Privacy Policy

Last updated: September 9, 2023

The purpose of this website (“Website”) is to facilitate best practices for clear and articulate reporting of on-chain holdings of digital assets by publishing white papers and other materials (each a “Project”).

This privacy policy (“Privacy Policy”) describes our policies and procedures about the collection, use, disclosure and sharing, or other processing of your personal information when you use this website, as well as when you interact with or participate in our events, programs, trainings and our other services or offerings that we may provide now or in the future (collectively, the “Services”). This Privacy Policy applies to activities by owners of this site (collectively “we” or “us”), including activities that we perform for other entities through management services agreements. For purposes of the GDPR, ORGANIZATION is the controller of your personal information.

In this Privacy Policy, “personal information” includes references to “personal data” as defined under applicable laws. Your use of our Website and Services, and any dispute over privacy, is subject to this Policy and the relevant Terms of Use (“Terms”), including the applicable limitations on damages and the resolution of disputes. The Terms are incorporated by reference into this Policy.

Personal Information We Collect

We collect personal information directly from individuals, from third parties, and automatically through the Website and Services. You do not have to provide us your personal information. If you choose not to disclose certain information, however, we will not be able to provide you with access to certain services or features, including news and updates, event registration, programs, or participation in other aspects of our offerings.

Communications

When you communicate with us (via email, phone, through the Website), we may maintain a record of your communication. Information collected may include name, organization, title, email address, and other contact information as well the contents of any communication or messages.

Your Input

We collect and store the information and content that you post to the Website, including your questions, answers, comments, forum postings (if any), and responses to surveys (if any). Please see the section on Publicly Available Information for how the information you post will be viewed on our Website.

Event Registration

When you register for one of our events to participate as an attendee, a speaker or a sponsor, we collect personal information that includes name, company, contact information, and other personal information.

Automatically Collected Information.

We may automatically collect the following information about users’ use of the Website or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; when you open certain emails we send; links you click; your IP address; your country of location; the length of time you visit our Website and or use our Services; and the referring URL, or the webpage that led you to our Website. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see our Cookie Policy for more information about our use of cookies.

De-identified Information

We may de-identify and aggregate certain personal information we collect such that the information no longer identifies or can be linked to a particular user or an individual data subject (“De-identified Information”), subject to the terms of any applicable user agreements. We may use this information to improve our Services, analyze trends, publish research, and for other marketing, research or statistical purposes, and may disclose such information to third parties for these specific purposes.

Contributions to Projects

When you contribute content to one of our Projects (whether on your own behalf or through contributions made as part of your employment services to your employer), we collect and store the information and content that you contribute. This includes the contents of those contributions, as well as information required to confirm the provenance of intellectual property contained in those contributions, and personal information that you make publicly available in the record of the contribution. Some Projects may require additional agreements or information pursuant to their intellectual property policies; in such cases we collect and store information related to your acceptance of those agreements. We may also collect information relating to your participation in technical, governance, or other Project-related meetings.

Other Project-Related Content

The content you provide in relation to Projects may also include materials that you make publicly available in connection with Project development, collaboration and communication, such as on mailing lists, blogs, message channels, Project tracking pages, and/or related services.

Payment Information

To attend events or purchase Services, users may be asked to be directed to a third-party site to pay for their purchases. If applicable, the third-party site may collect payment information directly to facilitate a transaction. We generally only record the result of the transaction and any references to the transaction record provided by the third-party site.

Purposes and Legal Bases for Our Using of Your Personal Information

We use the personal information we collect for our legitimate business interests, which include the following purposes:

Providing our Website and Services

To provide the Services and our Website, to communicate with you about your use of our Website and Services or about Project updates or new Project releases, to respond to your inquiries, provide troubleshooting of the Website and for other purposes to support users and the community.

Operating our Projects

To enable communication between and among open source contributors in the community; to facilitate and document Project governance and technical decision-making; to maintain, and make publicly available on a perpetual basis, records regarding intellectual property provenance and license compliance for Project contributions; and for related activities to further our core purpose of fostering an ecosystem that supports best practices for clear and articulate reporting of on-chain holdings of digital assets. See the “Attribution, Provenance and Integrity” section above for more information.

Event Administration

To plan, organize, and facilitate access to events and related services and activities, and to carry out informative and safe events for participants, including attendees, speakers and sponsors. If you provide us information about disabilities, medical conditions and allergies, we will use this information in order to provide appropriate accommodations for attendees and to ensure their health and safety; we will not use this information for other purposes, unless required by law or as necessary to defend our legal rights. If you request assistance from us for obtaining a visa letter to travel to one of our events and provide us with information required for such assistance (such as your citizenship, date of birth, and passport details), we will use this information in order to assist with providing you a visa letter; we will not use this information for other purposes, unless required by law or as necessary to defend our legal rights.

Personalization

To tailor the content and information that we may send or display to you on Website and in our Services, to offer location customization and personalized help and instructions and to otherwise personalize your experiences.

Marketing and Promotions

For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Projects, Services, events, trainings or other information we think may interest you related to this effort, and, subject to applicable law, our affiliates and managed services entities.

