Privacy Policy

Last Updated: 15 Dec. 2018

Kryptium is a distributed application that can be deployed and executed on Ethereum and Ethereum-compatible networks, using specially-developed programs (each, a “Smart Contract”) to enable users to place bets, or administer and settle other users’ bets, or provide data services regarding future, on-going or past events of any kind. The stakes of bets on any deployed instance of Kryptium are in fungible tokens (hereinafter “cryptocurrency”) issued by servers of the network which was used to deploy the Kryptium instance. Using the Kryptium desktop application (hereinafter the “App”), users can easily access the functionality and information of Smart Contracts and, in the near future, deploy and manage their own instances of any Smart Contract. A description of Kryptium as well as links for downloading the Kryptium App and the source code of Kryptium Smart Contracts are available on the website https://kryptium.io (hereinafter the “Site”). The Smart Contracts and the App are collectively referred to in these Terms as the “Platform”. The Platform and the Site were created and are maintained by Kryptium Team (“we”, or “us”).

Kryptium Team is committed to protecting and respecting your privacy. This Privacy Policy (this “Policy”) sets out how we collect and process personal information about you when you visit our Site, when you use our Platform, or when you otherwise do business or make contact with us.

1. TECHNOLOGY-RELATED CONSTRAINTS

Within the context of the Kryptium application, a “transaction” is any user action which uses the App or the Smart Contracts and results in registering information on the selected blockchain network. An indicative, non-exhaustive list of transactions includes upvoting or downvoting, opening a new bet, joining or matching a bet, settling a bet, deploying and configuring instances of any Smart Contract, registering an upcoming event, and registering the outcome of an event.

YOU SHOULD BE AWARE OF THE FACT THAT RECORDS OF ANY TRANSACTIONS, WHICH YOU DO VIA THE APP OR DIRECTLY USING THE SMART CONTRACTS, WILL BE PUBLICLY AVAILABLE. THESE RECORDS CANNOT BE DELETED OR ALTERED IN ANY WAY.

This will happen because Ethereum and Ethereum-compatible networks maintain, by design, secure public ledgers (“blockchains”) that keep track of all transactions between 2 electronic wallet addresses or between an electronic wallet address and the address of an Ethereum program, such as Kryptium Smart Contracts. All records of transactions become eventually immutable due the security architecture of blockchains.

IF YOU DISAGREE WITH HAVING RECORDS OF YOUR TRANSACTIONS PUBLICLY AVAILABLE ON A BLOCKCHAIN NETWORK THEN YOU SHOULD NOT USE THE PLATFORM.

2. WHAT INFORMATION WE COLLECT

A. From the Site

Kryptium Team collects data to enable us to provide you with the best experiences on our website and our Platform. You might provide some of this data to us directly when you contact us via the Site for support, or contact us as a prospective user, vendor, supplier, partner, or consultant. These data might include your first name, last name, email address, physical address and telephone number.

We get some of your data by recording how you interact with the Site. We have implemented this process using Google Analytics, a tracking service provided by Google LLC, a company registered in California, U.S.A. The types of personal data collected by Google Analytics are described at the URL https://privacy.google.com/businesses/adsservices/. Regarding IP addresses in particular, we have configured the service to collect anonymised IP address information.

The hosting provider of our Site, Bluehost Inc., a subsidiary of The Endurance International Group, Inc. which is registered in Massachusetts, U.S.A., automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

These data will not be combined with data from other sources.

B. From the App

We don’t collect any personal data using the App.

C. From Ethereum and Ethereum-compatible networks

Kryptium Team collects, from the blockchain networks, publicly available information about the transactions you executed using the Platform. This information includes your electronic wallet address, the type of transaction you performed and the various parameters of the transaction. These data cannot be categorised as personal data since they are anonymous by default.

D. About your choices

You have choices about the data we collect. When you are asked to provide personal data, you may decline. In particular:

  • You may disallow Google Analytics tracking on the Site by disabling cookies via your browser’s privacy settings.
  • When you contact us directly, you may not provide all information that we might request from you. However, in case of important missing information, we might not be able to support you or proceed in further discussions about the subject of your interest.

3. HOW WE USE YOUR INFORMATION

A. Data from the Site

  • Data from the contact form or other communication with Kryptium Team: We use this information to respond to your support requests or to communicate with you about the issue that you contacted us for. We do not share this information with any third party without your permission, and we do not use it for marketing purposes, unless we have got your consent to do so.
  • Tracking data: We have legitimate interest in processing these data using Google Analytics, to produce analytics that help us understand how our users navigate and use our Site, so as to continuously improve it.
  • Server log files: We and our partner Bluehost Inc. have legitimate interest in processing these data in order to optimise performance and safeguard the security of our Site.

