PRIVACY POLICY

Updated July 5th, 2022

This Privacy Policy describes how Solydaria, Inc. (“we,” “us,” “our,” “Company”), the owner and operator of the SOLYD Platform (“SOLYD Platform”) collects, uses, shares, and protects information in connection with the Company websites, applications (including our Shopify application) and other related properties, and any related services that refer or link to this Privacy Policy (“Services”).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time-to-time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Collection of Information

We offer the SOLYD Platform which is a cooperative cashback platform for merchants (“Merchants”) and shoppers (“Shoppers”), that allows Merchants to offer Shoppers promotions through games designed by Merchants (each a “SOLYD Promotion Game” or “Game”), and that allows Shoppers to earn cashback in cash through their Venmo account, or in Bitcoin, on purchases that are part of a Merchant’s active SOLYD Promotion Game completed through our websites, applications (including our Shopify application) and other related properties (collectively, the “Solydaria Properties”).

We collect, process, and use your information when you:

- Access our Services, as a Merchant through our Shopify application(s), or as a Shopper, earning cashback through participation in a Game;
- Connect to our Services using third-party accounts, such as your email, social media, or payment account(s)
- Contact us for support


Further, we and our service providers automatically collect certain information about you through:

- Interaction with our Services
- Monitoring and analyzing trends, usage, and activities

The types of information you provide may include Personal Information. “Personal Information” means information that can be used to identify you (whether alone or in combination with other information). The Personal Information you may provide to us from our website or our Shopify Application, may include:

- Email address
- Phone number
- Blockchain address
- The digital receipt of the product or service purchased by any Shopper from any Merchant with minimal personally identifiable information
- Venmo account information (only when transferring cashback to a Venmo account)

We may also collect certain non-personally identifiable information about you and your desktop or laptop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings. We also may use this information in the aggregate to analyze usage of the Site Offerings.

2. Legal Basis for Processing

We have the legal right to use your Personal Information in the ways described in this Privacy Policy based on your consent, or on the need to use the Personal Information to provide you with goods or services that you request, or for the legitimate purposes of furthering our existing relationship with you or preventing fraud. Accordingly, you have a contractual rather than a statutory obligation to provide such information. If you do not provide such information, you may be unable to use our Services and we may be unable to provide any goods or services that you request.

3. Use of Information We Collect

We may use information about you in the following ways.

3.1 Manage Your Account

If you provide us Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) deliver you Bitcoin or other payments, and identify opportunities for offers; (iii) send you technical notices, updates, security alerts, and administrative messages; (iv) provide you member services regarding your account and reply to your questions, comments and requests; and (v) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.

3.2 Improve Our Services

We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our merchant partners to provide a better service in the future. This information collection will be in aggregate and not tied to any personally identifiable user specifically.

3.3 Provide You Marketing Information

On a per case basis, with your approval, Company partners may request to access your Personal Information to provide you special offers, discounts and similar opportunities. Company may send you newsletters, rewards, discounts, promotion codes, events and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 5 (Your Choices) below.

4. Sharing of Information

We may share the information we collect, including your Personal Information, with third parties only in the case of suspected fraud.

4.1 Providers and Business Partners

We do not sell your Personal Information and only share it with third parties to prevent fraud on our Services. 

4.2 Protection of Rights and Other Legal Purposes

We may share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to defend our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of us or any third party.

5. Your Choices

You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing communications from us by using the unsubscribe link on the footer of our marketing emails or by using the Contact Us option through the Services, or in the case of SMS replying "stop" to communications. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable.

6. Data Security and Retention

We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. The only data the Company collects is encrypted and stored using Blockchain technology and is the property of the user. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may anonymize and aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.

7. Promotional Communications

By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by: (i) following the instructions provided in those communications; or (ii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. There may be opportunities for you to share your personal information with the Company or its partners in order to receive compensation or benefits.  In these cases the Company may present you with the opportunity and you will have the choice to opt in or opt out of any participation in sharing you information. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.

8. Cookie Policy

We NEVER use Cookies.  Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allo third parties to recognize your browser or mobile device and transfer information about you and your use of services.

9. Analytics, Targeting, Tracking

We, and third parties with which we partner, may track actions that happen on our services, for example, how many visitors log in, or how many times a button gets pushed, or how much time is spent visiting a page, however, this analytics data is blind and never tied to a user’s identity. We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms.  Some third-party service providers that we engage (including third-party retailers and advertisers) may also place their own cookies on your browser. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties. 

10. Third-Party Data

The Services contain hyperlinks to websites of merchants and retailers and other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.