Advertising

For targeting advertising to you on our Website and third-party sites and measuring the effectiveness and reach of ads and services (through third-party ad networks and services).

Analytics

To gather metrics to better understand how users access and use our Website and Services and participate in our Projects; to evaluate and improve the Website, including personalization, to develop new services; and to understand metrics regarding the community health of our Projects. If a user voluntarily provides and explicitly consents to our processing of personal information regarding their demographics and socioeconomics, we process such personal information for the specific purposes for which you have consented.

Compliance

To comply with legal obligations and requests. For example, to comply with laws that compel us to disclose information to public authorities, courts, law enforcement or regulators, maintain records for a certain period, or maintain records demonstrating enforcement and sublicensing of our trademarks and those of our Projects.

Business and Legal Operations

As part of our general business and legal operations (e.g., accounting, record keeping, and for other business administration purposes), and as necessary to establish, exercise and defend (actual and potential) legal claims.

Prevent Misuse

Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of the relevant Terms or this Privacy Policy

Sharing of Personal Information

We disclose personal information as set forth below, and where individuals have otherwise consented:

Publicly Available Information, including Your Contributions to Our Projects.

Your contributions to Projects, and certain of your other Content such as comments and messages posted to public forums, are available to other participants and users of our Projects and of our Services, and may be viewed publicly. In some cases you may be able to provide Project or contribution-related information directly to third-party sites and services; these third parties are independent data controllers and their use of your personal information is subject to their own policies.

Service Providers

We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, contractors and consultants.

Event Participants

If you register for an event, we may ask for your consent to share your personal information with third party sponsors and other participants. We will not share your event information with third parties without your consent.

Legally Required

We may disclose your information if we are required to do so by law (including to law enforcement in the U.S. and other jurisdictions).

Protection of Rights

We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process, enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of us, our contributors, participants in our events or Projects, or others.

Affiliates

The information collected about you may be accessed by or shared with our affiliates (if any), whose use and disclosure of your personal information is subject to this Privacy Policy, unless an affiliate has its own separate privacy policy.

Organizational Changes

We may disclose or transfer information, including personal information, as part of any merger, sale, and/or transfer of our assets, or restructuring of all or part of our business operations, bankruptcy, or similar event, including in negotiations, due diligence, and integrations related to such transactions.

Anonymized and Aggregated Information

We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies, Tracking, and Interest-Based Ads

We and any third-party providers we engage may use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on our Website and across third party sites or online services. We may combine this information with other information we collect about users.

Analytics Tools

We may use internal and third-party analytics tools, including Google Analytics. The third-party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

Data Security

We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

Opt Out of Emails and Other Communications

You may opt out of or withdraw your consent to receive emails from us by using the unsubscribe or opt out mechanisms included in our emails or by emailing legal@sodafinance.xyz.

Retention of Personal Information

We generally keep personal information only for as long as required to fulfill the purposes for which it was collected. In some circumstances, however, we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. In specific circumstances, we may also retain your personal information for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

Children’s Privacy

Except as specifically indicated within this Website, we do not knowingly collect or solicit personal information from anyone under the age of sixteen (16), or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.

Links to Third Party Sites and Services

The Website may contain links to third party sites or online services. Please refer to the privacy policies of the relevant third party websites or services to find out more about how they process and handle personal information.

Your Rights

Access and Amendment

If you have registered with us or created an account on our Website (if accounts are enabled) and wish to access or update certain personal information contained therein, you may do so online by visiting the accounts settings in your respective account. You may also contact our privacy coordinator, as set forth below, to access or amend your personal information.

Additional Rights

Individuals in the European Economic Area (and other jurisdictions where applicable) have additional rights under applicable law:

to obtain a copy of your personal information together with information about how and on what legal basis that personal information is processed;
to rectify inaccurate personal information (including to have incomplete personal information completed);
to erase your personal information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
to restrict processing of your personal information under certain circumstances;
to export certain personal information in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you and the processing is carried out by automated means;
to withdraw your consent to our processing of your personal information (where that processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal);
to obtain or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization; and
to object to our use and processing of your personal information that is conducted on the basis of our legitimate interest. You also have the right to object at any time to any processing of your personal information for direct marketing purposes, including profiling for marketing purposes.

Lodging a Complaint

You also have the right to lodge a complaint with your local supervisory authority for data protection, or privacy regulator.

Submitting a Request

To exercise the above rights or contact us with questions or complaints regarding our treatment of your personal information, contact us at legal@sodafinance.xyz. (Please note that we may request proof of identity and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will respond to your request within the applicable timeframes set out by law.)

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to legal@sodafinance.xyz. We may ask you to verify your California residency.

If you have any questions about our practices or this Privacy Policy, please contact us at lega@sodafinance.xyz, or write to us at:

SoDA Finance

Attn: Legal Department

2340 Francisco St Suite 204

San Francisco, California 94123-1956

Changes to this Privacy Policy

This Policy is current as of the effective date set forth above. If we change our privacy policies and procedures, we will post those changes on this page and/or continue to provide access to a copy of the prior version. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice on our Site or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.