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Privacy Policy and Cookies Statement

This Privacy Policy and Cookies Statement ("Policy") describes how 0xbow Ltd. and its affiliated companies (referred to in this document as "0xbow," "we," "us" or "our") collects, uses, shares and otherwise processes Personal Data (defined below) including:

Visitors to our website(s), mobile applications, and other online properties ("Site" or "Sites"); and

Any other individual about whom 0xbow may obtain Personal Data.

In this Privacy Policy, "Personal Data" means information that (either in isolation or in combination with other information held by 0xbow) enables you to be identified as an individual or recognized directly or indirectly. We may collect Personal Data when you use our Sites.

Overview

Unless we specifically state otherwise, 0xbow is the data processor of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us. 0xbow personnel are required to comply with this Privacy Policy and complete data protection training, where appropriate.

Collection of Personal Data

0xbow collects information that you provide directly or indirectly to us when you use our functionalities or browse our Site. We also collect data provided by job applicants or others on our Sites or offline means in connection with employment or consulting opportunities, which may also be subject to other Policies. We may also collect Computer Internet Protocol ("IP") address, unique device identifier ("UDID"), cookies, web beacons, web server logs and other technologies and other data linked to a device, and data about usage of our Sites ("Usage Data"). A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

Other types of information we may collect include your name, email address, username, password, phone number, location and any other information you choose to provide. We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site.

0xbow may require certain information from time to time for purposes of meeting its due diligence requirements specifically to comply with anti-money laundering and countering financing of terrorism obligations.

Use of Personal Data

We use the Personal Data that we collect:

To make our products and Sites more intuitive and easier to use we use device data, cookies and other information that you may provide. This data is necessary for our legitimate business interests in monitoring how our products and Sites are used to help us improve these products and Sites, and the information and tools available on these products and Sites.

To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate business interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.

To consider individuals for employment and contractor opportunities and manage on-boarding processes we use job applicant data. The processing is necessary for the purposes of recruitment and on-boarding.

To carry out any other legitimate purpose for which the information was collected.

We may also use automated technologies to sense, detect or collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site. The information we collect through cookies and similar technologies helps 0xbow (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our products and website; (3) measure the usability of our products and website and the effectiveness of our communications; and (4) otherwise manage and enhance our products and website, and help ensure they are working properly. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

How we share your information

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third-party;

In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;

With your consent or at your direction; and

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Specific provisions for EU-residents: This Section 6 applies to you, if you are from the European Union. 0xbow adopted the following provisions, to comply with the EU 2016/679 Directive General Data Protection Regulation ("GDPR"), pursuant to which 0xbow will be considered as a "Data Controller" with respect to our use of Personal Information of resident of the European Union.

Legal Basis. We base our processing of any personal data as "Data Controllers" based on the following lawful grounds: 0xbow relies, primarily, on your consent to the terms of this Policy and the terms set forth under our Terms of Use, as a legal basis for processing:

any Personal Information related to you or communicating any other promotional material

may collect and use your Personal Information when it is necessary for one of the legitimate uses set out in Section 3 above, which we believe are not overridden by your fundamental rights.

may process your Personal Information to comply with a legal obligation and to protect our users' vital interests. If, at any time, you wish to exercise your rights in accordance with the provisions provided by law (including as provided under Section ‎12 of this Policy) you may send us an email to via support@0xbow.io and request: to access your Personal Information together with information about how, and on what basis, such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can contact us via support@0xbow.io and we shall use commercially reasonable efforts to accommodate your request, if applicable; rectify any of the Personal Information being held when such information is inaccurate; to delete or restrict access to your Personal Information in limited circumstances as described under the GDPR. Please note that if we need to delete any Personal Information related to you, as per your request, it can take time until we completely delete residual copies of such data from our servers and backup systems.

to withdraw your consent to the processing of your Personal Information. However, please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal.

to obtain and reuse your Personal Information for your own purposes across different services, as part of your right to data portability.

‍Please note that you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA). If you have any concerns with respect to our methods of processing any Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to support@0xbow.io. If you reside in a country from the European Economic Area, then, by agreeing to the terms of this Policy, you agree to 0xbow sharing your Information outside of the European Economic Area. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use 'standard data protection clauses' which have been approved by the European Commission for such transfers. We shall not charge you for requesting to exercise any of the aforementioned rights.

