Last Updated: 3/17/2020
“Privacy Laws” refers to the applicable legislation, statutory instruments, and any other enforceable laws, codes, regulations, or guidelines regulating the collection, transfer, processing, use, and disclosure of, and/or rights to Users’ Personal Data based on their governing jurisdiction, including, in particular: (i) the California Consumer Privacy Act and its implementing regulations, as amended from time to time (the “CCPA”) and (ii) the European Union’s General Data Protection Regulation (EU) 2016/679 and any Member State implementing legislation, as amended from time to time (the “GDPR”).
Collection and Use of Personal Data
The EXCHANGE uses information about Users, including Personal Data, for a variety of purposes, including:
To enable a better experience when you use the EXCHANGE;
To monitor usage and analyze statistical information related to the EXCHANGE;
To supply information regarding your EXCHANGE usage upon your request;
To respond to comments, questions, and requests;
To carry out our obligations and enforce rights arising from our contractual relationship with you;
To improve and maintain the security, performance, and operational efficiency of the EXCHANGE;
To provide customer support;
To send communications regarding the EXCHANGE or information related thereto; and/or
For any other purpose with your consent.
When you visit the EXCHANGE, the EXCHANGE collects Personal Data. The categories of Personal Data collected by customers through the use of EXCHANGE services varies based on the specific services provided, the engagement and scope of services requested, and/or any configurations or customization's undertaken on your behalf in accordance with the terms of your EXCHANGE Services Agreement. Customers should contact a Customer Service Representative at firstname.lastname@example.org for more information. Personal Data Categories include:
Identifier Information. Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers;
Personal Information. Name, address, or telephone number; and
Internet or Other Similar Network Activity Information. Search history, or information on User interactions with the Sites or Services.
You are responsible for the accuracy of the information you provide to the EXCHANGE. The EXCHANGE will use reasonable efforts to maintain the accuracy and integrity of such information and update it, as appropriate. The EXCHANGE will not maintain data any longer than necessary for the purposes stated without your consent unless legally required.
End-User Personal Data
As part of using the EXCHANGE, you may enable access to an end-user (as governed by the terms of your Services Agreement). The EXCHANGE collects personal data on behalf of our customers in order to provide services and has no direct relationship with an end-users whose Personal Data may be processed in connection with the provision of those services. You are solely responsible for establishing policies for and ensuring compliance with applicable privacy laws relating to the collection of personal data from an end-user. For a description of the respective standard obligations of users and the EXCHANGE set forth in your Services Agreement, please refer to that agreement.
The EXCHANGE collects log files, domain names, and IP addresses of users for statistical purposes, to measure use, to improve the content or responsiveness of the Sites, or to customize the content or layout of the Site for individual Users. The EXCHANGE also may aggregate this information to identify traffic patterns for the Sites. This data helps the EXCHANGE understand how Users consume information on the Site and interact with the Services with the ultimate goal of building an experience that improves the EXCHANGE’s processes and priorities in accordance with User needs. Access to this data is restricted to those who administer the EXCHANGE’s network and Sites. The EXCHANGE may use and disclose this data to third parties only in connection with monitoring our networks for security purposes, in response to legal process or law enforcement inquiries, to control any abuses of the Sites, or to address identified violations of any contractual provision entered into between you and the EXCHANGE.
In addition, most web browsers contain cookies, but also provide controls that allow you to block or delete them. You have the ability to accept or decline cookies from the Sites at any time by modifying the settings in your web browser. Certain Site and Service features require cookies to function. Please be aware that if you choose to block cookies, you may not be able to access or use those features and preferences that are dependent on cookies.
Purpose of Personal Data Processing
The EXCHANGE’s legal basis for collecting and using Personal Data will depend on the Personal Data concerned and the specific context in which the EXCHANGE collects it.
However, the EXCHANGE will normally collect Personal Data with your consent, to perform a contract (for example, when providing Services), or where the processing is in the EXCHANGE’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, Ratio EXCHANGE may also have a legal obligation to process Personal Data or may need to do so in order to exercise, establish, or defend legal claims.
If the EXCHANGE asks you to provide Personal Data to comply with a legal requirement or to perform a contract, the EXCHANGE will make this clear at the relevant time and advise whether the provision of Personal Data is mandatory or not (as well as the possible consequences, if any, if you do not provide that Personal Data).
Confidentiality and Security of Personal Data
Security is one of the EXCHANGE’s highest priorities. The EXCHANGE takes commercially reasonable and appropriate steps to protect Personal Data transmitted from you to the Sites and in connection with the Services and to protect such data from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no internet transmission is ever 100% secure or error-free. In particular, email may not be secure and therefore special care should be taken when deciding what information is sent to the EXCHANGE via email. Where you use passwords, ID numbers, or other special access features, it is your responsibility to safeguard them.
The EXCHANGE makes commercially reasonable efforts to reduce the risk of data breaches and have dedicated controls and procedures in place for such situations, along with the procedures to make notifications to the relevant supervisory authorities and data subjects (where applicable).
Disclose/Onward Transfers of Personal Data
Any Personal Data provided to the EXCHANGE will be used for the EXCHANGE’s business purposes only and only disclosed on a need-to-know basis or as required by law. The EXCHANGE does not provide any third party provider with name or email information. When the EXCHANGE provides Personal Data to third parties used to deliver or support specific Services to you, our agreements with these third parties do not permit them to use Personal Data outside the scope of fulfilling those Services nor allow them to further disclose your Personal Data. You should consult your Services Agreement for information regarding disclosures and transfers relevant to the Services.
The EXCHANGE’s partners are independent third parties that are otherwise not affiliated with the EXCHANGE. Any relationship you elect to enter into with a partner for additional products and services is directly between you and that third party.
User Rights to Personal Data
Marketing, Selling, or Disclosing Personal Data
The EXCHANGE does not market or sell Personal Data to third-parties. Any provision or disclosure of Personal Data by the EXCHANGE will be governed by the EXCHANGE Services Agreement and applicable federal, state, local and international law, regulation, and policy.
For more information or other security and compliance activities please contact EXCHANGE support. The EXCHANGE acknowledges that individuals may have certain rights to their Personal Data under applicable Privacy Laws. Please be aware that there may be circumstances in which additional legal requirements may prohibit or narrow the EXCHANGE’s ability to address individual requests. If you would like more information regarding the EXCHANGE’s privacy practices, please email us at email@example.com.