Privacy Notice
Overview
Effective Date:
February
1, 2021
This Privacy Notice explains how Titan IO, Inc. (“Titan” or “we,” “us,” or “our”) collects, uses, and discloses
information about you when you visit, access, or use our websites, domains,
applications, software, and other online products and services, including
online portals and our network (collectively, the “Services”) or when you otherwise interact with us. By visiting
https://www.titan.io (the “Site”) or
otherwise using our Services, you acknowledge the practices described in this
Privacy Notice.
We will occasionally change this Privacy Notice. When
we do, we will notify you by revising the date at the top of this Privacy
Notice and, in some cases, we may provide you with additional notice (such as
adding a statement to our homepage or sending you a notification). We encourage
you to review the Privacy Notice whenever you access the Services or otherwise
interact with us to stay informed about our information practices and the
choices available to you.
Contact Us
If you have any questions about this Privacy Notice,
you may contact us via email at info@titan.io.
Information We Collect
·
Information You
Provide to Us
:
We collect information you provide directly to us. For example, to use our
Services we may ask you to provide us with certain information in order to
create an account, which may include personal information that can be used to
contact or identify you, such as your name, email address, billing address,
phone number, username and/or password. If you request technical or product
support, you may provide additional information on your usage of the Services,
including your environment set up and log files.
·
Information We Collect
from Third Parties
: We collect information that you provide the service providers helping
us provide our Services, some of which may include personal information. For
example, we may collect information related to know-your-customer, identity
validation, authorization, and eligibility services.
·
Information We Collect
Automatically
:
When you access or use our Services, we automatically collect information about
you, including:
o
Log Information
: This is information about
your use of the Services, including the type of browser you use, access times,
pages viewed, session IDs, your IP address, your phone number and the page you
visited before navigating to our Services.
o
Equipment Information
: This
is information about the equipment, computers, devices, and hardware you use in
connection with your access or use of the Services, including the hardware
model, specifications, operating system and version, and unique device
identifiers.
o
Location Information
: This is
information about the precise location of your equipment, computers, devices,
and/or hardware (collected in accordance with your device permissions).
o
Hashpower Information
: This is
information related to your mining operations to allow for efficient use of the
Services, such as device and/or client hashrate.
o
Financial Information
: This is
information related to payouts earned, amounts withdrawn, public key addresses
used, information needed to issue Form 1099s or other tax forms and account
balances.
Use of Information We Collect
We use information to provide, analyze, administer,
enhance, and personalize the Services and our marketing efforts, to process
your account registration, and to communicate with you on these and other
topics. Specifically, we may use information collected about you via the
Services to:
·
Provide and secure our Site and Services;
·
Create, monitor, and manage your account;
·
Deliver advertising, promotions, and other information
regarding the Services to you;
·
Analyze and understand our audience, improve the Services
(including our user interface experiences), and optimize content selection and
delivery;
·
Email you regarding your account or notify you of updates to
the Services;
·
Compile aggregate data and analysis for internal business
purposes;
·
Request feedback and contact you about your use of the
Services;
·
Resolve disputes and troubleshoot problems;
·
Respond to product and customer service or support requests;
·
Perform other business activities as needed;
·
Comply with and enforce legal requirements, agreements, and
policies;
·
Protect your and our rights; and
·
Any other purpose that is disclosed to you at the time we
collect the information that is related to a request made by you or for which
you have given express permission or consent to us.
Disclosure of
Information
We may share information collected from or about you
in the following ways:
·
Service Providers:
We may share your information with
service providers and third parties that perform services for us on our behalf,
including data collection, monitoring, and analysis; know-your-customer,
identity validation, authorization, and eligibility services; email and/or
content delivery; hosting services; customer service; and marketing access.
·
By Law or to Protect
Rights:
If
we believe the release of information about you is necessary to respond to
legal process, to investigate or remedy potential violations of our policies,
or to protect the rights, property, and safety of others, we may share your
information as permitted or required by any applicable law, rule, or
regulation. This includes exchanging information with other entities for fraud
protection.