11. Changes to This Privacy Policy

This Privacy Policy is current as of the effective date set forth above. Company reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).

12. Children

Our Services are not intended for children under 13 years of age, and no one under age 13 may provide any information to the Services. We do not knowingly collect personal information from children under the age of 13. If you are under age 13, do not use or provide any information to the Services, make any purchases through the Services, use any of the interactive or public comment features of the Services, or provide any information about yourself to us, including your name, phone number, email address or any screen name or username you may use. If you believe we might have any information from or about a child under age 13, please contact us at TOS@solydaria.co.

13. Rights Applicable to Certain Users

13.1 EU Users 

Solydaria is considered the “data controller” for its website as defined within Regulation (EU) 2016/679 (General Data Protection Regulation)(“GDPR”).  You, the User, are the “data subject.” The following agreement applies solely to personal data held within the website at www.solyd.xyz and the associated mobile application (collectively, the “Site“), or Solydaria’s internal records relating to the Site.

If you are visiting from the European Union (“EU”) or other regions with laws governing data collection and use that may differ from United States law, please note that you may be transferring your Personal Information to the Company in the United States and in other countries around the world for the purposes described under this Privacy Policy. Please note that the EU has determined that the laws of the United States do not provide adequate protection for your Personal Information. Accordingly, we are transferring your Personal Information from the EU to the United States based on your consent, or our need to use your Personal Information to provide goods or services that you order, and subject to the following additional protections:

- If we intend to disclose your Personal Information to any third party that will carry out processing on our behalf, we will enter into a contract with that third party that provides that your Personal Information may be processed only for limited and specified purposes consistent with the consent that you have provided to us, and that the third party must provide the same level of protection for your Personal Information that we are obligated to provide under this Policy while it is processing your Personal Information.

- If your Personal Information is being processed by automated means, you have the right to obtain a copy of your provided Personal Information, together with certain additional Personal Information that we have generated as a result of your use of our services, in a structured and commonly used and machine-readable format, and to transfer such Personal Information to another service provider. Upon your request, we will transfer that Personal Information directly to another service provider if it is feasible for us to do so

- If we are processing your Personal Information based on your consent, you may withdraw that consent at any time.

You may restrict our use of your Personal Information, by sending us an email stating your request to TOS@solydaria.co, if you have contested the accuracy of that information, or if the processing is unlawful or you need the information to establish, exercise or defend a legal claim. We will then store your Personal Information and process it only with your consent, or to establish, exercise or defend a legal claim or to protect the rights of others. The restriction with respect to information claimed to be inaccurate would end if we verify the accuracy of that contested information.Upon our receipt of your request by email at TOS@solydaria.co and our verification of your identity, we will advise you whether or not we are processing Personal Information concerning you and, if so, we will provide you with a copy of your Personal Information being processed and certain information about the nature and purposes of the processing. If your Personal Information is used for automated decision-making, we will provide you with information on the logic being used and the types of decisions being made. You may correct any such Personal Information that is inaccurate or incomplete.

Upon your request, we will erase any of your Personal Information that is no longer needed for the purpose for which it was collected, or that is being used for direct marketing purposes, or if our use is based on your consent and you withdraw that consent.

Our Services may be used by children in the EU between the ages of 13 and 16 only with parental consent. If we learn we have collected or received Personal Information from a child in the EU under the age of 16 without verification of parental consent, we will delete that information.

If we are using your Personal Information on the basis of your consent, and we change our Privacy Policy to permit any use or disclosure of your Personal Information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your Personal Information.

If you have a complaint about our compliance with this Policy, you may contact us at TOS@solydaria.co. If you are not satisfied with our response, you will have the right to lodge a complaint with the Supervisory authority in your country of residence in the EU.

If you are not subject to EU law, the rights in this section 13.1 do not apply to you.

13.2 California Residents 

If you are a California resident, you may (i) obtain certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes, and/or (ii) at any time opt-out of receiving promotional communications from us and/or request that we discontinue providing any of your Personal Information to unaffiliated third parties, in each case by sending an email to TOS@solydaria.co. Please note that if you decide to opt-out of receiving promotional information or request that we discontinue providing your Personal Information, your change in preference will only affect future contacts; if the information already has been provided to third parties, they may continue to use it.

Personal Information does not include:

- Publicly available information from government records.

- De-identified or aggregated user information.

- Information excluded from the scope of the California Consumer Privacy Act, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

14. Contact Us

If you have any questions regarding this Privacy Policy, please feel free to contact us by email at TOS@solydaria.co or by mail at Solydaria, Inc., 41 Flatbush Ave, FL 1, Brooklyn NY 11217.