Privacy Policy

FIGMENT NETWORKs INC. PRIVACY POLICY
Last Updated: December 12, 2018

We at Figment Network Inc. (“Figment,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Figment in connection with our Website and your delegation of tokens to us.

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website, who view only publicly-available content (“Visitors”) and end users (“Users”) who have provided us with information for such Users to use our services (the “Services”) via the Website.

By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. If you would like to delegate tokens with us, please see our Delegation Agreement, which is available here. Your delegation of tokens to us is governed by the Delegation Agreement and this Privacy Policy.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Use.

The Information We Collect and/or Receive

In the course of operating the Website and/or interacting with you, Figment will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

  1. Personal InformationWhen using our Services, you may be requested to provide us with certain personal information about yourself, such as your name, e-mail address, or phone number. All information we collect and/or receive under this section is collectively called “Personal Information.”

    We do not collect any Personal Information from Visitors when they use the Website, unless they provide such information voluntarily.

  2. Wallet InformationWhen delegating digital tokens to us, you will need to provide us with certain information related to the digital wallet in which you maintain the digital tokens being delegated (“Wallet ID”). We will only use your Wallet ID in order to provide our Services to you and not share your Wallet ID with any third parties other than for such purposes.
  3. Other InformationIn addition to the Personal Information and your Wallet ID, we may collect or receive additional information (collectively, the “Other Information”). Such Other Information may include:

    a. From Your Activity. In an ongoing effort to improve the Website and the Services, we automatically collect certain information, including, without limitation:

    IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Website Visitors visit; and similar data; Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data; and Activity and usage information, including pages viewed, preferences, session lengths, and similar data.

    b. From Cookies. We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly.

    c. Third-Party Analytics. We use third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Website and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

The Information Collected by or Through Third-Party Advertising Companies

You authorize us to share Other Information about your activity on the Website with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Website and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

Accessing and Modifying Information and Communication Preferences

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Figment marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Users cannot opt out of receiving transactional e-mails related to their transactions with Figment.

How We Use and Share the Information

You authorize us to use your Personal Information, Wallet ID, and Other Information (collectively, the “Information”) that you provide us in order to provide and improve the Website and Services; to solicit your feedback; and to inform you about our products and services and those of our partners.

You also authorize us to use and/or share Information as described below.

We may, from time to time, share and/or license Information to other companies who may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.

We will access, use, and share the Information as required to fulfill our contractual obligations to you or subsequent requests for Services and/or support by you.

We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

In an ongoing effort to better understand our Visitors, Users, Website, and the products and services of Figment and our promotional partners, we may analyze certain Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Website and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Website and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Figment or others.

How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-Canada Residents

The Website and its servers are operated in Canada and elsewhere. Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of Canada and choose to use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in Canada and elsewhere.

External Websites

The Website may contain links to third-party websites. Figment has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Website. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Figment may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to privacy@figment.network with “Privacy Policy” in the subject line or write to us at:

Figment Network Inc.
c/o Lowenstein Sandler LLP
1 Lowenstein Drive
Roseland, NJ 07068
Attention: Matthew Savare, Esq.

In addition, Figment does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Website. By accessing the Website and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact Figment via e-mail at privacy@figment.network with “Privacy Policy” in the subject line.