Last Updated: April 26th, 2023
Welcome! This Privacy Notice explains how Stelo Labs, Inc. (“Stelo”, “Company”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites, stelolabs.com, stelo.com, or approvals.xyz (the “Site”) and application, and the related content, platform, services, products, and other functionality offered on or through our online services, (collectively, the “Services”). It does not address our privacy practices relating to Stelo employees and other personnel.
Our Collection of Personal Information
Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes, we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.
Blockchain participants: Please note that by virtue of the public nature of the blockchain, including the Ethereum Blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain securitized tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please review how privacy and transparency on the blockchain works.
Personal Information Collected from Individuals
We may collect the following personal information submitted to us by individuals through the Services:
- Contact Information, such as your email address and social media handle.
- Crypto Information, including the website that the crypto transaction originated from, your public blockchain address associated with your self-hosted crypto wallet, crypto wallet types, amounts of digital assets and account balances.
- Inquiry and Communications Information, including information provided in custom messages sent through the forms, to one of our email addresses, or via phone. This also includes information provided in order to subscribe to any of our newsletters or waitlist (such as email address).
- Survey Information, including any questions submitted through surveys or content of any testimonials.
- Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
- Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as installations, usage, and activity on our Services) and location data (such as general geographic location based on the log data we or our third-party providers collect).
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information.
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Data Collection and Online Advertising section of this Privacy Notice.
Personal Information from Third Parties
We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.
We may receive the same categories of personal information as described above from the following third parties:
- Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you engage in one of our communities hosted on third-party platforms, such as Discord and Telegram, we will be able to see any public communications made within that platform.
- Service Providers: Our service providers that perform services solely on our behalf, such as website and service operators, collect personal information and often share some or all of this information with us.
- Social Media: When an individual interacts with our Services through various social media networks, such as when someone logs in through a social network, or follows us on Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Third Parties Related to Employment Applications: If you apply for a job with Stelo, we may receive information from your current or past employers, recruiters, third-party social media platforms and other third parties we use to obtain information about job applicants.
- Information from Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. Such information may include contact information, social media account information, general location, domains, cryptocurrency wallet address and related information, NFT ownership information (e.g., account address, transfers of NFTs between accounts), the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information (including cryptocurrency and NFT assets), and interest-in-services information, employment-related information, and interest-in-services information. We may combine this information with the information we collect from an individual directly. We use this information to provide the Services, contact individuals, to process employment applications and job applicant screening, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.
Our Use of Personal Information
We use personal information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services;
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email and social media;
- Request individuals to complete surveys about our company, companies we partner with, and the Services;
- For marketing and advertising purposes, including to market to you or offer you through email, direct mail, and provide you with updates on products or services we think that you may be interested in;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Facilitate customer benefits and services, including customer support through our command center services;
- Identify and analyze how individuals use our Services;
- Conduct research and analytics on our customer and user base and our Services;
- Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process, if you are applying for employment.
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- For any other lawful purpose, or other purpose that you consent to or for which you provide your information.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
Our Disclosure of Personal Information
We disclose personal information in the following ways:
- Affiliates. We may share personal information with other companies owned or controlled by Stelo, and other companies owned by or under common ownership as Stelo, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Stelo Labs Users: Holdings and transactions associated with your crypto wallet address are publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public. Through the use of the Service, we display blockchain information and other data associated with the recipient transaction wallet.
- Business Partners: From time to time, we may share personal data with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to identify fraudulent digital wallet ids on their services.
- Survey Providers: We share personal information with third parties who assist us in delivering our surveys and processing the responses.
- Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, rewards or debit card management platforms, and administrative services.
- Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the section Third Party Data Collection and Online Advertising for more information.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.
Control Over Your Information
You may control your information in the following ways:
- Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
- Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances.
Children’s Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Links to Third-Party Websites or Services
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to email@example.com.