Version Date: January 11, 2022

GENERAL

Coin Metrics Inc. (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at coinmetrics.io, including other media forms, media channels, mobile website or mobile application related or connected thereto, as well as in connection with the services we provide (whether through coinmetrics.io or otherwise) (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. You may also provide information to us when you meet us in person, such as at business conferences or when you are involved in our networking activities (collectively, “Networking Activities”) and this Privacy Policy relates to such information as well.It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

As used in this Privacy Policy (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means data protection laws enacted under the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR”) and the UK Data Protection Act 2018 (“UK DPA 2018”); and (c) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.To the extent that the Website is available to, or we collect information in connection with Networking Activities from, individuals located in the European Economic Area or the United Kingdom, or to the extent we process your Personally-Identifiable Information in the context of the activities of an establishment in the European Economic Area or United Kingdom, this Privacy Policy sets out our practices and obligations under the European Data Protection Laws, to the extent applicable.

If an organization with which you are associated (an “Organization”) uses our services, we may receive Personally-Identifying Information (as defined below) about you in connection with our provision of our services to your Organization. To the extent we process (as defined below) that Personally-Identifying Information solely in order to provide our services to your Organization, under the European Data Protection Laws, to the extent applicable, we will act as a processor (as defined in the European Data Protection Laws) on behalf of your Organization in respect of that Personally-Identifying Information; this Privacy Policy will not apply to the processing of that Personally-Identifying Information and your Organization will act as a controller (as defined in the European Data Protection Laws) in respect of that Personally-Identifying Information and is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your Personally-Identifying Information for any other lawful business purpose of ours, under the European Data Protection Laws, to the extent applicable, we will act as a controller of such Personally-Identifying Information and this Privacy Policy will apply to the processing of such Personally-Identifying Information.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, or engaging in Networking Activities with us, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. Without limitation of the foregoing, you hereby expressly grant consent to Company to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for Personally-Identifying Information (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by applicable law: whenever we transfer your personal data (as defined in the European Data Protection Laws) to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission or the UK Information Commissioner’s Office, as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.

You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.


GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

USERS OF THE WEBSITE GENERALLY

“Non-Personally-Identifying Information” is information that cannot be associated with an identified or identifiable individual. “Personally-Identifying Information,” by contrast, is information such as a name, login details, or email address that can be associated with an identified or identifiable individual. Additionally, our third-party service provider that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Additionally, the Company gathers Internet Protocol (IP) address from users of the Website; it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

WEB COOKIES

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Company uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used.

COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS MAY BE ABLE TO SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

WEB BEACONS

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they may be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

ANALYTICS

The Website may use third-party service platforms (including to help analyze how users use the Website).These third-party service platforms may place cookies on your computer or mobile device.The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

Here are links to the main third-party platforms we use:
google.com/policies/privacy
automattic.com/privacy
amplitude.com/privacy

AGGREGATED AND NON-PERSONALLY-IDENTIFYING INFORMATION

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors and investors, for the purpose of conducting general business analysis. For example, we may tell third parties the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest.

MOBILE DEVICE ADDITIONAL TERMS

  • Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
  • Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.

SOCIAL MEDIA

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.


COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

COLLECTION OF INFORMATION FROM USERS

Company may collect a range of Personally-Identifying Information from and about Website users and individuals with whom we engage in Networking Activities. Much of the Personally-Identifying Information collected by Company about individuals is information provided by individuals themselves when (1) registering for our service, (2) participating in polls, contests, surveys or other features of our service, (3) communicating with us, (5) engaging in Networking Activities, or (6) signing up to receive newsletters. That information may include a user’s name, address, email address, company, institute, and/or university with which you are associated, title, products that you may be interested in, information contained in your suggestions regarding the Website, and, if you transact business with us, financial information such as your payment method. In particular, our Payment Services Provider may collect your billing and credit card information from you directly. In addition, we may obtain your Personally-Identifying Information if you identify yourself to us by communicating with us including by sending us an e-mail with questions or comments or a request for support. Also, we will have access to any Personally-Identifying Information that you choose to share through the Website or in connection with our Networking Activities.You may also provide information to us in connection with Networking Activities and this Privacy Policy relates to such information as well.Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.

We may also collect Personally-Identifying Information about you from third-party sources such as LinkedIn and Substack, such as your job title, job function, company name, and/or email address.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

ONLINE POSTINGS

Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Website. We may provide areas on the Website where you can post reviews and other information relating to your activities on the Website. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION.

COMPANY COMMUNICATIONS

We may occasionally use your name and email address to send you notifications regarding new services offered by the Website or Networking Activities that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service.If you opt in, we and third parties acting on our behalf will use your name and email address to send you our weekly newsletter.If you wish to opt out of receiving these communications from Company or to change your preferences, you may do so by following the unsubscribe link in the email communications, by adjusting your subscription preferences (if applicable), or contacting us using the contact information below.

