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Privacy Policy

PRIVACY POLICY

Effective date: Jan 1, 2021

We at AlternativeData.com and Tokenwatch.io know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. This Privacy Policy is to inform you of our policies and practices regarding the collection, protection, use, sharing, and disclosure of information we collect when you visit our websites, and of the choices you can make about the way your information is collected, used, and shared.

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of AlternativeData.com’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data. Please refer to our GDPR Privacy Notice for EU Residents for more details.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, including the following products and services:

• AlternativeData.com is an enterprise facing website-based data dashboard platform available at https://alternativedata.com/, which enables its subscribers to visualize market/industry trends and consumer/business insights.

Note that this Privacy Policy does not cover the practices of companies we don’t own or control, or people that we don’t manage.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at business@alternativedata.com.

Will AlternativeData.com ever change this Privacy Policy?
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the https://alternativedata.com, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used, unless this is prohibited by applicable laws or any contracts/policies to which we are bound, in which case, we’ll notify you and prompt you with the choices to either consent to or reject the updated Privacy Policy. If you reject the updated Privacy Policy, some features of the Services may not be available to you.

What Information does AlternativeData.com Collect?
Information You Provide to Us:

We receive and store any information (including Personal Data about you) you knowingly provide to us. For example, when you register for the Services, we ask you for information that enables us to provide the Services, and we may require you to provide certain information, such as contact information (e.g. your name, username, company name, position, password, and email address). Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you’ve provided us the means to do so. For example, we may send you promotional email offers about our Services or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by “unsubscribe” in the email, or sending an email to business@alternativedata.com to request. We may also use such data you provided to us to operate or improve the Service, to customize the Services for you.

When you create your AlternativeData.com account, and authenticate with a third-party service (like Linkedin, Facebook or Google) we may collect, store, and periodically update information associated with that third-party account, such as your name, profile picture and email address. We will never publish through your third-party account without your permission.

Information Collected Automatically:

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include, but not limited to, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested.

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Also, if you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

How will AlternativeData.com Use Any of the Personal Information it Receives?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• Provide support and assistance for the Services;
• Communicate with you about the Services;
• Contact you about Service announcements, updates or offers;
• Meet contract or legal obligations;
• Respond to user inquiries;
• Fulfill user requests;
• Comply with our legal or contractual obligations;
• Resolve disputes;
• Enforce our Terms of Service;

Will AlternativeData.com Share Any of the Personal Information it Receives?

We do not rent or sell your Personal Information in personally identifiable form to anyone, except as expressly provided below. We may share your Personal Information with third parties as described in this section:

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing AlternativeData.com to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

User Profiles and Submissions: Certain user profile information, such as your name, location, or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send comments or upload images through the Services and other users can contact you through comments other means allowed by the functionality of the Services.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of AlternativeData.com and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of AlternativeData.com, our employees, our users, or others.

Is Personal Information about me secure?

You must prevent unauthorized access to your email accounts associated with our Services and Personal Information by selecting and protecting your third party credentials, such password and/or other sign-on mechanism, appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your email accounts in the Services.

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Information and applicable processing activity. For example, all Personal Information is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption. All Personal Information stored on our Services is hosted on Amazon Web Services (AWS) and Microsoft Azure, which undergo various third-party independent audits on a regular basis, covering compliance controls for its data centers, infrastructure, and operations. This includes SOC 2 certification and ISO 27001 certification.
We endeavor to protect the privacy of your email accounts and other Personal Information we hold in our records by reasonable data security measures in the similar industry, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

How long does AlternativeData.com retain my Personal Information?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in an aggregated and anonymized form not in a way that would identify you personally. If you want to close your account, please send us a clear written request to business@alternativedata.com. Please refer to “What Choices do I have?” below for more information regarding how to delete your Personal Information.

What Personal Information can I access?

Through the settings provided by the Services, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

name
email address

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at business@alternativedata.com.

California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: business@alternativedata.com.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records.

Please note that uninstalling the AlternativeData.com application from your mobile device does not delete your Personal Information we hold in our records. If you want to disassociate your email accounts from our Services and delete the Personal Information, you should request such deletion by sending a clear written request to us at business@alternativedata.com. Some information may remain in our records after the deletion, but only in a way that would not identify you personally. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

International Users

AlternativeData.com and many of its service providers are based in the United States. If you use the Service, please be aware that your Personal Information will be transferred to, processed, and used in the United States and other countries where we and our service providers maintain data processing facilities. If you are located in the European Union, Switzerland or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including your personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and please refrain from using our Services. By using our Services, you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to business@alternativedata.com, and we will try to resolve your concerns.

GDPR PRIVACY NOTICE FOR EU RESIDENTS

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, the Company’s Privacy Policy (the “Privacy Policy”). If there are any conflicts between this GDPR Privacy Notice and the Company’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at business@alternativedata.com.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

• First and last name
• Email address
• User content, for example, comments, posts, or other feedback you submit publically (which can include Personal Data if you include Personal Data in such content)
Information we receive from third party sources: Some third parties such as Google, Facebook, Linkedin provide us with Personal Data about you, such as the following:
• Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Google, Facebook, Linkedin), the third party service will send us information about you, such as email address, profile picture and name.
• Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
• Provide support and assistance for the Services
• Communicate with you about the Services
• Contact you about Service announcements, updates or offers
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Enforce our Terms of Service
How and With Whom Do We Share Your Data?
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
• Fraud prevention service providers
• Hosting service providers
• Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
• Social media services (if you interact with them through your use of the Services)
• Third party business partners who you access through the Services
• Other parties authorized by you
We also share Personal Data when we believe it is necessary to:
• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services
We also share information with third parties when you give us consent to do so.
Last, we share Personal Data with our affiliates or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, All Personal Data is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption. All Personal Data is stored on Benchling is hosted on Amazon Web Services (AWS) and Microsoft Azure, which undergo various third-party independent audits on a regular basis, covering compliance controls for its data centers, infrastructure, and operations. This includes SOC 2 certification and ISO 27001 certification.

Personal Data of Children:

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us atbusiness@alternativedata.com

What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email business@alternativedata.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by sending us an email at business@alternativedata.com
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by sending us an email at business@alternativedata.com.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data:

The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.

Company is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Company’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.

Please contact us at business@alternativedata.com with any questions or concerns relating to the Privacy Shield. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

What If You Have Questions Regarding Your Personal Data?
If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:

Name: Alternative Data Limited
Physical address: 9/F, TusPark, 118 Wai Yip Street, Kwun Tong, Hong Kong
Email address for contact: business@alternativedata.com
Designated representative and contact information
DP-Dock GmbH
Ballindamm 39
20095 Hamburg
Tel.: +49 (0) 40 99999 – 3430
Mob.: +49 (0) 172 918 22 22
E-Mail: mailtime@gdpr-rep.com
Data Protection Officer and contact information
Charlie Sheng, business@alternativedata.com
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