NFTTrack Privacy Policy

Last Update: Sep. 1st, 2022.

NFTTrack ("us", "we", or "our") provides services through a Platform (hereinafter referred to as the "Service(s)").

This Privacy Policy applies to your Personal Information when you visit this Site or use the Services. This Privacy Policy explains how we may collect, use, and disclose your Personal Information when you visit this Site or use the Services.

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use this Site and the Services.

This Privacy Policy is incorporated by reference into any terms of service made available on the Site or in the Services. By using the Services, you agree to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately stop using the Services.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Upon your acceptance of this Privacy Policy, your Personal Information collected by us prior to the time of acceptance shall also be subject to this Privacy Policy.

1. Definitions

1) Platform

Platform is the NFTTrack iOS and Android apps and website.

2) Personal Information

Personal Information means personal information that can be associated with an identified or identifiable person.  "Personal Information" can include name, postal address, telephone number, email address, financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, and Taxpayer ID).  Personal Information does not include information that does not identify a specific User.

3) Social Media Platform(s)

Twitter, Discord and other social media platforms in which the NFTTrack users can utilize the Services.

4) Marketplace(s)

OpenSea and other marketplaces for NFTs, digital items and crypto collectibles where the NFTTrack Users can trade NFTs, digital items and crypto collectibles.

5) Data Subjects

Data Subject is the identified or identifiable person to whom personal data relates. We process personal data of two main categories of Data Subjects.

NFTTrack Users: Individuals who

  1. browse the Platform as a visitor
  2. registered with the NFTTrack Platform through their Twitter account, or
  3. registered with the NFTTrack Platform through their Twitter account and connected their crypto wallets.

Social Media Platform or Marketplace Users: Individuals

  1. who are friends with or followed by NFTTrack Users on Social Media Platforms or Marketplaces.
  2. who bought, sold, or owned an NFT, digital item or crypto collectible which has a large trading volume.
  3. whose accounts are added by NFTTrack Users into NFTTrack’s system to follow up the transactions of such accounts, as such account related data is public and anonymous data stored in blockchain.

6) Data Controller

Data Controller means the natural or legal person (either alone or jointly or in common with other persons) who determines the purposes and means of the processing of personal data.

We act as a Data Controller when we process personal data of the NFTTrack Users and the Social Media Platform or Marketplace Users.

The NFTTrack Users may also act as Data Controllers when they process personal data of the Social Media Platform or Marketplace Users.

7) Data Processor

Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Data Processors in order to provide better service for you.

2. DISCLAIMER

In some cases (especially when we obtain the personal data not from the data subjects, e.g. from the Twitter or OpenSea platforms or other social networks and marketplaces) we are incapable to inform each data subject rather than by means of this Privacy Policy.

Nevertheless, we commit to implement appropriate measures to protect the data subject’s rights and freedoms and legitimate interests.

3. What Personal Information Do We Collect?

We may collect information about you when you visit our Sites or use the Services, including the following:

a. NFTTrack User

  1. Full name, Social Media Platform username, profile picture and sign in information, and other personal data that you voluntarily provide to us: We may collect such personal data from you directly when you provide us with such information, e.g. when you register with our platform, contact us or add an item to your wish list etc.
  2. If you link your Marketplace account; account information, profile link, and wallet address; NFT, digital item or crypto collectibles bought, sold, or owned; NFT project and collection information, price, and activity details.
  3. IP address, the pages of our Service that visited, the time and date of visit, the time spent on those pages, unique device identifiers and other diagnostic data: We (and third party service providers acting on our behalf) use cookies and other tools (such as apps analytic tools and pixel tags) to automatically collect information about you when you use our apps.
  4. Usage data: We may collect your personal data about how you use our Services from our own records. Your feedback and any information that you voluntarily share with us about your experience of using our Services.
  5. Information about you from third-party sources : We may obtain information from third-party sources such as public databases, ID verification partners, and credit bureaus, where permitted by law. Such information may include your name, account number and/or customer ID with a third party, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.
  6. Other information we collect related to your use of the Services: We may collect additional information, including email address, telephone number, mail address from or about you when you communicate with us, contact our customer support teams or respond to a survey. Such information will be collected to maintain contact with you and to provide the Services.

b. Social Media Platform or Marketplace Users

We collect personal data of you from legitimate sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.

  1. Display name, Social Media Platform username and profile picture.
  2. NFT, digital item or crypto collectibles bought, sold, or owned, project and collection information, price, wallet address and activity details.
  3. Other publicly available information.

4. Use of Your Personal Data

We may use your personal data for the following purposes:

a. NFTTrack User

  1. to provide and maintain our Services;
  2. to fulfill our contractual obligations to you and anyone involved in the process;
  3. to identify and resolve errors, problems or bugs in our Services;
  4. to allow you to participate in interactive features of our Services when you choose;
  5. to review your requests, suggestions and complaints regarding our Services and provide user support;
  6. to retain and evaluate information on your recent visits to our website and how you move around different sections of our app for analytic purposes to understand how people use our website so that we can make it more intuitive;
  7. to improve and personalize our Services based on your needs, requests and suggestions;
  8. to contact you for marketing purposes and promote our services (including push notifications).

b. Social Media Platform User

  1. to provide our Services to the NFTTrack Users by sending them statistical information on NFTs, digital items and crypto collectibles;
  2. to contact you for marketing purposes if you publicly disclose your Social Media Platform account. In such case, you will always have a chance to opt out of such marketing communications.

