Privacy Policy
Effective as of November 27, 2024.
This Privacy Policy describes how FirstMate Labs, Inc.
(“FirstMate,” "we",
“us” or "our) processes personal
information that we collect through our digital or online properties or
services that link to this Privacy Policy (including as applicable, our
website, mobile application and social media pages) as well as our
marketing activities, live events and other activities described in this
Privacy Policy (collectively, the “Service”). FirstMate
may provide additional or supplemental privacy notices to individuals
for specific products (such as Sensible) or services that we offer at
the time we collect personal information.
Index
Personal information we collect
Information you provide to us or that we generate about you. Personal
information you may provide to us through the Service or otherwise
includes:
Third-party sources. We may combine personal information we receive from
or about you with personal information falling within one of the
categories identified above that we obtain from other sources, such
as:
Public sources, such as blockchains, government agencies, public
records, social media platforms, public blockchains, and other publicly
available sources.
Service providers. We may combine personal information we receive from
or about you with personal information we receive from service providers
that provide services on our behalf or help us operate the Service or
our business.
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, such as:
For more information concerning our automatic collection of
data, please see the Tracking technologies section below.
Tracking Technologies
Cookies and other technologies. Some of the automatic collection
described above is facilitated by the following technologies:
How we use your personal information
Service delivery and operations. We may use your personal information
to:
Service improvement and analytics. We may use your personal information
to analyze your usage of the Service, improve the Service, improve the
rest of our business, help us understand user activity on the Service,
including which pages are most and least visited and how visitors move
around the Service, as well as user interactions with our emails, and to
develop new products and services. For example, we may use Posthog and
Google Analytics for this purpose. For Google Analytics, you can learn
more about Google Analytics and how to prevent the use of Google
Analytics relating to your use of our sites here:
https://tools.google.com/dlpage/gaoptout?hl=en.]
Marketing and advertising. We, our service providers and our third-party
marketing and advertising partners may collect and use your personal
information for marketing and advertising purposes.
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
Interest-based advertising. We and our third-party advertising
partners may use cookies and similar technologies to collect information
about your interaction (including the data described in the Tracking
technologies section above) with the Service, our communications and
other online services over time, and use that information to serve
online ads that they think will interest you. This is called
interest-based advertising. We may also share information about our
users with these companies to facilitate interest-based advertising to
those or similar users on other online platforms.
Compliance and protection. We may use your personal information
to:
Data sharing in the context of corporate events, we may share certain
personal information in the context of actual or prospective corporate
events – for more information, see How we share your personal
information, below.
To create aggregated, de-identified and/or anonymized data. We may
create aggregated, de-identified and/or anonymized data from your
personal information and other individuals whose personal information we
collect. We make personal information into de-identified and/or
anonymized data by removing information that makes the data identifiable
to you and we will not attempt to reidentify any such data. We may use
this aggregated, de-identified and/or anonymized data and share it with
third parties for our lawful business purposes, including to analyze and
improve the Service and promote our business.
Cookies and similar technologies. In addition to the other uses included
in this section, we may use the Cookies and similar technologies
described above for the following purposes:
Retention. We generally retain personal information 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
may consider factors such as 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.
How we share your personal information
Your choices
Access or update your information. If you have registered for an account
with us through the Service, you may review and update certain account
information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related emails
by following the opt-out or unsubscribe instructions at the bottom of
the email, or by contacting us. Please note that if you choose to
opt-out of marketing-related emails, you may continue to receive
service-related and other non-marketing emails.
Blocking images/clear gifs: Most browsers and devices allow you to
configure your device to prevent images from loading. To do this, follow
the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information
for interest-based advertising through the following
settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use
of the advertising ID associated with your mobile device for
interest-based advertising purposes.
Do Not Track. Some Internet browsers may be configured to send “Do Not
Track” signals to the online services that you visit. We currently do
not respond to “Do Not Track” signals. To find out more about “Do Not
Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal
information to provide certain services. If you do not provide the
information we identify as required or mandatory, we may not be able to
provide those services.
