies. We, and third parties we authorize, collect information through (i) cookies or small data files that are stored on an individual's device or browser and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “Cookies”). We use Cookies to automatically collect and use or disclose information for the purposes described in this Privacy Policy, including to analyze and track data, determine the popularity of certain content, and better understand each user's online activity. We may combine this Cookie information with other information we collect about you. You may choose to set your web browser to refuse Cookies, or to alert you when Cookies are being sent. If you do so, please note that some parts of our Services and Tools may not function properly.
Information from Third Parties and Other Sources
We also obtain personal information from third-party 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:
- Affiliates. We may receive information from other companies owned or controlled by Supererogatory, and other companies owning or under common ownership with Supererogatory, particularly when we collaborate in providing the Services and Tools.
- Social Media. If an individual chooses to interact with us on social media, we may collect personal information about them from their social media account that they make public. We use personal information collected in connection with their social media account to communicate with them, better understand their interests and preferences, and better understand our user base in the aggregate.
- Identity Verification Providers. In certain circumstances, we may engage third-party identity verification providers to help us verify the identity of a specific individual with whom we are interacting. This information is used primarily for purposes of preventing fraud.
- Data Analytics Providers. We rely on third-party providers to help us collect analytics relating to our services and user base. These data analytics providers often collect personal information directly from individuals or public blockchains and share some or all of this information with us in connection with their analytics services.
- Other Service Providers. Other service providers that perform services solely on our behalf, such as website hosting and marketing providers, collect personal information and often share some or all of this information with us in connection with their services.
- 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 background check information from credit bureaus or updated contact information from third-party information providers to connect with an individual who may be interested in our services.
- Publicly Available Sources. We collect personal information about individuals that we do not otherwise have, such as information publicly available on various blockchains (see below), public contact information or an individual's interest in our services from publicly available sources. We may combine this information with the information we collect from an individual directly.
Our Collection of Blockchain Information
Blockchain is a shared, immutable ledger used to record transactions of assets. In connection with our services, we may collect the following current and historical blockchain information directly from individuals, from the third parties identified above, or from public blockchains themselves:
- Account Address: The unique blockchain address or domain from or to which assets are transferred.
- Wallet Information: The wallet provider and wallet connected to a specific account address.
- Account Balance & Assets: The balance associated with the blockchain address, as well as the assets stored in connection with that account.
- Transaction Details: The transaction identifier, blockchain position for the transaction, date and time of the transaction, type of transaction, amount sent or received, fee amount, account address of the sender and recipient, and storage size of the transaction.
We may in certain circumstances combine the blockchain information we obtain with the information described above, such as where you are required to connect a blockchain wallet (such as through Coinbase Wallet, WalletConnect, Fortmatic, Ledger, or Trust Wallet) to the Service to facilitate the account address creation and wallet linking.
How We Use Information
We use your information and blockchain information in accordance with your instructions, including any applicable terms in the Terms of Use, to provide data processing as described in the policies and agreements of our affiliates, and as required by applicable law. We may also use the information we collect for:
Providing Services and Tools and Features
We may use the information we collect to provide, personalize, maintain, and improve our products and Services and Tools, including as we described in the Terms of Use. This includes using information to:
- operate, maintain, customize, test, measure, and improve our Services and Tools, and manage our organization and business;
- facilitate and process transactions;
- send information, including confirmations, notices, updates, technical alerts, security alerts, surveys, and support and administrative messages;
- communicate with you about the Services and Tools and events offered by Supererogatory and others and provide news and information that we think will interest you;
- personalize and improve your experience on our Services and Tools;
- monitor and analyze trends, usage, and activities in connection with our Services and Tools; and
- create de-identified or aggregated data.
Safety and Security
We may use your information to help maintain the safety, security, and integrity of you and our Services and Tools, including to:
- protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
- monitor and verify identity or service access, combat spam, malware or security risks;
- perform internal operations necessary to provide our Services and Tools, including to test, diagnose, and troubleshoot software bugs and technical and operational problems;
- help maintain the safety, security, and integrity of our property and Services and Tools, technology assets, and business;
- enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other Services and Tools;
- detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Supererogatory and others; and
- comply with applicable security laws and regulations.
User Support
We may use information we collect to provide support, including to:
- direct questions to the appropriate support person;
- respond to your comments and questions and provide customer service;
- investigate, troubleshoot, address and resolve user concerns and problems using the Services and Tools; and
- monitor and improve our customer support responses and processes.