5. Legal Basis for Processing

We rely on the following legal bases for processing your data:

a. NFTTrack User

  1. You have given consent to the processing of your personal data for one or more specific purposes,
  2. Processing is necessary for the performance of our contract,
  3. Processing is necessary for compliance with a legal obligation to which we are subject,
  4. Processing is necessary for the purposes of our legitimate interests, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

We have a legitimate interest in improving and personalizing our Services based on your needs, requests and suggestions, retaining and evaluating information on your recent visits to our app and how you move around different sections of our app, and contacting you for marketing purposes and promote our services, without affecting your fundamental rights and freedoms.

b. Social Media Platform User

Processing is necessary for the purposes of our legitimate interests, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

6. Disclosure of Your Personal Data

We disclose your personal data,

a. NFTTrack Users

  1. with other members of our family of entities for various purposes, including but not limited to, to provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of the Services, and communications.
  2. with third-party service providers that perform the Services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with the Services, verify your identity, assist in processing transactions, send you advertisements for the Services, or provide customer support. By using the Services, you have acknowledged and approved that third-party service providers have the right to collect, process and store your Personal Information.
  3. with other parties for our business purposes, including:
    1. to protect the vital interests of a person;
    2. to protect our property, the Services and legal rights;
    3. to help assess and manage risk and prevent fraud against us, our Users and fraud involving the Site or use of the Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals;
    4. to companies that we plan to merge with or be acquired by; and
    5. to support our audit, compliance, and corporate governance functions.
  4. with government and regulatory authorities and other organizations to meet legal and regulatory requirements, or to protect or defend our rights or property in accordance with applicable laws.

b. Social Media Platform or Marketplace Users

  1. with the NFTTrack Users for the provision of our Services to them. (We only disclose them to Users who registered with the NFTTrack Platform)
  2. with government and regulatory authorities and other organizations to meet legal and regulatory requirements, or to protect or defend our rights or property in accordance with applicable laws.

In some cases, we may not be able to give you access to your personal data that we hold, if making such a disclosure would breach our legal obligations to our other NFTTrack Users or if prevented by any applicable law or regulation.

7. Marketing

We may occasionally communicate news, updates, promotions and information relating to our products and services. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under the data protection laws in pursuit of our legitimate interests.

We may share personal data with third parties to help us with our marketing and promotional projects or sending marketing communications.

If you do opt out of receiving promotional and marketing messages, we will no longer use or transfer your personal data to third parties for direct marketing purposes. We would like to remind you that we may continue to send transactional or administrative e-mails (e.g. account status and activity updates, respond to your inquiries or complaints etc.) related to our services or your requests for information or materials, even you opt out.

8. Why Do We Retain Personal Information?

We retain Personal Information to fulfill our legal or regulatory obligations and for our business purposes.  We may retain Personal Information for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.  If your Account is closed, we may take steps to mask Personal Information and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws.  We will continue to use and disclose such Personal Information in accordance with this Privacy Policy.

9. How Do We Protect Your Personal Information?

We maintain appropriate technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Information against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. While we are dedicated to securing our systems and the Services, you are responsible for securing and maintaining the privacy of your password(s) and Account registration information, for example, to choose a password of sufficient length and complexity and not reveal account credentials to any third-parties, and verifying that the Personal Information we maintain about you is accurate and current.  We are not responsible for protecting any Personal Information that you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us.

10. Can Children Use the Services?

The Site and the Services are not directed to people under the age of 18 ("Minors").  We do not knowingly collect information, including Personal Information, from Minors or other individuals who are not legally able to use the Site and the Services. If we obtain actual knowledge that we have collected Personal Information from a Minor, we will promptly delete it, unless we are legally obligated to retain such data, and take steps to disable that Account.

11. Third-Party Websites and Social Media Platforms

We may employ third party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used (a "Third-party Service").Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Our Services may include access to publicly accessible blogs, forums, or social media platforms. Personal information you voluntarily transmit or publish online in a publicly accessible blog, forum, or social media platform may be viewed and used by others without any restrictions. By using such services, you assume the risk that your personal information may be viewed and used by third-parties for any number of purposes.

12. Changes to This Privacy Policy

We may revise, modify for replace this Privacy Policy from time to time to reflect changes to our business, the Site or the Services, or applicable laws.  The revised Privacy Policy will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with a prior notice by posting notice of the change on the "Policy Update" page of our website.  We also may notify Users of the change using email or other means. 

13. Transfers of Your Personal Information to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.  By using our Sites and the Services, you agree that all information collected via or by this Site may be transferred, processed, and stored anywhere in the world, including but not limited to, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, to provide the Services. And you consent to your Personal Information being transferred to other countries, including countries that have different data protection rules than your country. We will protect your information as described in this Privacy Policy if your Personal Information is transferred to other countries. We do not represent that our Sites and the Services are appropriate or available in any particular jurisdiction.

14.Contact Us

You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account information or Personal Information. We provide users with the ability to review and correct their personal information where it is inaccurate. You may do this at any time by logging in to your account or by contacting us in Discord http://discord.gg/ZFh3HpQMgz