Privacy Policy

Pond's Privacy Policy

Effective as of November 20, 2023

We ("Pond Global Ltd," "we", “us” or "our") operate Pond, a AI model that analyses on-chain data, compress information for users to develop their understanding of the crypto market based on on-chain information. This Privacy Policy describes how Pond processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including Pond and our social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”).

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Profile data, such as the username and password that you may set to establish an online account on the Service, referral code, photograph or picture, links to your profiles on social networks, including X, fka Twitter (“X”), and your publicly available information on these social networks, interests, preferences, and any other information that you add to your account profile.

  • Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.

  • Transactional data, such as blockchain transaction history and other information associated with your linked cryptocurrency wallet, in order to purchase Keys on the Service. This also includes your Key purchases and trade history.

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was received and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords and other similar data.

  • Promotion data, including information you share when you enter a competition or promotion. Please note that if you participate in a contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These contests are voluntary. We recommend that you read the rules and other relevant information for each contest that you enter.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, public blockchains and ledgers, and other publicly available sources.

  • Data providers, such as information services and data licensors.

  • Partners, such marketing partners and event co-sponsors.

  • Service providers that provide services on our behalf or help us operate the Service or our business.

  • Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture, details of last log-in, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service, such as Google. This data may include your Google username, profile picture and other information associated with your Google account on that third-party service that is made available to us based on your account settings on that service. Our use and disclosure of information received from Google’s APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Third party services also encompass any virtual currency account services you link to the Services. This data may include your wallet address and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, and radio/network information (e.g., Wi-Fi, LTE, 3G).

  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, and access times and duration of access.

  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails).

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Tracking technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

  • Local storage technologies, like HTML5, which provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

  • provide the Service;

  • enable security features of the Service;

  • establish and maintain your user profile on the Service;

  • facilitate social features of the Service, such as providing chat and messaging functionality;

  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

  • communicate with you about events or contests in which you participate; and provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

  • understand your needs and interests;

  • personalize your experience with the Service and our Service-related communications; and remember your selections and preferences as you navigate webpage

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

Events, promotions and contests. We may use your personal information to:

  • administer promotions and contests;

  • communicate with you about promotions or contests in which you participate; and contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;

  • enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.

  • Functionality. To enhance the performance and functionality of our services.

  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent for use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, and website analytics).

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Pond, financing of Pond, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Pond as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your profile and other user-generated content data may be visible to other users of the Service. This information can be seen, collected, and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Other users may be able to view your profile information, certain transactional information related to your recent trades, and chats. Your profile, follower count, and other profile information may also be available to all users of the Service.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the British Virgin Islands and may use service providers that operate in other countries. Your personal information may be transferred to other locations where privacy laws may not be as protective as those in your state, province, or country.

Age restriction

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: support@pond.international

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