Last updated: January 9, 2020
COLLECTION OF INFORMATION
Information You Provide To Us
We collect Personal Information you provide directly or indirectly to us. “Personal Information” means information about you that is personally identifiable or from which you can be identified together with other information (e.g., your name, address, email address or phone number). Personal Information does not include information that is de-identified, aggregated, or that cannot be reasonably linked with an identifiable individual. For example, we collect Personal Information about you when you create an account to use one of our Services, download or use our mobile applications, complete a transaction on our website or mobile applications, fill out a form through our websites or mobile applications, respond to surveys from us, enter into a sweepstakes, contest or other promotion that we make available to you, post messages to our forums or otherwise communicate with us.
The type of Personal Information we collect varies, depending upon which Services you access, participate in or are using. The types of Personal Information we may collect are as follows:
Information We Collect From Other Sources
We may also obtain information from other sources and combine that with Personal Information we collect through the Services. For example, we may collect nonpublic Personal Information about you from third parties, including identity verification services. We obtain financial transaction history through a vendor (including a user’s bank account or credit card account transaction history) as necessary to implement certain Services (such as for calculation of “spare change” for the Metal Pay “Round Up” feature) and delete this data periodically in most cases.
We may also obtain Personal Information when we acquire a business or assets from another company, such as the acquisition of assets from Metal Pay.
Information We Collect Automatically
When you download, access or use certain of the Services, we automatically collect Personal Information as follows:
USE OF INFORMATION
We use your Personal Information as follows:
We use your Personal Information for the following key purposes:
DISCLOSURE OF INFORMATION
We may disclose any Personal Information we collect about you, whether you are a current or former customer, user of or participant in the Services, including nonpublic Personal Information and any other information we collect to all companies affiliated with Metal, and with nonaffiliated third parties, which include non-financial companies, such as email service providers, identity and fraud verification services, and others, such as other users of our Services with which you engage in transactions. We may make such disclosures:
1.To service providers that perform support or marketing services on our behalf, including, without limitation, virtual assistants who provide customer support; and
2.For our everyday business purposes, such as to process transactions, maintain accounts, comply with U.S. and international financial regulations, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share Personal Information about you as follows:
◦With any party you intend to distribute cryptocurrency or funds to, or that intends to distribute cryptocurrency or funds to you, via the Services, including information about whether your account is active and whether the account has been verified.
◦With vendors, consultants, professional advisors such as lawyers, accountants, auditors and other service providers who need access to your Personal Information to carry out work on our behalf or provide advice to us. These service providers help with our business operations such as fraud prevention, technology services, and payment processors. We enter into confidentiality agreements with these service providers and they do not have any independent right to share your Personal Information.
◦We may provide information about you or your Personal Information to (i) respond to subpoenas, court orders, legal process or governmental regulations, (ii) establish or exercise our legal rights or defend against legal claims, or (iii) enforce our user agreements or other policies and agreements. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, or as otherwise required by law.
◦In connection with, or during negotiations of, any merger, sale of Metal assets, financing or acquisition or all or a portion of our business to another company.
◦With your consent or at your direction.
3.If we are under any other duty to disclose or share your information to comply with our legal obligations.
Other than in connection with a merger, sale of Metal’s assets, financing or acquisition, we will not sell or rent any of your Personal Information to third parties for their own marketing purposes.
Please note that third parties that support our customer identification and anti-fraud controls may retain and use Personal Information about you to perform services on our behalf and to improve their services. By using any of the Services, you consent to the retention and use of such information by these providers to improve their services.
We may also share aggregated or de-identified information with our affiliated companies or nonaffiliated third parties, which cannot reasonably be used to identify you.
The Personal Information that we collect from you may be transferred to, and stored at, a destination outside your country of residence. We are headquartered in the U.S. and your Personal Information is transferred to us in the U.S., and to the third parties referenced above who may also be in the U.S. or otherwise located in a country with less stringent data privacy laws compared to those in your country of residence. We use reasonable technical and organizational security measures to protect your Personal Information when it is transferred or shared to us or our affiliates or our third party recipients.
Protection of information
Although no data processing and transmission can be guaranteed to be 100% secure, we take reasonable steps to protect all Personal Information. Metal uses industry-standard encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to building and files.
Deletion of Personal Information
If for any reason you wish to delete your Personal Information stored with us, please send us an e-mail to: firstname.lastname@example.org, and we will make reasonable efforts to delete any such Personal Information in accordance with any applicable privacy laws and consistent with reasonable recordkeeping practices. We may need to retain certain Personal Information for business records purposes, or for tax, or other legal requirements, or otherwise as permitted under applicable data privacy laws. Before honoring a request for deletion, we may need to request information from you to verify your identity.
