Privacy Policy 

Effective January 1, 2022.

This Privacy Policy is specific to use of this 360insights portal/website (“website”) and 360insights’ administrative services for the Incentive Token Program (“Program”). Please see the Program sponsor’s applicable Privacy Policy, which shall apply to them and the Program generally.   

360insights (“we”) and the Program sponsors are committed to maintaining your privacy and protecting your information, including your personal data, when you visit and/or use this website. This Privacy Policy explains how we will use and protect your information.

We may modify this Privacy Policy from time-to-time and will notify you of these changes when you attempt to access the website.


What is “Personal Data”?

“personal data”, also sometimes referred to as personally identifiable information, PII, personal information, or non-public personal information, means, for purposes of this Privacy Policy, any information that (i) directly and clearly identifies you as an individual, or (ii) can be used in combination with other information to identify you as an individual. Personal data does not include such information if it is anonymous or if it has been rendered de-identified by removing personal identifiers.

How do we use your personal data?

Personal data is only collected on this website for the execution and administration of the Program services. Personal data such as your name, address, email address, cell phone number, company name, company address, and other relevant information will be used to create a user account and enable us to administer the Program services for the Program sponsors. Personal data will only be used to fulfil the specific purposes of the Program and associated activities, including but not limited to token banking account management, fulfilment of rewards and related communications.

What do we do with your personal data?

We may use and share your personal data only for the following purposes:

  • To register you on the website and to administer the Program website and services;
  • For assessment and analysis of the Program performance and reporting to the Program sponsors;
  • To enable us to monitor, review and improve the website and related services which are being offered; and
  • For internal statistical user reporting on an anonymized and aggregated basis

Unless otherwise required by law, we will not share your personal data with any other third party, unless we have informed you of the need to do so and obtained your consent. We do not sell your personal data.

How do we collect that information?

We collect information about you, including personal data, using various methods including:

When you submit it through this website;

  • From information held and supplied by the Program sponsors; and
  • When you call us or correspond with us by means other than through this website.
  • We may combine information that we collect about you through this website with information that you provide to us by other means.

How long do we keep your personal information for?

We retain your personal data and other information for the period of time that you are registered with this Program or as otherwise required by law.  Should you leave the Program, your personal data will be removed after 30 days unless retention is otherwise required by law or the Program sponsor’s business transaction retention policies provide otherwise. Your personal data will be retained for 6 months from the end of our administration of the Program to enable an orderly transition of the Program to a new administrator or closing of the Program. Any personal data obtained as part of an order for services by you or business transactional data will be retained for a period not exceeding 2 years following the end of our Program administration to enable the on-going management of the Program, including order support, issues and warranties and any required transition of the Program to a new administrator.  Thereafter, your personal data will be irretrievably deleted.

We will retain personal data essential for legal or regulatory purposes for the duration of the relevant requirements.

To whom do we disclose your information?

We will not disclose to any third parties, personal data which relates to you without your prior consent, except:

  • To the Program sponsors as defined above;
  • Where it is necessary to enable any of our staff, employees, agents, contractors, suppliers or commercial partners to provide Program services to us or to perform a function on our behalf (including fulfilling orders for products or services, supplying products or services that we provide on behalf of Program sponsor(s));
  • Where we have justifiable reason to disclose your information to other businesses, financial organizations or law enforcement agencies to be necessary or desirable with a view to the prevention or detection of fraud, or if we are required to or are permitted to by law.

What rights do you have?

You can request verification of your personal data we keep on record and, where required by local law, we will provide you with access to such personal data.

If you believe any information that we keep on record is inaccurate, you may request that it be corrected.

This Privacy Policy is intended to comply with 360insights’ obligations under California’s Consumer Protection and Privacy Act, as amended (“CCPA”), the California Privacy Rights Act (“CPRA”), as amended, and any similar state and/or federal laws applicable to the privacy of Personal Information or personal data collected hereunder. This Privacy Policy shall be interpreted in such a manner. This Privacy Policy does not provide any rights to you other than those mandated upon us by applicable law(s).

Cookies

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. The website that created the cookie can then access it at a later time to recover the information, for example for use on a different page.

Our use of cookies

We use our own and third-party cookies to enable you to experience the website, for functionality purposes, and for reporting purposes to authorized third parties, including Program sponsors.

Cookies are used both pre- and post-log in and the cookie is given a life based on system requirements, after which it expires.

Do Not Track

We do not track users over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

Linking

This website may contain links to other websites which are completely unrelated to the activities involved in our business and are outside of our control.  Whilst we try to ensure that we link only to websites which share our privacy and security standards, once you have left this website, we cannot be responsible for the protection and privacy of any information which you provide on other websites. You should exercise caution and review the privacy statement applicable to the website in question, prior to accepting the use of such website.

How We Protect Your Information

To prevent unauthorized access or disclosure, maintain data accuracy, and facilitate the appropriate use of information, We and our sub-processors use physical, technological, and administrative procedures to protect the personal data we collect through the website. Nevertheless, Internet transmissions are never completely private or secure. You understand that any messages or information you send to or through the website, including, without limitation, personal data, may be read or intercepted by others.  If you have any questions about this Privacy Policy or the personal data we collect, please contact us at

Residents of California

In order to comply with the requirements of the California Consumer Privacy Act (CCPA) for our Californian resident consumers and users, this Privacy Policy outlines the legal basis on which we collect and process your Personal Information and provides other information required by the CCPA.

360insights does not sell Personal Information and has not done so in the past 12 months.

The CCPA provides Californian resident consumers and users with specific rights regarding their personal information.

Information We Collect

  • We have collected the following categories of personal information from consumers within the last twelve (12) months:
  • Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number. Some personal information included in this category may overlap with other categories.
  • Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar network activity, such as browsing history, information on a consumer’s interaction with a website or application

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which your Personal Information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to non-discrimination

You have the right not to be discriminated against for exercising any of your rights

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a valid consumer request to us at [email protected].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person we collected Personal Information from or an authorized representative on your behalf.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.