Privacy Policy

Last Updated: 1 November 2021

hashport DLT Solutions Ltd. (“HP”, “we”, “us” and “our”) respects your concerns about privacy and appreciates your trust and confidence in us. This Privacy Policy explains how your personal information is collected, used, and disclosed. This Privacy Policy applies to our interoperability portal (our ‘Service’), that enables representative digital assets to move between third-party peer-to-peer distributed ledger technology-based platforms and their systems and applications. By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Use.

Our Service contains links to third-party distributed peer-to-peer networks and applications that are not owned or controlled by HP. As we do not control these third parties, we do not endorse or assume responsibility for their privacy statements. We encourage you to read the privacy policies of the third parties you will engage by using our Service. By using our Service, you acknowledge that HP’s Privacy Policy and Terms of Use do not apply to your use of such third party services.

1. Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process Personal Data through your use of our Service and this website. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data if any.

This website is not intended for children and we do not knowingly collect any data relating to children.

For the purposes of EU data protection laws (“GDPR”), hashport DLT Solutions Ltd is the data controller (i.e., the company who is responsible for, and controls the processing of, your Personal Data). The data controller can be reached at privacy@hashport.network.

2. Data we collect and how we collect it

Personal Data or Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Direct interaction with our Service:

Visiting our website: As a general rule, no Personal Information is collected about you when you visit our website, apart from the Identity/Contact Data submitted by you in a ‘contact us’ form, marketing opt-in or other potential links such as for contests or support.

Use of Our Service: By using our Service, you may provide us with certain Personal Data that includes, but is not limited to location data, wallet addresses, transaction amounts, browser version and device type. For the avoidance of doubt, hashport does not store any information in respect of your wallet addresses and transaction amounts on its servers.

Automated interactions from using our Service:

From time to time, though not actively sought or expected, we may receive information about you from third parties, such as our service providers. We may also collect information about you that is publicly available.

Third parties or publicly available sources:

From time to time, we may receive information about you from third parties, such as our service providers. We may also collect information about you that is publicly available.

3. How we use your Personal Data

We may use your Personal Data to:

Allow you use of our Service and applications and respond to your requests;
Provide you with the services, support or information requested;
Operate, maintain and add to the features and functionality of our Service;
Improve our website’s user experience and communicate better to engage users;
To send marketing emails or messages related to our Service;
Monitor aggregate metrics;
Analyze, diagnose and fix issues in our Service offerings; and
To process your job application for an open position.

We allow you to submit content to the Service and all transactions are public and traceable via third party sites or applications. Your wallet addresses, any information disclosed in the memo field, and any other Personal Information submitted by you, will be available publicly by default when you make a transaction and submit content to the Service or other public spaces of the Service, such as the Hedera Consensus Service. Except for transactions, which only remain on the Service temporarily, all other Personal Data you post to the Service will remain on the Service until you choose to remove it by submitting a delete request to privacy@hashport.network. Any removal of Personal Data may affect the functionality of the Service. For the avoidance of doubt, hashport does not store any information in respect of your public/private keys/wallet credentials on its servers. Also, your information is only stored for you to interact with the Service and is not used by us outside of this purpose.

We use your Personal Data to operate, maintain, and provide to you the features and functionality of the Service. If you provide information to us for a specific purpose, such as your email, we may also send you messages related to such purpose. We may also use your Personal Data where it is needed in order for us to comply with a legal obligation.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis for needing to do so.

We may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. How do we share your personal information?

We may share your Personal Information with:

The public and other members of the Service. Any content you post to public areas of the Service, including public groups, will be viewable by others on the Service and the public;

Other users of the Service. We share your information with third parties with whom you communicate on the Service. You control who you want to communicate with and what information you share;

Third parties at your request. For example, you may have the option to share your activities on the Service through email, text, or on various social media sites. Third parties may also include those whom we partner to provide contests and sweepstakes you may choose to participate in or enter. Such partners will usually be identified by name in relevant communications.

Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and

Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms and Conditions or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of hashport, our visitors, or others.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

5. How do we store and protect your information?

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Service may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

6. Your control over your information

How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., changes/updates to features of the Service, technical and security notices).

Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@hashport.network.

7. Types of Personal Information shared through third party tracking

Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Google Display Network Impression Reporting, , and Google Analytics Demographics and Interest Reporting. These features enable us to use cookies to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

8. How we store and protect your information

Data storage and transfer: Information collected through our Service may be stored and processed in any country in which HP or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy.

For individuals based in the EU, we store Personal Data for as long as necessary to fulfill the purposes for which we collect the data (see above under paragraph 3) and in accordance with our legal obligations and legitimate business interest, except if required otherwise by law.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable and we cannot guarantee absolute security of our systems. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised. We may also take other steps, in accordance with any applicable laws and regulations.

9. Specifics to EU privacy rights:

If you are located in the EU, you have the following rights in respect of your personal data that we hold:

Right of access. The right to obtain access to your personal data;
Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete;
Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed;
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;
Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another;
Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

9. Specifics to UK Privacy Rights

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. How do you contact us?

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@hashport.network.

11. What about changes to our privacy policy?

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change this Privacy Policy in a material manner, we will update the ‘last modified’ date at the top of this page and notify you that material changes have been made to this Privacy Policy. If you object to any changes, you may terminate your use.