ETC Privacy Policy
Last Updated: May 15, 2024
Eternal Tunnel Corporation, a Delaware corporation (“ETC,” “we,” “us,” or “our”), provides access to the ETC Interface (the “Interface”) and associated products (together, the “Products”). Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal and other information in connection with the use of the Products. By using the Products, you agree to this Privacy Policy. This Privacy Policy is subject to and incorporated by reference to our Terms of Service posted on www.thealbum.com.
1. Information We Collect About You
Personal Information
In order for you to access and use the Products, we may collect and use certain personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you when you use the Products. This information may include:
- Your name
- Contact information
- Other unique identifiers
- Financial information
- Information regarding your use of our Products
- Any other personal information you voluntarily share with us
This personal information is required to provide the Products to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing the Products to you.
Other Information Collected
We collect non-identifiable information, such as public on-chain data, and limited off-chain data (e.g., the device type or browser version used to access and use the Interface or other Products), as necessary to provide the Products to you, as well as for internal evaluation and enhancement of our Products. When you connect your blockchain wallet to the Interface or any other Products, we may collect and store your publicly-available blockchain address, which is publicly-available information and by itself is not personal information, to evaluate your use of the Products and to screen your wallet for any prior illicit activity.
2. How Your Information is Collected and Used
We collect most of your information from your use of the Products. However, we may also collect information:
- From publicly accessible sources (e.g., on-chain data, or property records)
- Directly from a third party (e.g., screening or due diligence providers)
- From a third party with your consent
- From cookies and geographical location tracking features (“geo-fencing”)
- Automated monitoring of our Products and other technical systems, such as our computer networks and connections, communications systems, email and messaging systems
We use the personal information listed above for the following business purposes:
- To provide our Products and/or to review and update our Products
- To comply with our legal and regulatory obligations, including in fulfillment of our anti-money laundering regulatory obligations
- For the performance of our relationship with you
- For our legitimate interests or those of a third party
- Where you have given consent
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.
Legitimate Interests/Consent
To the extent we rely on our legitimate interests as a legal basis for processing your personal information, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our Interface and other Products) and your interests. We believe that (a) you would reasonably expect us to carry out the kind of processing referenced above and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy. You have the right to withdraw any consent given to us for the processing of your personal information.
What We Use Your Personal Information For and Our Reasons
| What we use your personal information for | Our reasons |
|---|---|
| To provide the Products to you | To provide, monitor, maintain, customize, update, and improve the Products being utilized by you |
| To prevent and detect fraud against you, the Interface and/or our Products | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Screening for financial and other sanctions or embargoes | To comply with our legal and regulatory obligations |
| Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can efficiently deliver the best Products |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you |
| To address security risks | To monitor the Interface and the Products for potential security issues and protect our users |
| External audits and quality checks | For our legitimate interests or a those of a third party, i.e., to demonstrate we operate at the highest standards |
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone, or mail) about our Products, including exclusive offers, promotions, or new products or services. We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. You have the right to opt-out of receiving promotional communications at any time by:
- Contacting us at legal@etc.com
- Using any “unsubscribe” link in emails or “STOP” number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further Products in the future, or if there are changes in the law, regulation, or the structure of our business.
3. Who We Share Your Personal Information With
For the reasons identified above, we may share personal information with:
- Our affiliates
- Service providers we use to help deliver our Products to you
- Other third parties we use to help us run our business
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
- Our insurers and brokers
- Third parties in connection with, or during negotiations of, any reorganization, merger, or sale of our business
- Third parties when we believe it is necessary under applicable law; to enforce our Terms of Service; to protect our rights, privacy, safety, or property of yours or others; and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other governmental authorities
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We may also share personal information with external auditors.
4. How Long Your Personal Information Will Be Kept
We will only keep your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
Cross-Border Data Transfers
We may transfer your personal information to a third party that is located in a jurisdiction other than the one from which we collected your personal information, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your personal information to another jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organizational measures are implemented and maintained at all times to prevent the unauthorized and unlawful processing of personal information, and the accidental loss or destruction of, or damage to, personal information, consistent with our obligations under applicable data protection laws.
5. Your Rights Under the GDPR
If you are an EU or UK resident, you are entitled to certain rights under the GDPR and UK GDPR with respect to personal information that we have collected. We have listed below how these rights operate in the context of using our Products.
| Your Rights | Description |
|---|---|
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information - in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information - in certain circumstances, e.g., if you contest the accuracy of the data |
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations |
| Right to Object | The right to object: (a) at any time to your personal information being processed for direct marketing (including profiling); (b) in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests |
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
If you would like to exercise any of the above rights or if you have questions about your privacy rights, please use the contact details in the How to Exercise Your Rights section.
6. Your Rights Under California Law
“Shine the Light” and “Eraser” Laws
Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
Do-Not-Track Disclosures
We do not support Do Not Track (“DNT”) requests. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
7. Keeping Your Personal Information Secure
We have appropriate security measures in place designed to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
8. How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, please email us at legal@etc.com.
9. GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
10. Children
Our Products are not directed to children under the age of 18, and we do not knowingly solicit, collect, use, or disclose personal information from children under the age of 18. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
11. Changes to This Privacy Policy
This privacy notice was published in May 2024 and last updated on May 13, 2024. We may change this Privacy Policy from time to time – when we do, we will inform you via www.thealbum.com or other means of contact, such as discord.
12. How to Contact Us
Please contact us by email if you have any questions about this Privacy Policy or the information we hold about you. Our contact details are shown below:
Contact Details:
Email: legal@eternaltunnel.com
