1. Personal Information
We may receive Personal Information about you directly from you and automatically through your use of the Software. In this Policy, “Personal Information” means any information relating to an identified or identifiable individual.
Account information. When you use the Software, you may provide us with account information for processing, such as your username and account label.
Transaction information. When you submit a transaction using the Software, you may provide us with transaction information for processing, such as the sending address, receiving address, token amount, date, and time.
Communications. If you contact us about the Software, we may receive your account information, contact information, and the time, date, and content of your message and any attachments.
Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.
2. How We Use Personal Information
A. How We Use Personal information
We use Personal Information we receive through the Software as necessary for the following purposes:
Providing the Software. We use Personal Information to operate, maintain, and provide features of the Software.
Communicating with you. We use Personal Information to contact you for administrative and informational purposes, such as to respond to your inquiries, or to inform you about changes to our terms, conditions, and policies.
Other business purposes. We use Personal Information for compliance, risk management, and other business purposes, such as audits, security, compliance with applicable laws and regulations, fraud monitoring, and prevention.
B. Our Use of European Personal Information
If you are located in the European Economic Area, we only process your Personal Information when we have a valid legal basis to do so, including when:
You have consented to the use of your Personal Information.
We need to use your Personal Information to provide you with the Software, for example to give you access to the Software or to respond to your inquiries.
We need to use your Personal Information to comply with a legal obligation, such as a to comply with a court order.
We have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to monitor and prevent fraud. We only rely on our legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
The Software does not use any cookies.
3. How We Share Your Personal Information
Except as described in this Policy, we will not disclose your Personal Information collected on the Software to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
When you submit a Stacks transaction using the Software, your transaction information will be transmitted to the Stacks blockchain and publicly available via the Stacks blockchain. Transaction information includes the sending address, receiving address, token amount, date, and time.
When you submit an account label using the Software and you have opted to use a Gaia storage hub maintained by Hiro, the account label may be stored in encrypted format on a third-party cloud storage provider.
If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
4. Third Party Services
We use certain physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. It is important that you maintain the security and control of your credentials, and not share your passwords or private keys with anyone.
6. Your Rights and Choices
You have several rights and choices with regard to our use of your Personal Information. You may, of course, decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Software. If you wish to access, amend, or delete any other Personal Information we hold about you, you may contact us using the contact details at the end of this Policy. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, as permitted under applicable data protection law.
A. Your European Privacy Rights
If you are located in the European Economic Area, you have additional rights described below.
You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.
You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time, and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
B. Your Cookie Choices
The Software does not use any cookies.
7. Use of Software by Minors
8. International Visitors
Hiro uses servers hosted in the United States and is intended for users in the United States. If you choose to use the Software from regions of the world with laws governing data collection and use that may differ from U.S. law, please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. By using the Software you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
If you are located in the European Economic Area, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission (e.g., Canada), use contractual protections for the transfer of Personal Information, or transfer to recipients who have certified to the Privacy Shield or adopted Binding Corporate Rules. For more information about how we transfer Personal Information outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required or permitted by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of Software provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.
11. Contact Us
Hiro Systems PBC
101 West 23rd Street Ste 224
New York, NY 10011