COMPANY DISCLOSURES

Company will generally disclose Personally-Identifying Information we gather about you through the Website or in connection with Networking Activities under the following circumstances:

  • By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement, including to meet national security requirements; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • Research Collaborations.From time to time, we may collaborate with a third party to produce research reports for the Website. We will inform you if we share your name, email address and/or company name with such a third party and provide you with an option to opt out of such sharing.
  • Third-Party Service Providers. We may share your Personally-Identifying Information with our authorized service providers that perform certain services on our behalf (including without limitation our Payment Services Provider). These services may include website hosting, providing customer service and marketing assistance, performing business and sales analysis, providing a newsletter subscription platform, supporting the Website’s functionality and supporting other features offered through the Website. In the course of providing products or services to us, these service providers may have access to information collected through the Website, and related to our Networking Activities, including your Personally-Identifying Information.We use reasonable efforts to ensure that these service provides are capable of protecting the security of your Personally-Identifying Information. Please note, in particular, that the Website may use Google Analytics, including its data reporting features.Information collected by Google Analytics includes but is not limited to web metrics.For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options.
  • Business Transfers; Bankruptcy. Company reserves the right to transfer Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets, or in connection an investment in the Company. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.
  • Affiliates.Company may disclose information (including Personally-Identifying Information) about you to its Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Company, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise. Any information relating to you that Company provides to its Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

COMPANY RETENTION OF PERSONALLY-IDENTIFYING INFORMATION

Company will only retain your Personally-Identifying Information for as long as necessary to fulfill the purposes for which it collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for Personally-Identifying Information, the Company will consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which it processes your Personally-Identifying Information and whether it can achieve those purposes through other means, and the applicable legal requirements.

YOUR CHOICES REGARDING YOUR PERSONALLY-IDENTIFYING INFORMATION

You may at any time review or change your Personally-Identifying Information by going to your subscription preferences (if applicable) or contacting us using the contact information below.  Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

  • Request access to your Personally-Identifying Information (commonly known as ‘subject access request’). This enables you to receive a copy of the Personally-Identifying Information we hold about you and to check that we are lawfully processing it;
  • Request correction of the Personally-Identifying Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • Request erasure of your Personally-Identifying Information. This enables you to ask us to delete or remove your Personally-Identifying Information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your Personally-Identifying Information in certain circumstances;
  • Object to processing of your Personally-Identifying Information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
  • Request the restriction of processing of your Personally-Identifying Information. This enables you to ask us to suspend the processing of your Personally-Identifying Information, for example, if you want us to establish its accuracy or the reason for processing it;
  • Request the transfer of your Personally-Identifying Information to another party; and
  • Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your Personally-Identifying Information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your Personally-Identifying Information, object to the processing of your Personally-Identifying Information, or request that we transfer a copy of your Personally-Identifying Information to another party, please contact [email protected]. Your request will be processed as soon as practicable and in accordance with applicable law. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your Personally-Identifying Information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all Personally-Identifying Information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

GENERAL USE

We will only use your Personally-identifying information to the extent that the law allows us to do so. Pursuant to the European Data Protection Laws, legal bases for our processing your Personally-Identifying Information may include (without limitation):

  1. where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
  2. where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Website or otherwise);
  3. where it is necessary for us to comply with a legal obligation to which we are subject; and/or
  4. where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing or marketing the Website, or engaging in Networking Activities,and your interests or fundamental rights and freedoms do not override those legitimate interests.

Company uses your Personally-Identifying Information as described in this Privacy Policy, and in particular (1) to deliver the products and services that you have requested; (2) to engage in Networking Activities, (3) to manage your account and provide you with customer support; (4) unless you opt out, to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties;(5) to develop and display content tailored to your interests on the Website and other sites; (6) to resolve disputes and troubleshoot problems; (7) to measure consumer interest in our services; (8) to inform you of updates; (9) to customize your experience; (10) to detect and protect us against error, fraud and other criminal activity; (11) to enforce our Terms of Use; and (12) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment (through our Payment Services Provider), to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.


COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Our Website may provide you with access to other websites and services.Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Please be aware that Company is not responsible for the privacy practices of any websites or services other than the Website. A link to a third party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.


SECURITY

We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.


PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.


CHILDREN

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact Company using our contact information below to have that child’s account terminated and information deleted.


CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.


DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.


CONTACT

If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:

Coin Metrics Inc.
Attn: Privacy Officer
125 High Street, Suite 220
Boston, MA 02110
Email: [email protected]


COPYRIGHT AND LEGAL NOTICE

Copyright © 2022 Coin Metrics Inc. All Rights Reserved.