·
Business Transfer or
Fundraising:
In
connection with any reorganization, restructuring, merger or sale, other
transfer of assets, or if we are otherwise involved in a change of control
transaction or in connection with our fundraising activities, we may transfer
information, including your Personal Data, to one or more third parties as part
of the transaction, including the due diligence process. You acknowledge that
such transfers may occur and that the transferee may decline to honor
commitments we made in this Privacy Notice.
·
Parties With Your
Consent or When You Otherwise Choose to Share.
In addition to the sharing
described in this Privacy Notice, we may share any information from or about
you with any party when we have your consent or when you otherwise choose to
share such information.
Protecting Information
We Collect
While no one can guarantee
your personal information is completely secure at all times, we use
administrative, organizational, technical, and physical safeguards to protect
the personal information we collect and process. Our security controls are
designed to maintain data confidentiality and integrity, and to give us
appropriate access to your data.
Among other things, we use professional third party service
providers and data centers to provide our website, and enter into
confidentiality agreements with them where appropriate. Those service
providers and data centers implement industry-standard measures to protect the
security of the personal information we collect, such as SSL (Secure Socket
Layers), firewalls, digital certificates, and encryption.
Retention of Information
We keep your personal
information in line with set periods of time calculated using the following
criteria:
·
How long it is reasonable to keep
records to show we have met the obligations we have to you and by law;
·
Any periods for keeping
information which are set by law or recommended by regulators, professional
bodies or associations; and
·
Any relevant proceedings that
apply.
We keep Log Information and
Cookie Information for indefinitely.
Your Control Over Information
·
Account Information
: You may update or correct
information about you at any time by logging into your online account or
emailing us at the contact email address below.
·
Geolocation
: We may have access to your IP
address and if you enable the collection of location information your
geolocation. You can subsequently stop the collection of this information at
any time by changing the preferences through your web browser or the Services,
as applicable. If you do not allow us to collect your location information,
certain features may no longer function or be available to you.
·
Cookies
: We use cookies to collect
information (e.g., Log Information and Equipment Information discussed above)
and to help improve our Services and your experience. Cookies are sent to your
browser from a web site and stored on your computer’s hard drive or in device
memory. Most web browsers are set to accept cookies by default. If you prefer,
you can usually choose to set your browser to remove or reject browser cookies.
Please note that if you choose to remove or reject cookies, this could affect
the availability and functionality of our Services.
·
Opting Out
: You may opt out of future contacts
from us at any time. You can do so at any time by contacting us via the email
address below or through the unsubscribe link in our emails. If you opt out, we
may still send you non-promotional emails, such as those about your account or
our ongoing business relations.
Links
Our Services, including the Site, may contain links
to other sites. Please be aware that we are not responsible for the content or
privacy practices of such other sites. We encourage our users to be aware when
they leave our site and to read the privacy statements of any other site that
collects their information, including personally identifiable information.
Regional Provisions
European Economic Area
If you are in the European Economic Area (“EEA”), you have certain rights and
protections under the law regarding the processing of your Personal Data (as
defined under the General Data Protection Regulation).
·
Legal Basis for
Processing
.
If you are in the EEA, when we process your Personal Data we will only do so in
the following situations:
o
We need to use your Personal Data to perform our
responsibilities under our contract with you (e.g., providing the Services you
have requested).
o
We have a legitimate interest in processing your Personal
Data. For example, we may process your Personal Data to send you marketing
communications, to communicate with you about changes to our Services, and to
provide, secure, and improve our Services.
o
We have your consent to process your Personal Data. For
example, when you provide us with consent to send emails to you containing
information about our products and services, our affiliated or partner
entities, or other industry or business news.
o
We have a legal obligation to process your Personal Data.
For example, we may need to retain certain transactional data to comply with
our legal obligations. We may also be required to retain information about our
interactions with you when you make certain requests for information to comply
with our regulatory obligations.