Metal will retain your Personal Information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes. We will also maintain copies of your information to the extent retained as part of our standard backup/archive process. In addition, these procedures will not remove any of your information that you provided to other users or third parties, or that third parties collected from websites or services linked to our Services.
Access and Objection to Processing
Under applicable data privacy laws, you may have rights to request access to your Personal Information or to object to processing or request that the Personal Information you have provided to us is sent to another organization. If you would like exercise these legal rights, please contact us at email@example.com. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request. There are certain exemptions and restrictions of these rights under the applicable data privacy laws that enable personal information to be retained, processed, or withheld from access and we will inform you of these if applicable.
Your California Privacy Rights
California law permits customers who are California residents to request certain information about our disclosure of personal information during the prior calendar year to third parties for their own direct marketing purposes. However, we do not sell or rent your Personal Information to any third party for their own marketing. For questions, please contact us at firstname.lastname@example.org.
As of Jan. 1, 2020:
If you are a California resident, you also have the right to access any personal information we have collected about you and inquire about our collection, sale and disclosure of your personal information by calling us at [toll-free number] or visiting email@example.com
As of Jan. 1, 2020,: California residents have the right to opt-out of the sale of their personal information by visiting [ INSERT link to “Do Not Sell My Personal Information” page]
Your exercise of these rights will have no adverse effect on the price and quality of our goods and services.
To use the Services, you must be of the age of majority and, at the very least, over the age of 18. In addition, to participate in a promotion, you must be eligible under the Official Rules of that promotion. Metal Pay does not knowingly collect Personal Information from persons under the age of 18 and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that persons who have not reached the age of majority or are under the age 18 are not using the Services, including participating in promotions. In the event that it comes to our knowledge that a person under the age of 18 or who has not reached the age of majority in that person’s state of residence is using the Services, we will prohibit and block such user from accessing the Services and will make all efforts to promptly delete any Personal Information stored with us with regard to such user to the extent permissible by law and financial transactions recordkeeping requirements.
You agree (and, where required under applicable data privacy laws, you agree that only with your prior consent) that we may use your contact details for the purpose of informing you regarding products and services offered by us which may interest you through targeted advertising on your computer or mobile device, and to send to you advertisements and other marketing material, transmitted to the e-mail address you provide us.
You may withdraw your consent by sending a written notice to Metal by email to the following address: firstname.lastname@example.org or in the same manner as the advertising was transmitted to you (e.g., via email). We are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we are not responsible or liable with respect to such advertisements, products and services.
If you prefer to not receive targeted advertising from third parties, you can opt out of some network advertising programs that use your information. These network advertising programs may allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. To find out more, look for icons or other information displayed in the ads. To opt out of receiving interest-based advertising from third parties, click on both of the following links:
Response to “Do Not Track” Signals / Third Party Data Collection
Some Internet browsers include the ability to transmit “Do Not Track” signals. At this time, Metal does not process or respond to “Do Not Track” signals.
We do not knowing permit third parties to collect Personal Information about your online activities over time and across different website when you are using our Services.
Cookies & Local Storage
When you access or use the Services, we may use industry-wide technologies such as “cookies” or similar technologies, which stores certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your experience with our Services much more convenient and effortless. The cookies used by the Service are created per session, do not include any information about you other than your session key (removed as your session ends (usually after 24 hours)) and the ability to login again quickly (automatically removed usually after two years, unless manually removed on an earlier occasion). It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited. OTHER THAN THE STANDARD COOKIES MENTIONED ABOVE, PLEASE NOTICE THAT WE MAY ALSO MAKE USE OF E-TAGS WHICH WILL ENABLE US TO IDENTIFY USER BEHAVIORS. SUCH E-TAGS CAN ONLY BE REMOVED BY US AFTER RECEIVING A REQUEST FROM YOU IN WRITING IN THE MATTER.
We may also use certain third-party cookies. This is a different kind of cookie, stored on your computer by a third party, rather than by us. This kind of cookie is read-only (and not altered by us) each time you use the Service and when you visit certain websites or applications that use similar cookies.
Right to Lodge Complaints
We are transparent about the ways in which we collect and use Personal Information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your Personal Information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
Have any Questions?
If you wish to complain about the handling of your Personal Information outside of Metal you may, under applicable data privacy laws, have the right to raise a complaint with the supervisory authority in your country of residence.