1. VOICE AND DATA PRIVACY
In addition to the personal data you make publicly accessible on Voice, we collect certain personal data which is not generally publicly accessible. As explained below, we only process your non-publicly accessible personal data to the extent required for platform administration and certain other limited uses which we believe are necessary.
2. INFORMATION THAT IS PUBLICLY ACCESSIBLE
It is important to remember that most information on Voice is accessible to all, whether the person accessing the information is a registered user or a visitor to Voice.
Information which is publicly accessible includes the following:
- Certain information you give us when you sign-up for an account. This includes:
- Your full name.
- The photo you provide to us to use as your profile photo.
- Your place of residence.
- Information which you or others post on Voice. This may be text, images, videos or other material. This includes:
- Your posts.
- Your comments on your own posts and on other users’ posts.
- Responses to comments.
- Information about actions you take on Voice. This includes:
- The content that you engage with (for example, by liking or using Voice It).
- The features that you use.
- The actions you take in relation to content (for example, sharing or commenting).
- The actions you take in relation to other users (for example, following or unfollowing).
- The actions you take in relation to tokens (for example, using Voice It).
One key part of the operation of Voice is the publicly accessible blockchain maintained by us that we call the Voice Chain. Records of all posts made by users on Voice, as well as records of all actions taken by users on Voice, are published on the Voice Chain (but note that only a cryptographic hash of the content of posts is recorded on the Voice Chain – see next paragraph). The Voice Chain forms a permanent, uneditable and auditable catalogue of all posts and actions which will persist even if we delete other information we hold about you. The Voice Chain may also be accessible by persons who are not directly using or visiting Voice – for example, if someone carries out a search on a search engine.
The Voice Chain does not include a clear copy of the content ofposts and comments. Anyone looking directly at the Voice Chain will instead see a “hash”, which is a shortened cryptographic representation of this content. We can use the hash to validate posts. Actions, such as when you Like another user’s post, are recorded on the Voice Chain in a clear way, so that everyone can understand what actions have been taken.
Please remember that it is possible for third parties to take information which is publicly accessible on Voice and use it without our knowledge. This is outside of our control and any such use is beyond the remit of this Privacy Notice. Depending on your place of residence, such third parties may be obliged to notify you if they have obtained your personal data in this way.
3. INFORMATION THAT IS NOT PUBLICLY ACCESSIBLE
We process certain information about you which is not publicly accessible:
- Certain information that we collect as part of the sign-up process. This includes:
- Your date of birth.
- Your email address.
- Your residential address.
- Your phone number.
- Other identifying or contact information you provide to us.
- Information you otherwise provide to us. This includes:
- Information you provide when registering your interest in Voice.
- Updates you provide within the platform or via Help Center.
- Information you provide in any emails or other correspondence you send to us.
- Information you provide in submitting any question or comment or completing any survey, questionnaire or other form.
- Information that our platform and other systems collect about you.
- When you use or visit Voice, it will automatically collect some information about you and your visit, including Internet and network activity such as the Internet Protocol (IP) address (which may provide information about your location) used to connect your device to the Internet and some other information such as your browser type and version and the pages that you visit.
- We use third-party service providers to run data analytics. Voice may also download “cookies” to your device or place cookies onto your browser. For more information about these service providers and the nature of the services they provide and a description of the cookies we use, please refer to our separate Cookie Notice.
- If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems may record details of those conversations, sometimes including their content, which may include visual and audio information about you.
- Information that we collect from any identity and address verification third-party service provider.
- This is information which you provide as part of the identity verification process when you sign-up. It will include copies of the documents you submit to our service providers (for example, your passport or other ID document) and information our service providers derive from those documents for identity verification purposes.
- Other information.
- We may also collect certain information from other sources. For example, we sometimes collect information from third-party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
- Note that such information may also be processed by our service providers (see Section 5 below).
4. HOW WE MAY USE YOUR INFORMATION AND BASIS OF PROCESSING
We only process your information for legitimate business purposes, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances, we may also be required by law or regulation to disclose or otherwise process your information.
Pursuing our legitimate business purposes includes using information in the following ways:
- To operate, administer, and improve Voice and other aspects of the way in which we conduct our operations.
- To operate and administer user accounts, including carrying out account set-up and account recovery. This includes processing data for identity verification purposes and in order to confirm that the same user does not have more than one account.
- To communicate with you in accordance with your notification preferences, for example, to notify you when another user follows you, or when another user comments on your post.
- To otherwise communicate with you about your Voice account, if you have one, and Voice in general. For example to respond to you when you contact us or to notify you about relevant policies and/or terms and conditions.