Research and Development
We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services and Tools, improve our ability to prevent the use of our Services and Tools for illegal or improper purposes and develop new features and products relating to our Services and Tools.
Legal and Regulatory Compliance
We may verify your identity and conduct KYC and other customer diligence requirements by comparing the personal information you provide against third-party databases and public records, or conducting a background check. We may use the information we collect to investigate or address claims or disputes relating to use of our Services and Tools, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries. We may process the information to facilitate business transactions and reorganizations impacting the structure of our business, or to otherwise comply with our legal and financial obligations.
Direct Marketing
We may use the information we collect to market our Services and Tools to you. This may include sending you communications about our Services and Tools, features, promotions, surveys, news, updates, and events, and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at legal@supererogatory.io.
Information Sharing and Disclosure
With Affiliates. We share information with other companies owned or controlled by Supererogatory, and other entities that own or are under common ownership or control with Supererogatory, particularly when we collaborate to provide our Services and Tools.
At Your Direction. We may share information with third parties you engage with through our Services and Tools or as necessary to fulfill a request or transaction. For example, you may permit us to share personal information with others for their own marketing purposes. Such uses will be governed by the recipient's privacy policies.
To Comply with Our Legal Obligations. We may disclose your information: (A) to cooperate with governmental or regulatory investigations; (B) when compelled by subpoena, court order, or similar legal process; (C) when we believe in good faith that disclosure is necessary to prevent harm to another person; (D) to report suspected illegal activities; or (E) to investigate violations of our User Agreement or other applicable policies.
With Service Providers. We may share your information with service providers who assist us in business and compliance operations, such as marketing and technology services. Our agreements require these providers to use your information solely to perform services on our behalf.
Identity Verification Providers. When engaging third-party identity verification providers to verify the identity of individuals we interact with, we provide sufficient information to facilitate such verification.
With Public Blockchains. Certain transaction information may be made available on public blockchains, consistent with customary blockchain transaction practices. This information is publicly accessible and may be freely shared.
During a Change to Our Business. In connection with mergers, acquisitions, bankruptcy, dissolution, reorganizations, sales of assets or stock, financing, public offerings, or similar transactions, some or all of your information may be shared or transferred subject to confidentiality agreements.
Legal Obligations and Rights. We disclose information to third parties such as legal counsel, professional advisors, and law enforcement when necessary to:
- Obtain advice or protect our business interests;
- Establish, exercise, or defend legal claims;
- Comply with laws, lawful requests, or legal processes, including those related to national security or law enforcement;
- Protect our rights, property, and those of others, including enforcing agreements and policies;
- Detect, prevent, or suppress fraud;
- Protect health and safety; or
- As otherwise required by applicable law.
Aggregated or De-identified Data. We may share aggregated or anonymized data for various legitimate uses.
Legal Bases for Processing Your Information
Where required by law, the legal bases for processing your information as described in this Privacy Policy include:
- Performance of a contract between you and Supererogatory regarding the Services and Tools;
- Legitimate interests pursued by Supererogatory or a third party, provided your rights and interests do not override those interests;
- Compliance with legal or regulatory obligations; and
- Your consent for specific processing activities.
Your Rights and Choices
You may, at any time, contact us to learn more about your rights or to exercise them, including the right to:
- Access or receive a copy of the personal information we hold about you;
- Request correction of inaccurate or outdated information;
- Request deletion of certain personal information;
- Restrict processing or disclosure of your information;
- Revoke consent where applicable.
We will respond to your requests within applicable legal timeframes. Certain information may be exempt from such requests if necessary to fulfill legal obligations or legitimate interests. Verification of your identity may be required before processing your request.
Data Retention
We retain your information throughout your use of our Sites, Services, and Tools, and for a minimum of five (5) years thereafter to comply with legal obligations or resolve disputes. Even after you cease using our Services and Tools, we may process and share information as necessary to prevent fraud, comply with law enforcement, or protect legal rights.
Security
We implement administrative, technical, and physical safeguards to protect your personal information from unauthorized access or disclosure. However, no system is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your blockchain addresses and wallets.
Age Limitations
We do not knowingly allow use of our Services and Tools by individuals below the legal age in their jurisdiction. If you become aware of such unauthorized use, please contact us at legal@supererogatory.io, and we will take appropriate action to delete data and close accounts.
Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be reflected in the “Last Updated” date. For material changes, we will provide additional notice via email or through our Services and Tools.
Contact Us
For any questions regarding this Policy or to exercise your rights, please contact us at: legal@supererogatory.io