Last Updated: August 3, 2023
CyberBrokers Inc. (“CyberBrokers”, “we”, “us”, or “our”) is committed to protecting your privacy and complying with all applicable Data Protection rules and regulations. We have prepared this Privacy Policy to describe our practices regarding Personal Data (as defined below) we collect, use, and share in connection with the CyberBrokers website and services provided. Please also refer to our Terms of Use available on our site. “NFT” in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain (such as the Ethereum blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data.
Types of Data We Collect. We collect Personal Data and Anonymous Data. “Personal Data” means data that allows someone to identify you individually, including, for example, your email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.
Information You Provide Us.
When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address and IP address. We also collect your Wallet ID, which may become associated with Personal Data when you use our Service.
Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser or mobile device.
If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.
We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.
Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns including:
Information Collected by Our Servers. In order to enhance your experience with our Service, we gather certain types of information. This includes wallet addresses, along with social media information such as your username, email address, ID, and associated date and time stamps.
Cookies. Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.
Analytics Services. As is true of most websites and applications, our analytics provider may gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”) referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our user’s needs.
In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy.
Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. Third-party service providers may also collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, and date/time stamps
Public Information Observed from Blockchains. We may collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.
Use of Your Personal Data
We process minimal Personal Data from you to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we may use your Personal Data to:
Facilitate the creation of and secure your account;
Identify you as a user in our system;
Provide you with our Service, including, but not limited to, helping you view, explore, and participate in puzzles, games and quests using our system and software tools;
Improve the administration of our Service and quality of experience when you interact with our Service;
Provide customer support and respond to your requests and inquiries;
Investigate and address conduct that may violate our Terms of Use;
Detect, prevent, and address fraud and/or security breaches, violations of our terms or policies, and/or other harmful or unlawful activity;
Display your username next to the NFTs currently or previously accessible in your third-party wallet, and next to NFTs on which you have interacted;
Send you a welcome email to verify ownership of the email address provided when your account was created or when you subscribe to our newsletter;
Send you administrative notifications, such as security, support, and maintenance advisories;
Send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services;
Respond to your inquiries related to employment opportunities or other requests;
Comply with applicable laws and governmental regulations, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
Act in any other way we may describe when you provide the Personal Data.
We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data when permissible.
Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
Third-Party Service Providers/Processors We may share your Personal Data with third-party service providers or processors to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.
Affiliates. We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
Legal Rights Regardless of any choices you make regarding your Personal Data (as described below), CyberBrokers may disclose Personal Data: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on CyberBrokers; (c) to protect or defend the rights or property of CyberBrokers or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
User Rights Depending on jurisdiction, users who provide Personal Data (whether via active or auto consent) may have certain statutory and/or regulatory rights to that Personal Data, including but not limited to: (a) Access to the Personal Data, (b) Right to request deletion of some or all of the Personal Data collected, and (c) Right to opt-out of data selling. For more specific information refer to subsequent Section Seven.
Other Disclosures We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.
Third-Party Websites Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites, their content, or the manner in which they collect, store, or protect your Personal Data. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
Third-Party Wallets. To use our Service, you do not need a third-party wallet.
Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
Email Communications. As long as you have provided opt-in consent, we may periodically send you newsletters and/or emails that directly promote the use of our Service or third parties’ goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the Notifications preferences in your Settings page. Despite these preferences, we may send you occasional transactional service-related informational communications.
If you decide at any time that you no longer wish to accept Cookies from our Service as discussed above you can instruct your browser to stop accepting Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.
Data Access and Control. You may also have certain additional rights:
If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time. To contact us concerning your rights please email to: info@cyberbrokers.io.
If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not* “sell” your “personal information. To contact us concerning your rights please email to: info@cyberbrokers.io.
If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact our Data Protection Officer by using the “Submit a request” link Request or at the address provided in Section 13* below, specify your request, and reference the applicable law or regulation. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.
Data Retention. We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Service if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms of Use or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it.
Data Protection. We care about the security of your information and use physical, administrative, and technological safeguards and best practices to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.
You are responsible for ensuring your Log-in information is kept secure and private. That may include the use of Two-Factor Authorization when appropriate.
Minors. We do not intentionally gather Personal Data from minors who visit our site. Our Terms of Use require all users to be at least 18 years old. If a minor submits Personal Data to CyberBrokers and we learn that the Personal Data is the information of a minor, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a minor, please contact our Data Protection Officer by emailing info@cyberbrokers.io or at the address indicated in Section 13 below.
Users Outside of the United States. If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified herein. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.
Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.
Questions; Contacting CyberBrokers; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact our Data Protection Officer at info@cyberbrokers.io or at the following address: 1 E Erie St., Suite 525-2666, Chicago, IL 60611.