Website Privacy Notice

Last Updated: May 2024

1. INTRODUCTION

Anchor Labs, Inc. and its subsidiaries and affiliates (hereinafter, “Provider,” “we”, “our” or “us”) offers an unhosted Digital Asset software wallet that allows for independent storage and control of Digital Assets by the user (the “Wallet”). Privacy and data protection are a top priority for us, and we encourage you to read this Privacy Notice fully to understand our privacy practices.

2. SCOPE AND APPLICABILITY

This Website Privacy Notice (“Notice” or “Policy”) explains how we collect, use, store, share, delete, and protect your Personal Information when you interact with our website.

This Policy also describes the choices that Individuals have with respect to their Personal Information in relation to this website, and how to contact Provider to learn more about our privacy practices.

• If you are using the Wallet we will use and share any information, including Personal Information that we collect from or about you in accordance with our Unhosted Wallet Privacy Policy (available on our Privacy Center page), which provides certain choices with respect to the use and sharing of your Personal Information.

3. PERSONAL INFORMATION WE COLLECT

We may collect Personal Information about you in several ways when you use our website, as described below. 

‍Information You Provide. We collect the information you provide to us directly when you use our website. You can choose to provide Personal Information for: 

• Website Use – We collect some or all of the following Personal Information about you when you use our website to contact us:
  • name
  • email address
  • other information you choose to provide to us when you contact us with your inquiries.
• Research – For internal research and reporting.
• Security – To block disruptives uses.
• Job Applications – If you apply for a job with Provider, in addition to collecting the Personal Information described under “Website Use,” you will be directed to a third party platform that may collect the following Personal Information about you:
  • mailing address
  • phone number
  • job history
  • resume/CV
  • LinkedIn profile
  • any other Personal Information you choose to submit along with your application including U.S. Equal Opportunity Employment Information.
• Marketing Activities – If you attend our events, business meetings, visit our booth at industry conference or interact with our online or targeted marketing materials, in addition to the Personal Information described under “Website Use,” we may collect one or more of the following business contact information about you:
  • company
  • job title/role
  • other information that may be contained on your business card, if you choose to provide one
  • phone number
  • other information as described below in “Information We Collect”.

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Publicly Available Information. We may collect information about you via the following publicly available resources when you use our services:

• public records

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Note that we may combine information received from third parties or publicly available resources with information we have collected directly from you.

Information We Collect. When you use our websites or interact with our online targeted marketing materials, with your consent, we may use cookies and other tracking technologies to collect the following information about you:

• Browser and Device Information – Using cookies and other tracking technology, we may collect:
  • Geolocation data (e.g., zip code, GPS-based information including altitude)
  • Motion tracking (e.g., number of steps taken, heart rate)
  • IP address
  • Wi-Fi connectivity
  • Phone carrier and manufacturer
  • Mobile operating system version
  • Battery level
  • Device type/model
  • Version of Provider application used
  • http referrer fields
  • browser type and version
  • unique device identification numbers or pages viewed
  • date and time of visit
  • number of times you return to our website

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use information-gathering tools, such as cookies and other tracking technologies, to collect your Personal Information and other information as you use our services. Tracking technologies will only be deployed after you have permitted us to do so by providing consent. 

What Are Cookies? Cookies are small text files that are stored through the browser on your computer or mobile device. Cookies serve a variety of functions; they help you navigate between website pages efficiently and may improve the user experience on a website. Cookies vary in duration (they can be “persistent” or “session-based”), and by whom they are served (“first party” cookies are directly from us; “third party” cookies are from other parties on our behalf). They are only one of several types of technologies used to track online behavior.

Why We Use Cookies and Other Tracking Technologies. Provider uses these technologies to collect information that helps us better serve our users and enhance this Site, such as by tracking return visits, collecting Site usage information, and performing research, analysis, and Site analytics. At Provider, we use cookies to:  

• Track how you were referred to our website
• Improve the website functionality
• Perform analytics and marketing integration 
• Deliver personalized advertisements and other marketing offers

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Types of Cookies We Use. On our website, we use the following types of cookies:

• Performance and Analytics Cookies – We use performance and analytics cookies to understand how visitors engage with our website. These cookies help us:
  • understand how visitors arrive at our website
  • monitor website usage and performance
  • remember you when you return to the website, and
  • improve our website content.
• Marketing and Advertising Cookies – Provider and our service providers use marketing and advertising cookies to provide you with advertising based on your browsing activities and interests. These cookies monitor which ads have been served to your browser and which web pages you were viewing when such ads were delivered.
• Google Analytics and Integration – On our website, we use third party analytics and marketing integration services such as Google Analytics and Hubspot to track and optimize our website performance and marketing activities.
• Google Analytics – Google Analytics helps us understand how users engage with our website. Like many services, Google Analytics uses first party cookies to track user interactions and in our case, they are used to collect information about how users use our website. This information is used to compile reports and to help us control the use of cookies. You can control the use of cookies through your web browser settings. Please note that if you reject or delete cookies, some of our website features may no longer function to improve our website and services. To learn more about Google Analytics’ privacy practices, please visit Google’s Privacy Policy page here.  
• Cross-Device Tracking – Provider and our service providers match your browsing activity on our website across different devices. For example, if you browse our website via a mobile device and move to a laptop, we attempt to match your browsing activity from the two devices.

