Last Updated: December 6, 2022
1. WHAT PERSONAL INFORMATION DO WE COLLECT?
1.1. Information You Provide to Us
We may collect Personal Information directly from you when you use our Services and access the Site, including:
- Identification information provided about yourself and your authorized users at Registration, including name, date of birth, nationality, e-mail address, country of residence, government-issued identification number, telephone number, or job title.
- For legal entities, we may collect additional information including the institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, proof of legal formation, and personal identification information for all material beneficial owners.
- Financial Information including your transaction history, trading data, and/or tax identification.
- Information about the transactions you make on our Services, such as the name or address of the recipient, the amount, your account balances, the type of digital asset, and/or timestamp.
- Financial information regarding your proposed transactions.
- Your correspondence with Skolem, including survey responses, emails, and information provided to our customer support team or sales team.
1.2. Information We Collect Automatically
To the extent permitted under applicable law, we may collect certain types of information automatically whenever you interact with the Site or our Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Personal Information collected automatically includes:
- Online identifiers such as geo location/tracking details (country or city), browser fingerprint, operating system, browser name and version, personal IP addresses, and/or information about your internet connection.
- Usage data including authentication data, security questions, click-stream data, and other data collected via cookies and similar technologies that uniquely identify your browser.
- Device event information, such as crashes and system activity.
- How your device interacts with our Sites and Services, including pages accessed and links clicked.
- Transaction records.
- Additional information, as permitted by law or required to comply with legal obligations.
1.3. Information We Collect from Third Parties
We may obtain Personal Information about you from our affiliates or third party sources as required or permitted by applicable law. These sources may include:
- Our affiliates, if you link your Skolem Account to third party service providers.
- Public databases, credit bureaus and identification verification partners to help us verify your identity. Such information may include your public employment profile, status on any sanctions lists maintained by public authorities, and other relevant data.
- Public blockchain data, to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
2. HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use information that we collect about you or that you provide to us, including Personal Information, to help us:
- Comply with our obligations under applicable laws and regulations, including identity verification required under anti-money laundering laws.
- Prevent and investigate potential prohibited or illegal activities, fraud, and/or violations of our User Agreement.
- Ensure network and information security, combat spam or other security risks.
- Onboard you as a client and provide you with our Services.
- Communicate with you in relation to our Services, your questions, disputes, or other requests.
- Troubleshoot problems or issues you may encounter on the Site.
- Optimize and enhance your experience.
- Develop new products and improve functionality by understanding how you use our Site and Services.
- Carry out our obligations and enforce our rights arising from our User Agreement, including for billing purposes.
- Notify you about changes to our Site or Services.
- For additional purposes with your consent.
3. HOW DO WE SHARE YOUR INFORMATION WITH THIRD PARTIES?
Skolem does not sell, rent, or trade your Personal Information. We take care to allow access to your Personal Information only to affiliates, service providers or third parties who require access to perform their tasks and duties, including assisting us in operating our Site, conducting our business, or servicing you. We may use third parties for the following purposes:
- To verify your identity by comparing the Personal Information you provide against third party databases and public records.
- For network infrastructure and security.
- For cloud storage and document repository services.
- For administrative tool providers, including email and CRM services.
- To simulate your proposed transactions.
- To execute transactions with DEX and dApps.
- To provide information to our professional advisors, including banking, legal, compliance, insurance, accounting, or other consulting services.
- To support law enforcement, officials, or other third parties in complying with any court order, subpoena, law, or legal process, including to respond to any government or regulatory request.
- When we believe in good faith that the disclosure of Personal Information is necessary to prevent financial loss, to report suspected illegal activity, to protect the rights of others, or to investigate violations of our User Agreement or any other applicable policies.
- For any other purpose disclosed by us when you provide the information.
We may anonymize your Personal Information. If we do, this non-personally identifiable information may be used internally or may be provided to external parties for marketing, advertising, or other uses.
4. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?
We have implemented reasonable physical, electronic and administrative security measures designed to protect your Personal Information from accidental loss, theft, unauthorized access, misuse, alteration, disclosure and destruction. For example, all Personal Information you provide to us is stored on our secure servers, physical access to our offices is restricted and controlled, and we authorize access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee that such misuse, loss, unauthorized access, modification or disclosure will not occur. The safety and security of your Personal Information also depends on you, and the security of the computer, device or network you use to communicate with us. Any transmission of Personal Information is at your own risk. We are not responsible for your circumvention of any privacy settings or security measures contained on the Site.
5. HOW DO WE RETAIN YOUR PERSONAL INFORMATION?
6. THIRD PARTY SITES
Transactions that you perform through the Site will be sent to the blockchain. As a result, some of your data may or will be stored on a blockchain-based network and, therefore, will be accessible to anyone who accesses the blockchain. Data stored on a blockchain cannot be deleted. We are not responsible for the blockchain, its security measures, or the data published in the blockchain.
8. ACCESSING YOUR INFORMATION
If you would like to review or change your information, you may do so by emailing us at email@example.com. We may not accommodate a request to change information if we believe the change would violate any legal requirement or cause the information to be incorrect.
9. CHILDREN'S PERSONAL INFORMATION
Our Site and Services are directed to people who are at least 18 years old and older, and, therefore, we do not knowingly request to collect personal information from any person under the age of 18. If we suspect that information is submitted by a person younger than 18 years old, we will not allow this person to use the Services and will take steps to delete the information as soon as possible. If you believe that we might have any such information, please contact us at firstname.lastname@example.org.
10. CONTACT INFORMATION