Linked third-party platforms. If you choose to connect to the
Service through or with a third-party platform or service, you may be
able to use your settings in your account with that platform or service
to limit the information we receive from it. If you revoke our ability
to access information from a third-party platform or service, that
choice will not apply to information that we have already received from
that third party. Other sites and services
The Service may contain links to websites, mobile applications,
and other online services operated by third parties. In addition, our
content may be integrated into web pages or other online services that
are not associated with us. These links and integrations are not an
endorsement of, or representation that we are affiliated with, any third
party. We do not control websites, mobile applications or online
services operated by third parties, and we are not responsible for their
actions. We encourage you to read the privacy policies of the other
websites, mobile applications and online services you
use.
Security
We employ technical, organizational 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.
International data transfer
We are headquartered in the United States and may use service
providers that operate in other countries. Your personal information may
be transferred to the United States or other locations where privacy
laws may not be as protective as those in your state, province, or
country.
Children
The Service is not intended for use by anyone under 18 years of
age. If you are a parent or guardian of a child from whom you believe we
have collected personal information in a manner prohibited by law,
please contact us. If we learn that we have collected personal
information through the Service from a child without the consent of the
child’s parent or guardian as required by law, we will comply with
applicable legal requirements to delete the information.
Changes to this Privacy Policy
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 or other appropriate means. Any modifications to this Privacy
Policy will be effective upon our posting the modified version (or as
otherwise indicated at the time of posting). In all cases, your use of
the Service after the effective date of any modified Privacy Policy
indicates your acknowledging that the modified Privacy Policy applies to
your interactions with the Service and our business.
How to contact us
Additional information for California residents
To privacy@holdsensible.com, California residents may send us
requests for information regarding to whom we have disclosed certain
personal information (as defined under the Shine the Light, Cal. Civ.
Code Section 1798.83) during the preceding calendar year for their own
direct marketing purposes and the categories of personal information
disclosed. 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.
Personal information we collect
Information you provide to us or that we generate about you. Personal
information you may provide to us through the Service or otherwise
includes:
Contact data, such as your first and last name, salutation, email address, and mailing addresses.
Profile data, such as the wallet address and username and password that you may set to establish an online account on the Service.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Blockchain transaction data, such as information relating to or needed to complete your transactions on or through the Service, including wallet address, trading activity, deposits, withdrawals, account balances, token holdings, transaction number, transaction sender and recipient, transaction amount, and transaction history.
Financial data, such as your virtual currency or wallet account balances and other associated information.
Other data not specifically listed here, which
we will use as described in this Privacy Policy or as otherwise
disclosed at the time of collection.
Third-party sources. We may combine personal
information we receive from or about you with personal information
falling within one of the categories identified above that we obtain
from other sources, such as:
Public sources, such as blockchains, government agencies, public records, social media platforms, public blockchains, and other publicly available sources.
Data providers, such as information services and data licensors.
Partners or linked third-party services, such as
marketing partners and third parties with which we integrate or
otherwise connect in order to provide the Service, such as Privy,
Coinbase and third-party blockchains and other services. If you link or
connect the Service with another third-party service, we may receive
data such as Blockchain transaction data and Financial data and other
information associated with your account on that third-party service.
Please refer to the relevant partner or linked third-party services
operator for their relevant privacy practices.
Service providers. We may combine personal information
we receive from or about you with personal information we receive from
service providers that provide services on our behalf or help us operate
the Service or our business.
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, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such
as your interactions with our email, text or other
communications (e.g., whether you open and/or forward emails) – we may
do this through use of pixel tags (which are also known as clear GIFs),
which may be embedded invisibly in our emails.
For more information concerning our automatic collection of data, please
see the Tracking technologies section below.
Data about others. We may offer features that help
users invite their friends or contacts to use the Service, and we may
collect contact details about these invitees so we can deliver their
invitations. Please do not refer someone to us or share their contact
details with us unless you have their permission to do so.
Tracking Technologies
Cookies and other technologies. Some of the automatic collection
described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session-replay technologies, such as those provided by Posthog that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Posthog at https://posthog.com/privacy.
Chat technologies, such as those provided by e.g., Atlas Support that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. Atlas Support and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.
Software development kits. An SDK is third-party
computer code that may be used for a variety of purposes, including to
provide us with analytics regarding the use of Service, to integrate
with third-party platforms, and to add features or functionality to the
Service.
