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Last Updated: August 3, 2023
Utila Inc (“Utila”, “we”, “our” or “us”) develops and operates a digital assets management platform software solution, which includes the Utila mobile apps, including Utila Mobile App, Utila Offline App and Utila SDK (“App“). We also operate the websites https://www.utila.io/ https://console.utila.io their subdomains and their related features (“Website”, and collectively with the App – the “Services”).
Specifically, our Policy addresses the following –
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.
You are not legally required to provide us with any Personal Data (as defined below), but without it we will not be able to provide you with the full range or with the best experience of using our Services.
1. What types of data we collect?
We collect two types of data from you: Personal Data (“Personal Data”) and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you. If we associate Non-Personal Data with Personal Data, we will treat such information as Personal Data.
Information from Other Sources
We are working closely with third parties (including, for example, our business partners, sub-contractors, etc.) and may receive information about you from them to the extent permitted by applicable laws. For example, we may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Services), traffic analytics vendors, fraud prevention agencies and others. We may also receive your data from third party providers which may conduct KYC, or CDD, or any other screening or AML or CTF-related procedures on our behalf, where applicable; or from third parties, including node providers, which may provide us with blockchain activity information. We may combine this information with the information we have already collected from you via the Service in order to provide you with, and to and improve, our Services.
2. Why we process your Personal Data, and under what legal bases?
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlies our usage.
3. With whom we share your data?
We may share your Personal Data as described below:
4. Your rights
Certain jurisdictions provide individuals with certain statutory rights to their Personal Data. For example, as an EU resident subject to the GDPR, you may request to:
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
We will make an effort to reply within a reasonable timeframe, and as required under applicable data protection laws. Please feel free to reach out to us at any time via the following email address: email@example.com.
If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
5. International data transfers
Since we operate globally, and accordingly Personal Data may be stored and processed in various countries worldwide. We may transfer your Personal Data to countries other than your own jurisdiction, including to the United States. These countries’ data protection rules may differ from those in your country. We will take appropriate measures to ensure our transfers of Personal Data comply with applicable data protection laws.
6. How we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
7. How we protect your data?
Our Services are only eligible to individuals who are the greater of eighteen (18) years of age or the age of legal majority in the applicable jurisdiction (“Applicable Age“). We do not knowingly collect or solicit Personal Data from anyone under the Applicable Age. By accessing, using or interacting with our Services, you certify to us that you are not under the Applicable Age. In the event that we learn that we have collected Personal Data from an individual under the Applicable Age without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Applicable Age, then please contact us through the contact details available below.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
9. Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
10. Contact Us
If you have any further questions, please contact us by email at firstname.lastname@example.org
Physical address: Hamasger 35 Tel-Aviv, Israel