- To protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes.
- To comply with our legal and regulatory obligations and bring and defend legal claims, including possible disclosure to litigation counterparties or government bodies, to protect a person’s vital interests.
- To send you emails containing marketing information which we believe you will find relevant and interesting (subject to your consent where required).
- For the provision of data analytics services to third parties (subject to your consent where required). This will be based on information available on the Voice Chain relating to your interactions with the platform and other information about your use of Voice.
5. DISCLOSURE AND INTERNATIONAL TRANSFER OF YOUR INFORMATION
Where reasonably necessary for the various purposes set out above, we may disclose personal data about you:
- to other members of the Block.one group;
- to any service providers who host our websites, or other information technology systems, or otherwise hold or process your information on our behalf, under appropriate conditions of confidentiality and security;
- to a person who intends to or is taking over our business and assets, or relevant parts of them;
- to regulatory, prosecuting and other governmental agencies, courts or authorities or litigation counterparties, in any country or territory; and
- to comply with any applicable laws or regulations.
These disclosures may involve transferring your personal data overseas. If you are dealing with us within the European Economic Area (EEA) or the United Kingdom (UK), you should be aware that this may include transfers to countries outside the EEA / UK. Where required, when we transfer personal data to our affiliates or our service providers, we will ensure that our arrangements with them are governed by appropriate safeguards or agreements on terms approved for this purpose by the European Commission and / or the relevant authority in the UK (as the case may be).
6. RETENTION AND DELETION OF YOUR INFORMATION
We delete or anonymise the information that we hold about you when it is no longer required for the purposes described above, except to the extent otherwise required by law or regulation. That being said, as explained above, certain information will be retained permanently in hash form on the Voice Chain.
Further information about our record retention policies is available on request. Please contact us as set out below.
7. RIGHTS OF INDIVIDUALS IN CERTAIN PLACES
If you are located in certain places, you may have some or all of the following rights:
- A right of access to the personal data that we hold about you, and to some related information, under applicable data protection law and regulation. We will provide you with one copy of your personal data free of charge, but we may charge you a fee to cover our administrative expenses if you request further copies of the same information.
- A right to require any inaccurate personal data that we hold about you to be corrected or deleted.
- A right to object to our use of your personal data for direct marketing purposes at any time.
- A right to object to our processing of some or all of your personal data (and require it to be deleted).
- A right to data portability, which means the right to receive your personal data in a structured, commonly used and machine-readable format.
- A right to define guidelines (general or specific) for the storage, erasure and communications of your personal data after your death.
If you wish to exercise any of these rights that apply to you, please contact us as set out below. When exercising any of these rights, you will have to prove your identity to our satisfaction so that we can be sure that they apply to you and to safeguard your information from unauthorized access by someone impersonating you.
We comply with any obligations imposed on us by applicable law or regulation in relation to any processing of your personal data. We also recognise any rights you may have under applicable law or regulation in relation to such processing. In some cases, where you do not have the benefit of a particular right, or we do not have to comply with a particular obligation, that another user has the benefit of, because of your place of residence, we may nevertheless (without obligation and in our sole discretion) grant you the benefit of such right or choose to fulfil such obligation, but are under no continuing obligation to do so.
You may also be able to lodge a complaint about our processing of your personal data with the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose, but we would invite you to attempt to resolve the issue with us first.
Where law or regulation requires us to provide you with a notice, or other explanation of the information about you that we collect and process (or similar), this Privacy Notice shall be understood as fulfilling our obligation to provide you with such notice or explanation.
8. Contact Us
We welcome questions, comments and requests regarding this Privacy Notice and our processing of personal data. Please be sure to review the Voice FAQ. Please use the following means to contact us:
- By mail to: 4001 Kennett Pike, Suite 302, Wilmington, Delaware 19807, United States
- By email to: email@example.com
- By phone at: +1 540 315 8111
If you are in the EEA, you may also contact our representative in the EEA. Please contact us:
- By mail to: Achieved Compliance Advocacy, Ltd., Attn: Ms. S. Ali re Voice, Princess House, Princess Way, Swansea, UK SA1 3LW
- By email to: firstname.lastname@example.org
Please also contact us using the method above if you have a disability and require this Privacy Notice in an alternate format.
9. CHANGES TO THIS PRIVACY NOTICE
Any changes we make to this Privacy Notice in the future will be made available on Voice and also available if you contact us as set out above. Please check back frequently to see any changes.
If you do not agree with any of the statements set out in this Privacy Notice, you should stop using Voice in any way.
Date of Last Update: February 14, 2020