Specific provision for California residents.

This Section 7 applies to you only if you reside in the State of California, United States. 0xbow adopted the following provisions to comply with the California Consumer Privacy Act ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Section ‎7.

The following categories reflect the type of personal information which 0xbow has collected within the last twelve (12) months:

Identifiers and Personal information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account usernames, as well as Personal Information as such term is defined in this Policy.

Electronic network activity information, including, but not limited to, browsing history and any additional information related to your interaction with our Service.

0xbow has obtained such information as set forth in Section ‎7.1 above and Personal Information as provided under Section ‎1.1 above (for the purpose of this Section ‎7, the "Personal Data").

0xbow may use the Personal Data it collects or receives for its legitimate interests (as set out in Section 3 above), which 0xbow believes are not overridden by your fundamental rights. 0xbow may also disclose such Personal Data to third parties for its legitimate purposes as described in Section 5 above.

In the preceding twelve (12) months, 0xbow has disclosed the following Personal Data for our business purposes:

Identifiers (including your name, email address, profession).

Personal Data's categories as listed in the California Customer Records statute).

Inferences.

Identifiers and Personal information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account usernames, as well as Personal Information as such term is defined in this Policy.

Electronic network activity information, including, but not limited to, browsing history and any additional information related to your interaction with our Service.

0xbow has obtained such information as set forth in Section ‎7.1 above and Personal Information as provided under Section ‎1.1 above (for the purpose of this Section ‎7, the "Personal Data").

0xbow may use the Personal Data it collects or receives for its legitimate interests (as set out in Section 3 above), which 0xbow believes are not overridden by your fundamental rights. 0xbow may also disclose such Personal Data to third parties for its legitimate purposes as described in Section 5 above.

In the preceding twelve (12) months, 0xbow has not sold any of your Personal Data.

Your rights as a California Resident. You are entitled to request the following specific rights under the CCPA, solely with respect to Personal Data related to you:

Request to know (a) what categories and specific components of Personal Data we collect about you and from which sources; (b) categories of Personal Data that we disclosed for the purpose described in Section 5 above, and the categories of third parties with whom we have shared any particular category of your Personal Data. If we disclose any of your Personal Data to a third-party, we will provide you, after authenticating your identity, with a list that will identify the specific category of your Personal Data which was disclosed.

Request that we delete any Personal Data we collect about you. After authenticating your identity, we will delete (and direct our service providers to delete) any Personal Data related to you from our records, unless an exception applies. Please note that if we need to delete any Personal Data related to you following your request, it can take time until we completely delete residual copies of Personal Data from our servers and backup systems.

Instruct us not to sell any Personal Data related to you that was collected by us.

You have the right not to be discriminated against by 0xbow, for exercising your rights under the CCPA.

If you have any concerns about how we process Personal Data related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to support@0xbow.io. Please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal. Also, please note that 0xbow shall not charge you for requesting to exercise any of the rights set forth in this Section ‎3.

Transfer of Personal Data To Other Countries

We may transfer your Personal Data to countries outside of your country of residence, including, but not limited to the European Economic Area ("EEA") and the United States. Personal Data is not processed outside of the countries listed in this Privacy Policy.

How We Protect Your Information

Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.

How Long We Retain Your Information

We strive to only keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for longer than we otherwise would.

Children's Information

Our Services are not directed to children under the age of 18. If you learn that a child under the age of 18 has provided us with personal information without consent, please contact us.

Your Rights

If you are resident in countries with applicable data privacy laws you have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you, to require that any incomplete or inaccurate Personal Data is amended, to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations), to object to the use of your Personal Data or to withdraw consent. You may also have a right to lodge a complaint with the local data protection authority if you believe that we have not complied with the applicable data protection laws. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at support@0xbow.io.

Changes To This Privacy Policy

We reserve the right to change and update this Privacy Policy from time to time. If we make changes, you will be notified of the change by the date at the top of Privacy Policy, which will reflect the last date updated.

Third-Party Services, Applications, and Websites

Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.