Electables Privacy Policy

Last Updated: June 1, 2022.

Numero Inc. and its affiliates (“Numero,” “we,” “our,” and/or “us”) value the privacy of individuals who use our Electables website and related services (collectively, our “Platform”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from or about individuals who use our Platform (“Users”) to purchase “NFTs” from political campaigns and nonprofit organizations. For the purposes of this Privacy Policy, “NFT” means a non-fungible token or similar digital item implemented on a blockchain (such as the Flow blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data. This Privacy Policy applies only to Users on our Platform; the privacy policy for our website numero.ai and its related services (including for individuals interacting with the Electables Platform on behalf of political campaigns and nonprofit organizations) can be found at https://secure.numero.ai/privacy. By using our Platform, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Platform is also subject to our Terms of Service (electables.com/terms).

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us.

Registration and Profile Information. If you sign up for an account, sign up for notifications or updates, or participate in our surveys, we ask you for your name, email address, address, phone number, and any other information we collect.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Success Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Platform.

Payment Information. If you make a purchase through our Platform, a third-party service provider that handles payments for us will receive your payment card information.

B. Information We Collect When You Use Our Platform.

Location Information. When you use our Platform, we may infer your general location information (for example, your internet protocol (IP) address may indicate your more general geographic region).

Device Information. We receive information about the device and software you use to access our Platform, including IP address, web browser type, and operating system.

Usage Information. To help us understand how you use our Platform and to help us improve it, we automatically receive information about your interactions with our Platform, like the pages or other content you view, the searches you conduct, purchases you make, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Platform.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Platform, you may not be able to utilize the features of our Platform to their fullest potential.

Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.

C. Information We Receive from Third Parties.

Campaigns and Data Partners. We may receive additional information about you from third parties such as political campaigns and data or marketing partners and combine it with other information we have about you. 

Other Users. We may receive information about you from other Users, such as when a User sends you a referral using our Platform.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect:

  • To provide, maintain, improve, and enhance our Platform;
  • To personalize your experience on our Platform such as by providing tailored content and recommendations;
  • To understand and analyze how you use our Platform and develop new products, services, features, and functionality;
  • To communicate with you, provide you with updates and other information relating to our Platform, provide information that you request, respond to comments and questions, and otherwise provide user support;
  • To facilitate the connection of third-party services or applications;
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you;
  • To generate anonymized, aggregate data containing only de-identified, non-personal information and use it for any lawful purpose;
  • To send you text messages;
  • To facilitate transactions and payments;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • For compliance purposes, including enforcing our TOS or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • For other purposes for which we provide specific notice at the time the information is collected.

HOW WE SHARE THE INFORMATION WE COLLECT

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Platform.

User Content.  The collections and donations you make on our Platform will be displayed on our Platform and viewable by other Users by default. For example, your name, NFT purchase, NFT purchase amount, and the campaign from which you purchased the NFT may be visible to other Users on our Platform. If you join our Platform via a referral link, then the referring user will be informed when you join and make a purchase. Although this content is public by default, below in the “Your Preferences” section of this Privacy Policy, we describe the controls that you can use, along with other relevant settings associated with your account, to limit the sharing of certain information. We are not responsible for other Users’ use of available information, so you should carefully consider whether and what to keep public.

Third-Party App Integrations. If you connect a third-party application to our Platform, we may share information, such as donor information, with that third party.

Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Platform.

Campaign finance law requires that we send your name, address, occupation, and employer information along with details of your contribution to the recipient of your contribution. Each candidate or committee receiving your contributions may report this information in its reports to the Federal Election Commission (FEC) or the relevant respective state or local agency. FEC reports containing this information are publicly available from the FEC website. State reports are typically available through the state agency designated to oversee campaigns and elections. Numero does not publicly report your personal information in connection with your contribution.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

YOUR CHOICES

Sharing Preferences. We provide you with settings to allow you to set your sharing preferences for your profile and purchases on our Platform. Certain information may always be publicly available to others, and other information is made publicly available to others by default. To change whether certain information is publicly viewable, you can adjust the settings in your account. Even if you choose to make your blockchain wallet or NFT purchases not publicly viewable on our Platform, there will still be a public record of your NFT purchase on the Flow blockchain.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with information we collect, some features of our Platform may not work as intended.

THIRD PARTIES

Our Platform may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

SECURITY

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Platform is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@electables.com.

INTERNATIONAL VISITORS

Our Platform is hosted in the United States and intended for visitors located within the United States. If you choose to use our Platform from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Platform. By providing any information, including personal information, on or to our Platform, you consent to such transfer, storage, and processing.

UPDATE YOUR INFORMATION

You can update your account and profile information through your profile settings. If you would like to close your account, please notify us at support@electables.com.

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through our Platform, we will notify you through our Platform, by email, or other communication.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@electables.com or write to us at:

Numero, Inc.

200 Spectrum Center Drive, Suite 300

Irvine, CA 92618