Cow Moon Wealth Software, Inc. (“Common.xyz”,“we”,“us”, or “our”) works hard to build and maintain a relationship of trust with you. This “Privacy Policy” describes our privacy practices in connection with the www.common.xyz website, the Common.xyz Platform (i.e., the Common.xyz decentralized governance platform), and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.
Please read this Privacy Policy, which is part of our Terms of Service, before using our Service. If you do not agree with the Terms of Service and/or this Privacy Policy, you must refrain from using our Service. By accessing or using our Service you agree to our use of your information consistent with the Terms of Service and this Privacy Policy, subject to your rights described below.
Personal information. We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“personal information”) including:
The type of personal information we collect about you may vary based on how you use our Service and your relationship with us.
Usage information. We automatically collect information in connection with the actions you take on our Service (“usage data”). For example, each time you use our Service, we automatically collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our website, and the duration of your visits to our website. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as personal information. If this information is not capable of being individually associated with you, we treat it as usage data.
Communication recordings. We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
Information you provide to us. We may ask you to provide us with personal information when you interact or communicate with us, including when you sign up for the Service and through events, surveys, and marketing or promotional programs. You are not required to provide your personal information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Service or we may not be able to fulfill your requested interaction.
Contributions you make. You may post, publish, or display information on public areas of our Service or transmitted to other users of the Service or third parties, such as comments, questions, messages, voting responses, polling responses, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Further, if you make a contribution to the blockchain networks via the Service, it will automatically become public. Your contributions are posted and transmitted to others at your own risk and are out of our control but are subject to our Terms of Use. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of Service with whom you may choose to share your contributions. Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons. Your contributions may reveal personal information about you so we encourage you understand the impact of your contributions, including to review how privacy and transparency on the blockchain network work.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services.
Information we obtain from other third parties. We may collect personal information about you from other sources, including third parties, and combine that with information we collect through our Service. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, third-party wallet providers, other customers or consumers, data providers, and data from activity and information that is publicly visible and/or accessible on blockchains or other public sources.
If you choose to login to the Service via a third-party platform, including but not limited to GitHub or WalletConnect, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your GitHub username and profile picture. You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.
Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
Cookies and automated tools. We use cookies (a small text file placed on your computer to identify your computer and browser) and may use other automated tools such as pixels to track your interaction with our Service and to improve the experience of our Service, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of our Service may not work if you delete or disable cookies.
We may use the following types of cookies:
We and third parties may also use tools that enable us to track certain aspects of a user’s visit to our Service. This technology helps us better manage content on our Service by informing us what content is effective, how consumers engage with our Service, and how consumers arrive at and/or depart from our Service. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and personal information, if provided by the user.
If you arrive at our Service by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to our Service, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached our Service to determine what information the operator collects and how it uses such information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or personal information.
Interest-based advertising. We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Service as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use by an Advertiser of information that they may collect from you. Advertisements may be shown via our Service or on third-party websites. If you do not want to receive interest-based advertising, please see the subsection below titled “Targeted online advertising.”
Information from advertisements. If you arrive at our Service via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social media widgets. Our Service may include social media features, such as the Facebook, YouTube, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Service as well as other personal information. A cookie may be set to ensure that these features properly function. These companies’ privacy policies govern your interactions with these features and you should review the relevant privacy policies before interacting with these features.
We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To operate the Service. We use your personal information to:
For research and development. We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.
To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
To display advertisements. We may work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the subsection below titled “Targeted online advertising.”
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance and fraud prevention. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Reviews and testimonials. If you provide a review or testimonial, we may post it publicly on our Service or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:
Service providers. We may share your personal information with vendors, consultants and other third party companies and individuals that provide services on our behalf or help us operate the Service. Categories of service providers we use include:
These service providers may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
Other third-party disclosures. We may occasionally disclose your personal information to third parties who do not provide services to us, for purposes such as:
Other users and the public. Your profile and other user-generated content (except for messages) may be visible to other users of the Service and the public. For example, we may use technologies like API to display or share information relating to your public activity on blockchains, or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of information.
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
European Union users should read the important information provided below about transfer of personal information outside of the European Union.
As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as follows:
If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
In this section, we describe the rights and choices available to all users. Users who are located within the European Union, European Economic Area, Switzerland, or the United Kingdom can find additional information about their rights below.
Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into your account.
Opting out of marketing communications. You may opt out of marketing-related emails by following the instructions in those emails, or by contacting us at [email protected]. If you opt out, you may continue to receive service-related and other non-marketing emails, such as those about your account or our ongoing business relations. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Cookies & Browser Web Storage. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), andSafari (Mac).
Targeted online advertising. Some of the Advertisers that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Service and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Cow Moon Wealth Software Inc and others to, among other things, analyze and track data, determine the popularity of certain content, Service or products, deliver advertising and content targeted to your interests on our Service and other websites and better understand your online activity.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service.
California Shine the Light law (California Civil Code Section 1798.83). California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information via email to [email protected]. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
California “Do Not Track” Disclosure. Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Service does not respond to “do not track” signals.
The information provided in this “Notice to European Users” section applies only to individuals in the European Union, European Economic Area, Switzerland, and the United Kingdom (collectively, “Europe”).
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Essentially, it boils down to information about an individual, from which that individual is either directly identified or can be identified. It does not include “anonymous data” (i.e., information where the identity of individual has been permanently removed).
Controller. Cow Moon Wealth Software, Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. See the Contact Us section below for contact details.
Legal bases for processing. We use your personal information only as permitted by law, for the purposes for which we collected it as listed below. In respect of each of the purposes for which we use your personal information, the European data protection legislation requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information.
Purpose | Category of personal information involved | Why do we do this | Our legal basis for this use of data |
---|---|---|---|
Account Creation |
| To process and manage registrations you make through the Site, including for courses or events that we organize or host and to administer contests and other promotions |
|
Operate the Service |
| To operate, maintain, administer and improve the Site. To better understand your needs and interests and personalize your experience with the Site. To respond to your service-related requests, questions and feedback. |
We have a legitimate interest in providing you a good service, with updates on our Service and related offers where you have purchased or shown interest in similar services from us. |
Compliance, Fraud Prevention and safety |
| To keep our website, our services and associated systems operational and secure To enforce the terms and conditions that govern the Site | Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks. |
Troubleshooting |
| To track issues that might be occurring on our systems, provide support and maintenance for the Site To manage and communicate with you regarding your relationship with us, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages. | Legitimate Interests. It is in our legitimate interests that we can monitor and ensure the proper operation of our Service and associated systems and services. |
Purpose | Category of personal information involved | Why do we do this | Our legal basis for this use of data |
---|---|---|---|
Marketing |
| To form a view on what we think you may want or need, or what may be of interest to you. You will have the ability to opt out of such communications. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly. | Consent. |
Job application |
| To manage our recruiting and process employment applications. To facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. | Legitimate Interests. We have a legitimate interest in considering your job application. |
Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Your rights. European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
Exercising Rights. You may submit request to exercise a privacy right by email to [email protected].
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
Complaints or Concerns
You have the right to make a complaint at any time to the supervisory authority for data protection issues in country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
We encourage you to understand privacy implications when using the Service. If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, please send us an email to [email protected].