Privacy Policy

Effective date of the policy: March 21, 2022

To allow users access to and use of the NEARamp Software Development Kit (“SDK”), developed by Crypto-Capable (“we”, “us”, “our”), we need to access and retain certain information about you. The collection, handling, retention, disclosure, protection, and processing of Personal Information (defined below) we gather from you is governed by this Privacy Policy (“Policy”).  

This Policy refers to, incorporates, and includes our Terms of Use. We may revise this Policy from time to time, so please check this page regularly to ensure you remain aware of the changes we may make. If you disagree with this Policy, please refrain from accessing or using the SDK.

If you have any queries, concerns, or grievances regarding this Policy, or the processing of your information, you may please write to our Grievance Redressal Officer, Mr. KS Pradham, at legal@cryptocapable.community. 

1. Categories of information:

In this Policy, Personal Information means information or an information set that identifies or could be used to identify an individual. We collect the following types of information as set out below:

S. No

Category of Information

Description

1.

E-mail Address

This includes your e-mail address, or a hashed (encrypted) form of your e-mail address.

2.

Device and Network Data

This includes information like your device model ID, the operating system, the browser being used, use of a Virtual Private Network (VPN) or other similar data points.

3.

Geolocation Data

This includes information about the location of the IP address or the time zone or other similar data points.

4.

Usage and Analytics Data

This includes information such as the App usage pattern, the language of usage, user analytics or other similar data points.

5.

Inference Data

This includes inferences drawn from any of the information collected by us.

6.

Wallet Data

This includes your NEAR Wallet ID and the crypto-assets linked with the Wallet ID.

2. Legal basis:

We collect and process your Personal Information: (i) to provide you the SDK in accordance with our Terms of Use; (ii) for the performance of the contract executed with you in accordance with our Terms of Use; and (iii) our legitimate interests to do so, provided that such legitimate interest is not overridden by your rights, (as specified in Section 9 below). This information is compiled and analysed on an aggregated basis. 

3. Manner of collection:

We collect your Personal Information in the following three ways:

  1. Information you provide to us: You may provide us with information so as to enable us to integrate the SDK with your software or to access, interact with, or use our SDK. 
  2. Information we may receive from third parties: We may receive certain information about you from third parties through authorization that you may have provided to such third parties for sharing such information with us. 
  3. Information we generate: We use in-house or third-party analytics tools to help us measure the usage of the SDK. These tools collect information sent by your device or browser while you access, use or interact with the SDK. 

4. Purpose of processing:

We process your information for the following purposes:

  1. Provision of SDK: We may use the information to operate, and provide you the various functionalities of the SDK. We use the information to support your use of the SDK. Where it is in our legitimate interests to do so, we use the Personal Information collected by us for various purposes to enable us to serve you better. 
  2. Improvement and Analytics: We may use your information to improve our offerings and the SDK. We may also use your information to undertake analytics activities.
  3. Fraud Prevention: We may use your information for the identification, prevention and mitigation of fraudulent activity. 
  4. Legal Obligations: We may use your information to comply with our legal obligations.

5. Disclosure: 

The information we collect is shared only on an as-needed basis. We do not sell your data to third parties for profit. We may execute data-sharing agreements or disclose collected data to third parties to provide the SDK. We have detailed the manner in which we share the collected data here:

S. No

Category

Description

1.

Cloud Platforms

We may use third-party cloud service providers to store and process your information, included but not limited to Microsoft Azure and MongoDB.

2.

Fraud Prevention Platforms

We may use certain third-party platforms to identify, prevent and mitigate any fraudulent activity, including but not limited to Bureau ID and HCaptcha.

3.

Analytics Platforms

We may use certain third-party applications to perform analytics-related tasks and to generate Inference Data, included but not limited to Microsoft Azure, HCaptcha, Google Analytics and Sentry.io.

4.

Law Enforcement Agencies

We may share your information with law enforcement agencies, government officials, regulatory bodies, courts, banks, self-regulatory organisations and other similar entities to comply with our legal obligations.

6. Storage and Transfer:

We may host, transfer and process data, including Personal Information, in India and in other countries that we use to operate and manage the SDK. We use the services of third-party data processors to host data. Transfers of data to these third parties are done under contract in compliance with applicable law.

7. Security:

We take appropriate technical and organisational measures, proportionate to the risk possessed,  to protect your information. The transfer of Personal Information between your end device and us is generally carried out in an encrypted form. You can identify an encrypted connection by the lock symbol in the address line of your browser. If you communicate with us by email, access by third parties cannot be ruled out. In the case of confidential information, we recommend using encrypted email communication (PGP).

However, no internet or electronic transmission is ever fully secure or error-free. We expressly disclaim any liability for any unauthorized access or use of any information, if such access or use has been done despite us employing all commercially reasonable efforts, in accordance with applicable law. 

8. Retention:

We will retain your information as long as needed or permitted, in light of the purposes mentioned above, subject to our compliance with this Policy. Among other criteria, we may determine the retention period based on the length of the ongoing relationship with you. We may further retain and use this Personal Information as necessary to comply with our legal obligations. 

9. Your Rights: 

You have the following rights with respect to your Personal Information: 

  1. Right of access - You can ask us for copies of your Personal Information being processed or retained by us.
  2. Right to rectification - You can ask us to rectify inaccurate or incomplete Personal Information about you (which you cannot update without our assistance).
  3. Right to erasure - You can ask us to delete your Personal Information in certain circumstances, subject to our compliance with data retention requirements, as per Section 8. Please note that multiple legal bases may exist for the retention of your Personal Information.
  4. Right to restriction - You can ask us to restrict the processing of your Personal Information in certain circumstances, like (i) where you contest the accuracy of your Personal Information, (ii) where the processing is unlawful; or (iii) where we no longer need to process your Personal Information.
  5. Right to object - You can object to the processing of your Personal Information in certain circumstances. If you object to processing based on legitimate or public interests, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or where the processing is otherwise required for the establishment, exercise or defence of legal claims.
  6. Right to data portability - You can ask us to transfer the Personal Information to another organisation (where technically feasible) or to you, in certain circumstances, like (i) where you have provided us your Personal Information or (ii) where your Personal Information is processed using automated means.
  7. Right to lodge Complaint: You can lodge complaints with your respective data protection authority, if we are unable to address your concerns. 
  8. Right to withdraw consent: You can withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal

In order to exercise any of your rights you may send us an email at legal@cryptocapable.community detailing your request. We may undertake additional measures to confirm your identity. Please note that exercising your rights might affect our ability to provide you the SDK or any of its functionalities. 

10. Other Information about our Privacy Practices:

  1. Other Application: You might interact with our SDK through third-party software. We do not determine and we are not responsible for the privacy practices of such third-party software. When you share your information with such third-party software, you do so at your own risk. Please read the privacy policy applicable to such third-party software for more details.  
  2. Do Not Track: We might not respond to a “Do Not Track” signal in any particular way, since there is no common understanding on what such a signal is supposed to mean. 
  3. Children's Personal Information: Our services are not directed at individuals below the age of 18 years (“Minors”). We do not knowingly collect any Personal Information from Minors. We encourage parents and legal guardians to monitor their children’s usage and to help us enforce our Policy. 
  4. Changes to this Policy: We may, in our sole discretion, modify or update this Policy from time to time. If we make any material changes to this Policy, we will notify you by posting a prominent notice on our website. Your continued use of the SDK constitutes your agreement to be bound by such changes to this Policy. 
  5. Business Transactions: We may assign or transfer this Policy, and your Personal Information, in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings, provided that the recipient of such information will continue to be bound by the terms of this Policy.