For information concerning your choices with respect to the use of
tracking technologies, see the Your choices section, below.
How we use your personal information
We may use your personal information for the following purposes or as
otherwise described at the time of collection:
Service delivery and operations. We may use your
personal information to:
provide the Service and operate our business;
enable security features of the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate; and
provide support for the Service, and respond to your requests,
questions and feedback.
Service personalization, which may include using your
personal information to:
understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate
webpages.
Service improvement and analytics. We may use your
personal information to analyze your usage of the Service, improve the
Service, improve the rest of our business, help us understand user
activity on the Service, including which pages are most and least
visited and how visitors move around the Service, as well as user
interactions with our emails, and to develop new products and services.
For example, we may use Posthog and Google Analytics for this purpose.
For Google Analytics, you can learn more about Google Analytics and how
to prevent the use of Google Analytics relating to your use of our sites
here: https://tools.google.com/dlpage/gaoptout?hl=en.]
Marketing and advertising. We, our service providers and our third-party
marketing and advertising partners may collect and use your personal
information for marketing and advertising
purposes.
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
Interest-based advertising. We and our
third-party advertising partners may use cookies and similar
technologies to collect information about your interaction (including
the data described in the Tracking technologies
section above) with the Service, our communications and other online
services over time, and use that information to serve online ads that
they think will interest you. This is called interest-based advertising.
We may also share information about our users with these companies to
facilitate interest-based advertising to those or similar users on other
online platforms.
Compliance and protection. We may use your personal
information to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful,
unauthorized, unethical or illegal activity, including cyberattacks and
identity theft.
Data sharing in the context of corporate events, we may
share certain personal information in the context of actual or
prospective corporate events – for more information, see How we share
your personal information, below.
To create aggregated, de-identified and/or anonymized data.
We may create aggregated, de-identified and/or anonymized data
from your personal information and other individuals whose personal
information we collect. We make personal information into de-identified
and/or anonymized data by removing information that makes the data
identifiable to you and we will not attempt to reidentify any such data.
We may use this aggregated, de-identified and/or anonymized data and
share it with third parties for our lawful business purposes, including
to analyze and improve the Service and promote our business.
Cookies and similar technologies. In addition to the
other uses included in this section, we may use the Cookies and
similar technologies described above for the following
purposes:
Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Functionality. To enhance the performance and functionality of our services.
Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
Analytics. To help us understand user activity
on the Service, including which pages are most and least visited and how
visitors move around the Service, as well as user interactions with our
emails. For example, we may use Posthog and Google Analytics for this
purpose. For Google Analytics, you can learn more about Google Analytics
and how to prevent the use of Google Analytics relating to your use of
our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Further uses. In some cases, we may use your personal
information for further uses, in which case we will ask for your consent
to use of your personal information for those further purposes if they
are not compatible with the initial purpose for which information was
collected.
Retention. We generally retain personal information 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 may consider factors such as 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.
How we share your personal information
We may share your personal information with the following parties and as
otherwise described in this Privacy Policy, in other applicable notices,
or at the time of collection.
Affiliates. As applicable, our corporate parent,
subsidiaries, and affiliates.
Service providers. Third parties that
provide services on our behalf or help us operate the Service or our
business (such as hosting, information technology, online chat
functionality providers, customer support, email delivery, marketing,
consumer research and website analytics).
Third parties designated by you and linked third-party services.
We may share your personal information with third parties where
you have instructed us or provided your consent to do so such as the
relevant blockchains and third parties with which we integrate or
otherwise connect in order to provide the Service, such as Privy,
Coinbase and other services. These third parties’ use of the shared
information may be governed by their own privacy policies and/or the
settings associated with any third-party account you link to or
integrate with the Service.
Advertising partners. Third-party advertising companies
for the interest-based advertising purposes described above.
Partners. Third parties with whom we
partner, including parties with whom we co-sponsor events or promotions,
with whom we jointly offer products or services, or whose products or
services may be of interest to you. Our partners’ use of the shared
information may be governed by their own privacy policies.
Professional advisors. Professional advisors, such as
lawyers, auditors, bankers and insurers, where necessary in the course
of the professional services that they render to us.
