At Trojan. (hereafter “we,” or “us”), we prioritise your privacy. This Privacy Policy (the "Policy") outlines our methods for gathering, applying, and disclosing Personal Information (as defined later in the text). You must review this Policy alongside our Terms of Service ("Terms"), which are incorporated into this Policy. Please note that we reserve the right to modify any of our guidelines and practices at any time, but you will always find the most recent version of this Policy right here. Continuing to use our Platform after we have made any changes signifies your acceptance of those changes; therefore, we recommend you check this Policy regularly for any updates.
This policy covers: - The type of information we gather from you or that you provide when you access our website or use any related tools, mobile applications, web applications, decentralized applications, smart contracts, or Application Programming Interfaces (“APIs”) hosted on any Trojan’s websites, including, but not limited to, successional websites or applications (collectively referred to as the “Platform”). - Our practices for gathering, applying, safeguarding, and disclosing said information. We encourage you to study this Policy meticulously to comprehend our policies and procedures for managing your personal information. Should you disagree with our methods and practices, we politely ask that you cease to use our Platform. By using our Platform, you express your acceptance towards the Policy's terms.
PERSONAL INFORMATION GATHERED BY US
In this context, "Personal Information" refers to information that directly or indirectly identifies an individual or is reasonably capable of identifying an individual and can be associated with an identified or reasonably identifiable individual. Personal Information We Gather from You. Categories of Personal Information we (or our Affiliates) may collect directly from you include: Personally identifiable Information like name, email, phone number, postal address, wallet address, and legally required information including Know Your Customer verification information. Personal Information That May Be Gathered Automatically. We (or our Affiliates) may collect automatically the following categories of Personal Information through your use of our services: IP address, domain name, Device Information (operating system, browsers, device name, language preferences), Usage Data (system activity, internal and external information related to Trojan website pages you visit), and Geolocation Data (information about your device’s location). Collection of Personal Information may involve the use of Cookies, explained in greater detail below.
Trojan does not retain online identifiers, device information, or geolocation data on our systems. It’s important to note that third-parties we may deal with, like vendors or payment processors, might store this information. Personal Information We Collect from Third Parties. Third-party Personal Information we may collect and/or verify include: Identification Information (name, email, phone number, postal address), Transaction Information (public blockchain data). We, and any others who can associate your public digital asset address with your Personal Information, may identify you from a blockchain transaction because, under some circumstances, Personal Information published on a blockchain (such as your digital asset address and IP address) can be associated with Personal Information we and others may have. Moreover, through data analysis techniques on a given blockchain, it might be possible to discern other Personal Information about you; and additional Information, as needed to adhere to legal obligations. Accuracy and Retention of Personal Information
Our commitment is to ensuring the Personal Information we have about you is accurate for its intended uses, and not retained beyond the required purpose.
MINOR INFORMATION
We don’t intentionally collect data from or market to individuals younger than 18. We do not consciously solicit data from or engage in marketing activities to those under 18. By using the Platform, you are asserting that you are 18 years or older or that a parent or guardian of the minor who is under 18 is consenting to the minor’s use of the Platform. If we discover any information we collected is from users less than 18 years of age, we will immediately deactivate the account and take reasonable steps to promptly remove such data from our records.
HOW WE USE YOUR PERSONAL INFORMATION
We collect personal information about you with the aim of providing you with the best possible experience, to protect you from significant risks related to improper usage and fraud, and to assist us in improving our Services. Specifically, we may use your personal information to: Provide you with our Services as per our Terms. Remain in compliance with legal and regulatory requirements. Detect and deter fraud. Protect the security and integrity of our services. Provide customer assistance. Market our services and products.
HOW WE SHARE YOUR INFORMATION
We never sell, share, or lease your personal information to third parties for commercial purposes. We will not share your personal information with third-parties apart from situations listed below: Service Providers - We could share your personal information with third-party service providers to accomplish business or commercial tasks such as fraud detection and prevention, security threat detection, payment processing, customer service, data analysis, IT, marketing and advertisement, network infrastructure, storage, transaction monitoring. Law Enforcement - We might be compelled to disclose your personal information to law enforcement, government officials, and regulators. Consent - We might share your personal information with your permission. If we decide to alter the purpose for which your personal information is gathered and used, we will amend this policy.
COOKIES
Our users should be aware that we may use data files called cookies, flash cookies, pixel tags, or other tracking tools (“Cookies”) as is common practice when you access Trojan. Cookies help us identify our customers, collect information about your use of Trojan, and customize our services and content for you. If you reject cookies, you may be unable to use certain aspects of the Trojan website. If you do not consent to Cookies being placed on your device, we kindly ask you not to access Trojan.
DIRECT MARKETING
Under applicable laws and regulations, we may occasionally send direct marketing materials about services, products, facilities, or activities based on information collected about you. You can opt-out of such communications by following the instructions in each communication. We do not provide your personal information to third parties for their direct marketing purposes without your consent.
INFORMATION SECURITY
We cannot guarantee absolute security, but we tirelessly work to protect Trojan and our users from unauthorized access, alteration, disclosure, or destruction of the Personal Information we gather and keep. To do so, we employ measures such as SSL encryption of Trojan website communications, regular reviews of our Personal Information collection, storage, and processing practices, and limiting access to your personal information to our employees.
INFORMATION FOR PERSONS SUBJECT TO EU DATA PROTECTION LAW
We recognize our North American entity's customers in the European Union (“EU”), European Economic Area (“EEA”) or the Channel Islands, or other locations are under EU data protection law (collectively “Europe”). We recognize, and, to an extent applicable to us, adhere to relevant EU data protection laws. Under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) the term “personal data” has a specific legal meaning. Lawful Bases for Processing - Under GDPR, we process personal data subject to a legal basis such as Legal Obligation, Contractual Obligation, to monitor the usage of Trojan, to conduct security checks of our Service, protect our rights, and to market Trojan and our services. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before your withdrawal. European Privacy Rights - Europeans have rights under GDPR subject to certain exceptions under the law with respect to their personal data which includes Rights to access and rectification, right to erasure, right to restriction of processing, right to data portability. To exercise these rights, please contact us as described at the end of this Policy. We will check the identity of the requesting party to ensure that they are legally entitled to such requests.
COLLECTION AND TRANSFER OF DATA OUTSIDE THE EEA
We operate many of our services from the United States. Therefore, we may transfer personal data from Europe to other countries outside of Europe, including the United States, under certain conditions like Contractual obligation, consent to the transfer of your personal data to third country. Please understand that our services may not be available if we are unable to transfer your personal data to third countries. Based on California law, you may have the right to request access to the personal information we have gathered from you, request changes, or delete it under particular circumstances. To submit a request to exercise these rights, contact us as described at the end of this Privacy Policy. We will verify the identity of the person making the request.
CONTACT US
Do feel free to contact us with any queries or concerns about this policy or our handling of your Personal Information.
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