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Last Updated: March 10th, 2023
Your privacy is important to us at Streamflow. We respect your privacy regarding any information we may collect from you across our website.
This Policy describes how we use, share, and protect the personal information of users of our Platform. It also describes the rights and choices regarding use, access to, and correction of personal information available.
2. Collection of Personal Information
Here is a list of the categories of personal information we may collect and process.
Information You Provide Us
We may collect personal information from you, when you schedule a demo and/or sign up to receive communications from us. Such personal information includes your name, email address, and phone number. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. If you use our Platform to automate token vesting, issue token grants in compliance, and manage token cap tables then we may collect other personal information including your crypto wallet public address.
We may also collect personal information at other points on our Platform that explicitly states that personal information is being collected from you. Streamflow will disclose the purposes of collecting your personal information accordingly. Streamflow will only use your personal information for the purposes for which is has been collected from you.
3. Use of Personal Information
In general, personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you
better. We use your personal information in the following ways:
- Allow you to create and maintain an account on our Platform;
- Allow you to manage stakeholder lists and cap tables;
- Automate vesting of tokens;
- Facilitate the transfer or issuance of tokens;
- Provide improved administration of our Platform;
- Provide you with customer support when you request it;
- Market our products and services to you;
- Send you administrative email notifications, such as security or support and maintenance advisories; and
- Send you email notifications related to actions on the Platform.
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using personal information collected from or about you. You may opt-out of such communications at any time by contacting us via email at email@example.com. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your personal information for those third parties’ direct marketing purposes without your consent.
4. Disclosure of Personal Information
We will not disclose any personal information we collect from you to any third-parties except as indicated below:
- Service Providers - We may share your personal information with third-party service providers for business or commercial purposes. Your personal information may be shared so that they can provide us with services, including customer support, data analytics, advertising, marketing, and data processing. We share your personal information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your personal information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations.
- Professional Advisors - We may share your personal information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
- Law Enforcement and Legal Request – We may disclose personal information to comply with applicable legal and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
- Business Transfer – We may disclose personal information to a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Streamflow’s assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which personal information held by Streamflow are among the assets to be transferred.
5. Personal Information of Minors
We do not knowingly collect personal information from children under the age of eighteen (18) without authorization by a holder of parental responsibility. If you believe that we may have collected personal information from or about a child under the age of eighteen (18) without such authorization, please contact us at firstname.lastname@example.org.
6. Protection of Personal Information
We take the protection of your personal information seriously. Streamflow employees who have access to your personal information are made aware of the importance of keeping it confidential. We care about the security of the information and use various administrative, and technological safeguards to preserve the integrity and security of all information collected through our platform. Measures we take include encryption of Streamflow website communications with TLS/SSL; single sign-on and required two-factor authentication for all sessions for Streamflow employees; periodic review of our personal information collection, storage, and processing practices; and restricted access to your personal information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
When we rely on service providers that may require access to your personal information, we require them to have adequate privacy and security standards. We use contracts and other legally binding measures with our service providers to maintain the confidentiality and security of your personal information, and to prevent such information from being used for any other purpose.
However, no data security measures can guarantee complete security; we also depend on you to take common sense steps to ensure your personal information remains secure. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our platform.
7. Information for California Consumers
The information and rights in this section apply specifically to California residents.
Streamflow does not sell, trade, exchange, or rent out our User’s personal information for compensation, nor have we done so in the preceding twelve (12) months.
California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. Currently, Streamflow does not disclose personal information to third parties for direct marketing purposes. Thus, upon receipt of such a request by a California consumer, and as required by California state law, we will either (1) respond with a confirmation that we have not disclosed any personal information to third parties in the previous calendar year, or (2) if our practices have changed, we will provide the categories of personal information that has been shared in the past twelve (12) months and categories of third parties to whom such personal information was disclosed, whichever is relevant.
California consumers have the right to:
- Request disclosure of the categories and specific pieces of personal information that Streamflow has collected about you;
- Request disclosure of the categories of third-party sources, if any, from which Streamflow has collected personal information about you;
- Disclosure of the business or commercial purpose(s) for which your personal information has been collected by Streamflow;
- Receive a list of the categories of third parties with whom Streamflow has shared your personal information;
- Request that Streamflow delete any personal information that it has collected from you (subject to exceptions); and
- Not be discriminated against by Streamflow (e.g., charged different rates, provided different levels of service, denied goods or services, or suggested any of the preceding) for exercising any of the individual rights granted above.
To exercise any of your rights as a California consumer, you can submit a request to email@example.com.
Before complying with your request, we will need to verify that it is you that is making the request. To accomplish this, you may be requested to (1) confirm specific personal information that we already know about you; or (2) provide us with appropriate identification and documentation. California consumers are limited to two requests for personal information per 12-month period. Only you or an authorized agent may make a verifiable data subject request related to your personal information.
The verifiable data subject request must provide sufficient information and documentation to allow us to verify that you (or an authorized agent) are the person about whom we collected personal information. We will not provide you with personal information if we cannot verify your identity and/or authority to make the data subject request and confirm the personal information belongs to you or the represented individual. We use personal information provided in a verifiable data subject request solely to verify the requestor's identity or authority to make the request.
We will acknowledge receipt of your data request within 10 days. We will respond to a verifiable data subject request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period. If you have an account with us, we will deliver our response to the email address for that account or within your account profile. If you do not have an account with us, we will deliver our response electronically at the email address in your request. All disclosures we provide will only cover the twelve (12) month period preceding the verifiable employee request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable data subject request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
8. Retention of Personal Information
We retain personal information for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Platform to you;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
10. Updating Your Information and Contacting Us
If you have any questions or complaints related to our practices with respect to the collection, use, or disclosure of personal information, or if you would like to update your information, please contact us at: firstname.lastname@example.org.
Store your team's tokens for safekeeping, and distribute them efficiently when the time comes.