Authorities and others. Law enforcement, government
authorities, and private parties, as we believe in good faith to be
necessary or appropriate for the Compliance and protection
purposes described above.
Business transferees. We may disclose personal
information in the context of actual or prospective business
transactions (e.g., investments in or financings of FirstMate,
public stock offerings, or the sale, transfer or merger of all or part
of our business, assets or shares), for example, we may need to share
certain personal information with prospective counterparties and their
advisers. We may also disclose your personal information to an acquirer,
successor, or assignee of FirstMate as part of any merger, acquisition,
sale of assets, or similar transaction, and/or in the event of an
insolvency, bankruptcy, or receivership in which personal information is
transferred to one or more third parties as one of our business
assets.
Other users and the public. Due to the nature of
blockchain technologies, any data posted to a blockchain will be visible
to other users of the Service and the public. 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 this information.
Your choices
In this section, we describe the rights and choices available to all
users.
Access or update your information. If you have
registered for an account with us through the Service, you may review
and update certain account information by logging into the
account.
Opt-out of communications. You may opt-out of
marketing-related emails by following the opt-out or unsubscribe
instructions at the bottom of the email, or by contacting us.
Please note that if you choose to opt-out of marketing-related emails,
you may continue to receive service-related and other non-marketing
emails.
Cookies and other technologies. Most browsers let you
remove or reject cookies. To do this, follow the instructions in your
browser settings. Many browsers accept cookies by default until you
change your settings. Please note that if you set your browser to
disable cookies, the Service may not work properly. For more information
about cookies, including how to see what cookies have been set on your
browser and how to manage and delete them, visit www.allaboutcookies.org.
You can also configure your device to prevent images from loading to
prevent web beacons from functioning.
Blocking images/clear gifs: Most browsers and devices
allow you to configure your device to prevent images from loading. To do
this, follow the instructions in your particular browser or device
settings.
Advertising choices. You may be able to limit use of
your information for interest-based advertising through the following
settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device
settings to limit use of the advertising ID associated with your mobile
device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser
from which you wish to limit the use of your information for
interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with
participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured
to send “Do Not Track” signals to the online services that you visit. We
currently do not respond to “Do Not Track” signals. To find out more
about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect
personal information to provide certain services. If you do not provide
the information we identify as required or mandatory, we may not be able
to provide those services.
Linked third-party platforms. If you choose to connect
to the Service through or with a third-party platform or service, you
may be able to use your settings in your account with that platform or
service to limit the information we receive from it. If you revoke our
ability to access information from a third-party platform or service,
that choice will not apply to information that we have already received
from that third party. Other sites and services
The Service may contain links to websites, mobile applications, and
other online services operated by third parties. In addition, our
content may be integrated into web pages or other online services that
are not associated with us. These links and integrations are not an
endorsement of, or representation that we are affiliated with, any third
party. We do not control websites, mobile applications or online
services operated by third parties, and we are not responsible for their
actions. We encourage you to read the privacy policies of the other
websites, mobile applications and online services you use.
Security
We employ technical, organizational 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.
International data transfer
We are headquartered in the United States and may use service providers
that operate in other countries. Your personal information may be
transferred to the United States or other locations where privacy laws
may not be as protective as those in your state, province, or
country.
Children
The Service is not intended for use by anyone under 18 years of age. If
you are a parent or guardian of a child from whom you believe we have
collected personal information in a manner prohibited by law, please
contact us. If we learn that we have collected personal
information through the Service from a child without the consent of the
child’s parent or guardian as required by law, we will comply with
applicable legal requirements to delete the information.
Changes to this Privacy Policy
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
or other appropriate means. Any modifications to this Privacy Policy
will be effective upon our posting the modified version (or as otherwise
indicated at the time of posting). In all cases, your use of the Service
after the effective date of any modified Privacy Policy indicates your
acknowledging that the modified Privacy Policy applies to your
interactions with the Service and our business.
How to contact us
Email:privacy@holdsensible.com
Additional information for California residents
To privacy@holdsensible.com, California residents may send us requests
for information regarding to whom we have disclosed certain personal
information (as defined under the Shine the Light, Cal. Civ. Code
Section 1798.83) during the preceding calendar year for their own direct
marketing purposes and the categories of personal information disclosed.
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.