B. Data from Ethereum and Ethereum-compatible networks

  • Anonymous data from your betting activity: We have legitimate interest in processing these data in order to produce analytics that help us understand how our users use the Platform and to which extend. This insight is importance for further optimization of the Platform and also supports our product and business development activities.
  • Anonymous data regarding the deployment and maintenance of your Smart Contract instances. We have legitimate interest in processing these data in order to produce analytics that help us understand the current status and growth momentum of Kryptium’s betting ecosystem. This insight is importance for further optimization of the Platform and also supports our business development activities.

4. HOW WE PROTECT YOUR INFORMATION

In accordance with the applicable regulation, Kryptium Team shall take all necessary measures to process your information in a secure and confidential manner.

In particular, Kryptium Team shall implement the technical and organizational measures that will guarantee the security and confidentiality of the data collected and processed, in order to prevent them from being distorted, damaged or communicated to unauthorized third parties, by ensuring a level of security that is appropriate to the risks linked to the processing and to the nature of the data, taking into consideration the technical level and cost of such implementation.

Kryptium Team may not however guarantee the confidentiality of the personal data rendered public by you.

The App or the Site may include links to third-party websites or external sources. You acknowledge that the Policy only applies to the use of the App and the Site, and does not in any way cover the data collected and/or processed by the third-party websites or external sources to which the App may link. Consequently, Kryptium Team cannot be held liable for the personal data collection and processing practices of these websites or external sources, which are governed, as the case may be, by the personal data policies that are specific to each of these websites or external sources.

5. COOKIES AND OTHER TRACKERS

A tracker is a cookie, a beacon, a tag, an invisible pixel, or any other system capable of storing and/or collecting information relating to navigation on the user’s terminal (computer, tablet, etc.) and/or their activity. On our Site, cookies are used by the Google Analytics tracking service.

You can enable or disable cookies via your browser’s privacy settings.

6. DISCLOSURE OF INFORMATION TO OUTSIDE PARTIES

Personal data, collected or processed during the use of the Site by users, are sent to the approved and authorized members of Kryptium Team who, due to their role, need to have access to such information for the purposes of processing described above.

Kryptium Team may also communicate information related to its users, including personal data, to the administrative or judicial authorities, in particular in the context of requisition.

7. HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA

Kryptium Team recognizes that your privacy is very important and that users of our Platform and Site have a number of rights in relation to how we process their personal data. These include:

  • The right to access their data,
  • The right to correct their data,
  • The right to object to the collection and processing of their data,
  • The right to delete their data,
  • The right to limit the collection and processing of their data,
  • The right to portability of their data.

You may exercise your rights by sending a request by email to the address privacy@kryptium.com.

The User is informed that the exercise of certain rights, in particular objection and deletion, may restrict or prevent communication with Kryptium Team.

Kryptium Team reserves the right to verify the User’s identity.

8. CHILDREN

We do not knowingly collect, maintain, or use personal information, as defined by the US Federal Trade Commission’s Children’s Online Privacy Protection Act Rule, from children under 13 years of age, and no part of the Platform or the Site is directed to children under the age of 13.

If you are located in the European Economic Area (hereinafter “EEA”), we do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of the Platform or the Site is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, then you may alert us at privacy@kryptium.com. If we learn that we have collected any personal information from children under 13 (or 16 in the EEA), then we will promptly take steps to delete such information.

9. CROSS-BORDER DATA TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

You are hereby informed that your personal data may be transferred within the Kryptium Team to a country other than your country of residence and in particular outside of the European Union. The transfer of personal data is made in accordance with applicable law.

You are also informed that your personal data may be transferred to service providers, sub-contractors and partners located outside of the European Union. Prior to the transfer, and in accordance with applicable law, Kryptium Team shall carry out the necessary requirements to obtain the necessary guarantees for the security of such transfers, in the countries that do not have an adequate level of protection, such as contractual clauses.

10. DATA RETENTION

We take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.

When determining the retention period (no longer than 24 months), we take into account various criteria, such as the type of services or products requested by or provided to you, the nature and length of our relationship with you, the impact on the services or products we provide to you, if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

11. CHANGES TO OUR PRIVACY POLICY

We will update this privacy statement when necessary to reflect customer feedback and changes to our products, services or operational procedures. When we post changes to this statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or in how Kryptium Team will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by sending you a notification directly. We encourage you to periodically review this privacy statement to learn how Kryptium Team is protecting your information.

12. HOW TO CONTACT US

If you have a privacy concern, complaint, or a question for the Data Protection Coordinator of Kryptium Team, please contact us by sending us an email at privacy@kryptium.io. We will respond to questions or concerns within 30 days.

If you have a technical or support question, please send us an email at info@kryptium.io.

Unless otherwise stated, Kryptium Team is a data controller for personal data we collect through the Site subject to this statement.