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Managing Cookies & Online Tracking. Where appropriate or legally required, we will describe how we use the information collected about you so that you can make choices about how your information is used.

• Managing Cookies – You can control the use of cookies on your device at any time by changing your preferences or options in your browser settings. Each browser provides different mechanisms for managing cookies. You can usually find these settings in the “Options” or “Preferences” menu of your browser; otherwise, look at your browser’s help menu to determine the best way to modify your browser’s cookie storage. You can also block, disable, or delete the cookies that are stored on your device. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages on our website. To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/.
• Analytics Preferences – For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To learn more about Google Analytics, visit Google's "How you can control the information collected by Google on these sites and apps" article available here. 
• “Do-Not-Track” – Some browsers allow a user to send “Do-Not-Track” signals to a website to prevent tracking of that Individual’s activity. At this time, we do not respond to web browser “Do-Not-Track” signals. To learn more about browser tracking signals and DNT, visit http://www.allaboutdnt.com.
• Targeted Advertising – Targeted advertising (also known as online behavioral advertising) is the practice of collecting and using Personal Information from a device, particularly concerning browsing history, and using it to deliver advertisements that may be of specific interest to that user. Some companies that we work with may use cookies and other tracking technologies to deliver targeted advertisements. Depending on your location, we will require you to opt in for your Personal Information to be collected in order to receive targeted advertisements.

5. HOW WE USE PERSONAL INFORMATION

We use Personal Information we have about you as described below.

• Communicate with You – We use the information we have about you to respond to your inquiries, requests, and/or send important notices. This includes, for example, delivering customer support, and periodic emails related to company news, updated policies, product/service updates and information, job openings, or press releases.
• Market Our Services – We use the information we have about you to market our services. This includes, for example, sending you email communications about products, offerings, events and webinars or customized offers or materials.
• Comply with The Law – We use the information we have about you to comply with applicable laws, regulations, and contractual obligations. This includes, for example, conducting compliance and/or security checks, audits, or assessments, enforcing our contracts and agreements with our customers, or complying with applicable law enforcement obligations.
• Other Purposes You Consent To – We use the information we have about you for other purposes if you consent to those uses at the time you provide your Personal Information.
• De-identified or Aggregate Information – We use the information we have about you to create de-identified or aggregate information, such as de-identified demographic or location information, information about devices used to access our website, or other relevant analyses. We also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, etc.

6. HOW WE SHARE PERSONAL INFORMATION

Anchorage Digital may share the Personal Information we have about you as described below.  

• Across Our Affiliates – We may share information across Provider’s affiliates to provide you with services, prevent fraud, comply with the law, or in the event of a sale, merger, acquisition, or other liquidity event.

• Advertising Partners – We may share information with third parties to facilitate advertising on third party websites or mobile apps. If you do not want your Personal Information shared with our advertising partners, contact us as described in Section 11 “Contact Us.”  
• Sale, Merger, or Acquisition – As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Provider’s assets are sold or transferred to a third-party, end-user information would likely be one of the transferred business assets.
• Legal, Regulatory, Safety, and Compliance Purposes – In certain situations, we may be required to share your information with law enforcement officials or government authorities as required by laws, regulations, legal processes, and governmental requests. These situations may include, but are not limited to:  
  • complying with a subpoena or other legal process requests;
  • protecting your rights;
  • protecting your safety or the safety of others;
  • investigating fraud;
  • responding to a government request.

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Any third parties that we share your Personal Information with are limited by law and by contract in their ability to use your Personal Information. Provider requires third party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Policy, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the privacy and data security practices of third parties outside of Personal Information we receive from or transfer to them.

If you elect to receive periodic email communication from us (i.e., company news, product and service information), you may choose to opt out from receiving such communications by clicking the ‘Unsubscribe’ link provided in these emails.

7. HOW WE PROTECT PERSONAL INFORMATION

At Provider, we take our responsibility to protect the security and privacy of your Personal Information seriously. We are committed to maintaining the confidentiality, integrity, and security of your Personal Information and taking precautions to protect such information. We use reasonable and appropriate administrative, technical, and physical safeguards to protect information we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We regularly review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to our community, our customers, and ourselves. We also require third party service providers acting on our behalf or with whom we share your information to maintain security measures consistent with industry standards.

8. CHILDREN’S PRIVACY

Our services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any Personal Information from, or market to, Individuals under the age of 13. 

If we become aware, or If you learn that an individual under the age of 13 has provided us with Personal Information contrary to these rules, please contact us as described in Section 11 “Contact Us” and we will delete the information from our systems.

9. THIRD PARTY SERVICES, APPLICATIONS, AND WEBSITES

Certain third party services, websites, or applications used to navigate to and from the website have separate user terms and privacy policies that are independent of this Policy. 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 before use.

10. CHANGES TO THIS NOTICE

We may change or update this Notice in the future. When we do, we will post the revised version on our website. This notice was last updated and became effective on the date posted at the top of this page.

11. CONTACT US

If you have questions about this Notice, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us. You can email us at privacy@anchorage.com.