Privacy Policy

1. DATA COLLECTION

1.1 When you access, use, connect to, or interact with the Website, we may collect certain categories of information about you, including personal data, from a variety of sources.

Information you provide to us:

1.2 Data may include: (i) any digital-asset, smart-contract, or protocol address ("Wallet") information; and (ii) geolocation data. You provide this data to us when you connect your Wallet to the Website.

1.3 Other data may include transaction data or history (such as your public blockchain transaction history and other information associated with a linked address or Wallet and token holdings). Should you contact us, we will collect the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

Information we collect automatically:

1.4 When you visit certain pages on our Website, our servers save each access in a log file. The following data may be collected: (i) the date and time of access; (ii) the country from which the website is accessed; (iii) any API endpoints being accessed; (iv) user agent details; (v) the operating system of your computer and the browser you are using (provider, version, and language); and (vi) the transmission protocol used (e.g., HTTP/1.1).

1.5 Finally, we may use web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Website, including technologies collecting certain information about your access to, use of, connection to, or interaction with the Website ("Usage Data") that may be integrated with third-party service providers.

1.6 When you access, use, connect to, or interact with the Website, the Company and any of its third-party service providers may receive and record personal data that you may have provided and your digital signature.

1.7 In our legitimate interests to provide effective services to you, we may also use this data to create aggregated, anonymized, or de-identified data.

2. THIRD-PARTY WALLET CONNECTIONS

2.1 Certain features of the Website may require you to connect a compatible third-party digital Wallet. By using such Wallet, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet.

2.2 Wallets are not maintained or supported by, or associated or affiliated with, the Company. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA

3.1 We generally process the information we collect when we need to do so to perform our contract with you. For example, the processing of this data is carried out for the purpose of enabling your access to, use of, connection to, and interaction with the Website, including: (i) to facilitate your connection to the Website; and (ii) to identify if you are likely to be a Restricted Person, as defined in our general Terms of Use, available at app.pacifica.fi/terms. Each case with respect to any of (i) or (ii) is in order for us to perform our contract with you and in our legitimate interests to provide access to the Website to you.

3.2 With your consent, we may use any data collected, including Usage Data, to tailor features and content to you and to ensure content is presented in the most effective manner for you and your device. We may also use and run analytics to better understand your user experience with respect to the Website.

3.3 We may also process this data in our legitimate interests to assist system security and stability for provision of the Website, to conduct troubleshooting, data analytics, testing, and research, and to enable optimization and internal statistical analysis with respect to the Website, as well as to maintain the safety and security of our users, the Website, and to improve and develop the Website.

3.4 In addition to the foregoing, we may use any of your information to comply with any applicable legal obligations, to enforce any applicable terms of use, and to protect or defend the Website, our rights, and the rights of our users or others.

4. COOKIES

4.1 We use cookies to enhance your experience when accessing and using the Website. The cookies we use are strictly necessary cookies, which help ensure compliance with our Terms of Use, and are otherwise integral to our ability to provide the best user experience and to help us understand general usage patterns. These cookies are not used for marketing purposes. By continuing to use the Website, you consent to the placement of these cookies.

5. YOUR RIGHTS

5.1 Under applicable data protection laws, you may have certain rights in relation to your personal data. These rights may include the following:

5.1.1 Access to your personal data that we hold, information on how we use it, and who we share it with;

5.1.2 Request the correction of inaccurate or incomplete personal data we hold about you, which we may verify as necessary before making changes;

5.1.3 Deletion or removal of your personal data, in certain circumstances;

5.1.4 Objection to the processing of your personal data, in certain circumstances;

5.1.5 Restriction of the processing of your personal data, to stop us from processing the personal data we hold about you other than for storage purposes, in certain circumstances;

5.1.6 Portability of your personal data; we will endeavor to provide you, or a third party, with a copy of the personal data that we hold about you and transfer it to a third party in a structured, commonly used, machine-readable format;

5.1.7 Withdrawal of consent, where we rely on consent to process personal data; this will not affect the processing of personal data carried out before consent is withdrawn or on legal bases other than consent.

5.2 You may submit a written request concerning the processing of your personal data to ops@pacifica.fi. Please note that, prior to any response to such requests, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case.

5.3 Note that these rights apply only in certain circumstances and all of these rights may be limited by law. Such limitations may apply, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

5.4 To the extent required under applicable data protection laws, we will be responsive to your request without undue delay and where required under applicable data protection laws, at least within one month (though this may be extended by a further two months in certain circumstances).

6. SHARING OF PERSONAL DATA

6.1 In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law, including, but not limited to:

6.1.1 service providers and vendors: we may share your personal data with third parties to process on our behalf. Such third parties could include blockchain analysis service providers, screening service providers, developers, content delivery service providers, and data analytics service providers. Such service providers may assist us with many different functions and tasks, including geo-blocking based on IP address and collecting anonymized device information for analytics purposes.

7. DATA RETENTION

7.1 We will retain your personal data only for so long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements, or as otherwise required by law. The length of time we retain your data will depend on the nature of the data and the purpose for which it was processed.

8. SECURITY AND PROTECTION

8.1 Be aware that despite our efforts to protect your personal data and other information, we cannot guarantee perfect security of your information transmitted through the Website. In addition, note that any information you send to us electronically, may not be secure while in transit. Any transmission is at your own risk.

9. CHILDREN'S PRIVACY AND DATA PROTECTION

9.1 If we become aware that we have unknowingly collected information about any person under eighteen (18) years of age, we will make commercially reasonable efforts to delete such personal data and other information from our records.

10. SOCIAL MEDIA AND THIRD-PARTY LINKS

10.1 We may provide links on the Website to other websites or online platforms operated by third parties, including social media or content platforms operated by third parties, such as X (formerly Twitter) or Medium (such platforms, generally, "Social Media Platforms"). We may also provide links to websites or online platforms operated by third-party contributors to the Pacifica ecosystem ("Contributors"). We do not own, operate, or control such third-party websites. If you follow links to sites not owned or operated by us, you should review their available privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy, security, or content of these sites, including the accuracy, completeness, or reliability of information and services found on these sites.

10.2 Note that third parties and Contributors may provide services, information, dashboards, websites, tools, functionalities, and applications, and these may be linked from time to time through the Website or through Social Media Platforms. Such third parties and Contributors are independent and as such, we do not own, operate, or control their services, information, dashboards, websites, tools, functionalities, and applications and cannot guarantee, and are not responsible for, the privacy, security, or content of these sites or the accuracy, completeness, or reliability of services, information, dashboards, websites, tools, functionalities, and applications found on these sites. Our inclusion of links, including through Social Media Platforms, does not, by itself, imply any endorsement of such services, information, dashboards, websites, tools, functionalities, and applications, or of their owners, operators, or publishers, except as disclosed on the Website.

10.3 When you open a link to any Social Media Platform from the Website, a direct connection may be established between your browser and the server of the Social Media Platform. This provides the Social Media Platform with information that you visited the Website and accessed the link. If you access a link to a Social Media Platform while logged-in to your account on the Social Media Platform concerned, the content of the Website may be linked to your profile on the platform (i.e., the Social Media Platform may link your visit to the Website directly to your user account). If you want to prevent this, you should log out before clicking on the relevant links. In any case, an association takes place when you log-in to the relevant Social Media Platform after clicking on the link.

11. CONTACT

11.1 Should you have any questions or complaints about our privacy or data-protection practices, your personal data, or this Policy, you can email us at ops@pacifica.fi.