OPENPEER PRIVACY POLICY

This Privacy Policy (“Policy”) describes the manner in which OpenPeer ("we", "our", or "us") and our website at openpeer.xyz (the “Site”) use and collect data from individuals. This Policy, which is incorporated into and is subject to the OpenPeer Terms of Service and OpenPeer Protocol Disclaimer, describes the information that we gather from you on the Site, how we use and disclose such information, and the steps we take to protect such information.

High Level Summary

• OpenPeer Labs Inc. is an incorporated company based in the Republic of Panama that operates openpeer.xyz.
• OpenPeer Protocol is a set of smart contracts deployed across the Ethereum ecosystem.It is not governed by OpenPeer Labs Inc.
• OpenPeer Protocol may collect and store personal data, such as first name, last name, street address, date of birth or email addresses.
• OpenPeer Protocol collects non-identifiable data such as public on-chain data and limited off-chain data like device type, browser version etc. This is to help drive production vision, not track users.
• Users are empowered to explore client-side privacy techniques and tools

High Level Summary

• Publicly Available Blockchain Data. When you connect your non-custodial blockchain wallet to the Site, we collect and log your publicly-available blockchain address to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen your wallet using intelligence provided by blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
• Personal Data. We may collect and log your personal information such as your email address, name and other personal data. Note that you are agreeing to share this information with us when you choose to sign up for an OpenPeer account.
• Information from local storage and other tracking technologies. When you use the Site, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.
• Information from other sources. We may receive information about your wallet address or transactions made through the Site from our service providers in order to comply with our legal obligations and prevent the use of our Services in connection with fraudulent or other illicit activities.

Under no circumstances will OpenPeer request for you to share personal information such as private keys or seed phrases.

How We Use the Information We Collect

We use information we collect on the Site in a variety of ways in providing the Site and operating our business, including the following:

• Providing the Services. We use the information that we collect on the Site to operate, maintain, enhance and provide all features of the Site, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Site.
• Aggregated Data. We use the information that we collect on the Site to understand and analyse the usage trends and preferences of our users, to improve the Site, and to develop new products, services, features, and functionality.
• Safety and Security. We may use data to protect against, investigate and stop fraudulent, unauthorised, or illegal activity. We may also use it to address security issues such as bugs, enforce our agreements and protect our users and company.
• Marketing. We use the information that we collect on the Site to send users marketing messages about our products and services.
• Legal Compliance. We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.

We do not collect the content of your communications with other OpenPeer users. All communication is through a third party service enabling wallet-to-wallet communications. These channels are end-to-end encrypted and are not accessible to OpenPeer.

We may send you messages by email or push notifications, with updates about our services, news related to cryptocurrency or decentralised finance, and marketing messages. You have the right to opt-out of receiving such information. You may exercise that right by clicking the “unsubscribe” link in a message we send you, or through contact us at contact@openpeer.xyz.

When We Disclose Information

Except as described in this Policy, we will not disclose information about you that we collect on the Site to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• Any information that you voluntarily choose to include in a publicly accessible area of the Site will be available to anyone who has access to that content, including other users.
• We work with third party service providers to provide website, application development, hosting, maintenance, printing, and other services for us. These third parties may have access to or process information about you as part of providing those services for us.
• We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the Site and any facilities or equipment used to make the Site available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including: (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Site.

Your Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Site. You may update, correct, or delete your account information and preferences at any time by accessing your account preferences page on the Site. If you wish to access or amend any other personal information we hold about you, you may contact us at contact@openpeer.xyz.

We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.

Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Complaints

If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this please contact us as set out below. We will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.

OpenPeer takes all privacy complaints seriously and will aim to resolve any such complaint in a timely and efficient manner.

OpenPeer expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Autoridad Nacional De Transparencia Y Acceso A La Información (which is the regulator responsible for privacy in Panama) at:

Telephone Number: (507) 527-9270 to 74
Mailing Address: Ave. del Prado, Building 713, Balboa, Ancon, Panama, Republic of Panama
Website: www.antai.gob.pa

Third-Party Sites

The Site may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Site. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Site. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Age Requirements

Protecting the privacy of young children is especially important. Our Site is a general audience site not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18. If you believe we have received personal information about a child under the age of 18, please contact us at contact@openpeer.xyz.

Data Security

We use certain managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Notification of Breach

In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate and notify you as soon as possible.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Site, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. Your continued use of the Site after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.