·
Data Subject Requests
and Rights
.
o
If you are in the EEA, you have the right to access or
modify Personal Data we hold about you and to ask that your Personal Data be
corrected, erased, or transferred. The right to transfer your Personal
Data or the right to data portability means that you can request that we
provide certain Personal Data about you that we process in a machine-readable
format. The right to erasure means that you can request deletion or removal of
certain Personal Data we process about you.
o
You also have the right to know whether, and for what
purposes, we process Personal Data about you, the right to be informed about
the Personal Data we collect and/or
process about you, the right to know with whom we have shared Personal Data
about you, for what purposes, and what Personal Data has been shared (including whether Personal
Data was disclosed to third parties for their own direct marketing purposes),
and where processing of Personal Data about you is based on consent, the right
to withdraw your consent to such processing. You may also have the right to
object to, or request that we restrict, certain processing. If you would
like to exercise any of these rights, you may contact us at our contact email
address shown below and include in the subject line the nature of your request.
Note that we may need to request additional
information from you to validate a request relating to the exercise of any of
the rights above.
·
How We Store Your
Personal Data
Your information is securely
stored in the United States and in other countries including in China and in
countries in Europe. You understand and agree that we may
transfer your information to the United States or our offices in other
countries. We endeavor to apply suitable safeguards to protect the privacy and
security of your personal data and to use it only consistent with your
relationship with us and the practices described in this Privacy Notice.
·
Questions or
Complaints
.
If you are
in the EEA and have a concern about our processing of Personal Data that we are
not able to resolve, you have the right to lodge a complaint with a data
privacy authority. For contact details of your local Data Protection
Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
California
If you are a California
resident, please note that we do not share information that identifies you
personally with non-affiliated third parties for their own marketing use
without your permission.
Under the California
Consumer Privacy Act (“CCPA”), California residents have the right to
know and request access to their Personal Information (as defined under the
CCPA) collected and shared within the past 12 months, the right to delete their
Personal Information in accordance with the CCPA, the right opt out of selling,
and the right not to be discriminated against if invoking these rights granted
by the CCPA.
·
Submitting CCPA Requests
If you are a California
resident and a consumer of the website and our services, you can submit a
request by contacting us at the following email address:
info@titan.io.
For requests that require
identity verification, we will take commercially reasonable steps to verify
your identity, including asking you to provide us with information to confirm
your identity using the information we have on file. If you wish to designate
an authorized agent to make a request on your behalf, please indicate that when
submitting your request.
We will make good faith
efforts to respond to your request. There may be circumstances under the CCPA
in which we cannot, or need not, respond to your request. Any requests that can
be processed by us will be done so in no more than 45 days from the date we
receive your request, unless the law requires a faster response or we notify
you that an extension is required. In case of an extended completion period, we
will process your request in no more than 90 days from the date of your
original request. Consumers are limited to two requests to know/access their
personal information within a 12-month period.
·
Personal Information Collected, Used and Disclosed within
the Past 12 Months
Category
of data collected from consumers within the past 12 months
: |
Source
of this data |
Business
or commercial purpose |
Identifiers such as a name, online identifier,
Internet Protocol address, and email address |
You |
Provide our Site/Services |
Commercial information such as Services purchased
or obtained and account history |
You, service providers, and automatically through
use of service |
Provide our Site/Services |
Internet or other electronic network activity
information, including, but not limited to, information regarding a
consumer’s interaction with our Site/Services |
You, service providers |
Provide our Site/Services
Analytics |
Geolocation data |
You |
Provide our Site/Services
Analytics |
Because our services are
intended for adults, we do not knowingly collect personal information from
children or minors under the age of 16, nor do we knowingly share any such
personal information with third parties.
Nevada
Residents of Nevada have a right to submit a request to opt-out of sale of personal information, referred to under Nevada law as “covered information.” Please note, however, that we have not “sold” covered information as that term is defined by Nevada law, nor do we intend to “sell” any such information.