Last Updated: March 1, 2019
For any and all privacy-related questions, please contact us at firstname.lastname@example.org.
This Policy describes how we collect, use, process, and disclose your information, including personal information. This Policy applies when you do any of the following:
(a) access the Symetria Platform, which includes Symetria’s website (symetria.io) and hosted wallet and cryptocurrency conversion services, as well as other products, content, associated websites, and applications,
(b) create a Symetria account,
(c) upload content to the Symetria Platform, and
(d) participating in transactions on the Symetria Platform.
Personal Information is information about an identifiable individual.
1. INFORMATION SYMETRIA COLLECTS
1.1 Necessary Information.
The information listed below is requested and collected when you set up an account and during your time as an account-holder. This information is necessary in order for us to offer you the services in accordance with our Terms of Service and, in some cases, applicable law.
(a) Account Related. When you sign up for a Symetria account, we request certain information such as your email or phone number.
(b) Profile Related. To use certain features of the Symetria Platform, we may ask you to provide additional information, which may include your name, address, email or phone number.
(c) Identity Verification Related. Where required by our regulatory or legal obligations, we may collect identity verification information (such as images of your government issued ID or other authentication information).
(d) Communication Related. When you communicate with Symetria or use the Symetria Platform to communicate with other Users, we collect information about your communication and any information you choose to provide. We will track this information to enhance our service.
(e) Transaction Related. When you engage in transactions or other account activity, we will track information such as the number of individual transactions posted, type of account activity, and any specific information we’re required to track to comply with applicable laws.
1.2 Volunteered Information. You may choose to provide us with additional personal information to obtain a better User experience. For example, you may choose to upload a profile photo. This additional information will be processed based on your consent and you will be able to decide whether it will be publicly available.
You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Symetria account, respond to surveys, or use other features of the Symetria Platform.
1.3 Automatically Collected Information.
We may collect information that is automatically sent to us by your web browser or your device which runs our applications, for example your domain name and your numerical IP address. We may also collect other information about your activity on the Platform, such as the type of browser you use and the content you view on the Platform.
We use this information to improve our understanding of how Users use the Symetria Platform, and to improve the Symetria Platform. Please refer to your browser’s or device’s instructions to learn how you may be able to control the flow of this information.
2. HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to:
(a) provide, improve and develop the Symetria Platform,
(b) create and maintain a trusted and safer environment and comply with our legal obligations (such as know-your-client rules), and
(c) improve our ability to provide our services or to tailor our services to you.
These reasons for using, storing and processing information are described in more detail below.
2.1 Provide, Improve, and Develop the Symetria Platform.
By using, storing and processing the information we collect, we can:
(a) enable your access and use of the Symetria Platform,
(b) enable you to communicate with other Users,
(c) operate and optimize the Symetria Platform and experience by the performance of analytics and conducting research (for example),
(d) provide customer service,
(e) send you service or support messages, updates, security alerts, and account notifications,
(f) personalize and customize your experience, and
(g) facilitate performance of our contracts with other Users and third parties, including fee payment obligations in those contracts.
We process this information given our legitimate interest in improving the Symetria Platform and our Users’ experience with it.
2.2 Security Measures
By using, storing and processing the information we collect we can implement security measures such as (among others) fraud detection and prevention, identify verification, and risk assessments.
We may also use it to comply with legal obligations (know-your-client rules, for example), to resolve disputes and to enforce our Terms of service and other policies.
We process this information given our legitimate interest in protecting the Symetria Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
By using, storing and processing the information we collect we can:
(a) send you marketing, advertising, and other information that may be of interest to you, and
(b) personalize, measure, and improve our advertising.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Symetria account.
3. SHARING & DISCLOSURE
3.1 With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you attempt to engage in a transaction or other account activity involving another User.
3.2 Required Disclosure.
Symetria may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Symetria, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our Users to legal liability, (iv) to enforce and administer our Terms of Service (v) to protect the rights, property or personal safety of Symetria, its employees, its Users, or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Symetria Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we will notify Users about legal requests unless: (i) doing so is prohibited by applicable law, or (ii) we believe that providing notice would create a risk of injury or bodily harm to an individual or group or create or increase a risk of fraud upon Symetria’s property, its Users and the Symetria Platform. In such cases, we will attempt to notify Users about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.3 Aggregated Data.
We may also share aggregated information (information about our Users that we combine so that it no longer identifies or references an individual User) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. OTHER IMPORTANT INFORMATION
4.1 Analyzing your Communications.
We may review, scan, or analyze your communications with us on the Symetria Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes.
Occasionally we may need to manually review some communications or account activity, in connection with fraud investigations and customer support, for example, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on Symetria's legitimate interest in ensuring compliance with applicable laws and our Terms of Service, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5. THIRD PARTY PARTNERS & INTEGRATIONS
6. YOUR RIGHTS
6.1 Managing Your Information.
You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.
You are solely responsible for protecting and keeping private your unique private key.
6.2 Rectification of Inaccurate or Incomplete Information, Data Access.
You have a right to access to your personal information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below.
6.3 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Symetria Platform to you, you can request that we erase your personal information and close your Symetria account, subject to applicable laws. Please note that if you request the erasure of your personal information:
(a) We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
(b) We may retain and use your personal information to the extent necessary to comply with our legal obligations.
(c) Because we maintain the Symetria Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period.
7. SECURITY AND RISKS
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Symetria account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Symetria account, please contact us following the instructions in the Contact Us section below.
Notwithstanding Symetria’s robust security and privacy measures, we cannot eliminate completely the risk of a security breach. A breach that discloses information you provide to us, like your personal or financial information, may result in such harm as financial loss or identity theft. If you are uncomfortable with these residual risks, please do not use the Symetria Platform.
In the event of a breach, we will notify you and advise you of the steps we are taking to address the breach.
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