MAU Accounts DAO adopts the following privacy policy and rules for handling personal data:
(in the text, all terms that start with a capital letter are defined as stated in the Mutual Obligations Accounting Agreement).
1.1. MAU Accounts DAO is committed to protecting the privacy of all Participants. Before using the Services or accessing the Site and other information and/or technical systems and resources supported by MAU Accounts DAO (hereinafter referred to as the “Resources”), you should carefully read this Privacy Policy to familiarize yourself with your rights and what we can do with your personal information.
1.2. All individuals or other entities that use the Resources must join the Mutual Obligations Accounting Agreement, thereby becoming its Participants.
1.3. In the subsequent text of the Privacy Policy, MAU Accounts DAO is referred to as “we”, the user and/or Participant as “you”, or other second person pronouns.
The Privacy Policy defines the types of personal data that we may collect and/or use in the course of providing our Services, as well as how we will use and protect this data.
We recommend that you carefully read and understand the terms of this Privacy Policy. By accessing our Resources, regardless of whether you have joined the Mutual Obligations Accounting Agreement and thereby become a Participant, you express your consent, understanding, and confirmation of the following:
3.1. Based on your own free will and consent, you agree to disclose your Personal data to us;
3.2. You agree to comply with all the provisions and conditions of this Privacy Policy;
3.3. You agree that we may collect information about you when you log into any of the Resources, register on the Resources, join the Mutual Obligations Accounting Agreement, and/or use the Services offered by us;
3.4. You agree to any changes we may make to our Privacy Policy in the future;
3.5. You agree that our partners, affiliated entities, and employees may contact you in connection with services and products that, in our reasonable opinion, may be of interest to you (unless you have expressly stated in writing that you do not wish to receive such information).
4.1. When you use the Resources, you agree to allow us to use cookies to track all of your actions and collect and store all information you leave on the Resources, including, but not limited to, your IP address, location, and other information. For more information on how we use cookies, please refer to our Cookie Policy.
4.2. By using the Services and/or Resources, you provide us with the following categories of information:
4.2.1. Identification information. This information can help us verify if you are authorized to use our Services. It includes, but is not limited to, your name, residential address, mailing address, identity documents, and corresponding numbers issued by competent authorities of various jurisdictions to confirm your identification information, as well as any other information that can help us verify your identity.
4.2.2. Contact information. This information helps us communicate with you during the provision of the Services, including, but not limited to, your phone number, active email address, mailing address, and information related to your debit card and/or accounts with other financial institutions.
4.3. When you use any of the Resources or Services, we may collect additional information to improve the functionality and enhance your experience using our Resources and Services, as well as their security or in compliance with any court order, applicable laws, administrative rules, or any directive from any competent authority of the relevant jurisdiction.
4.4. If you visit any links to third-party websites, pages, content, or platforms that may be accessible through links on the Resources or any link from any of our third-party partners, you must and will be required to agree to and comply with the separate and independent privacy policy of such third parties. This Privacy Policy does not apply to third-party websites, and we do not take any responsibility for the content and activities of such sites, operated by third parties.
We collect your personal data based on:
5.1. Information you provide to us directly when contacting us;
5.2. Information we receive from third parties, such as third-party service providers;
5.3. Information obtained during our business relationship with you;
5.4. Information collected when you use our Resources and Services;
5.5. Information collected from publicly available sources.
6.1. Regarding Personal Data protected by the General Data Protection Regulation (GDPR), you have a number of legal rights related to the Personal Data you store with us, including:
6.1.1. To receive information about the processing of your Personal Data by you and to access the Personal Data you have provided to us. Please note that in some cases we have the right to refuse such requests for access to copies of Personal Data (especially information covered by legal professional privilege).
6.1.2. If your Personal Data is inaccurate or incomplete, you may request us to make corrections. To do so, we may ask you to provide copies of valid identification documents to verify the authenticity of your identification information.
6.1.3. In some cases, you may request us to delete your Personal Data. Please note that under certain circumstances (such as for reasons of public interest, public health, or scientific and historical research), we have the right to retain your Personal Data even if you request its deletion.
6.1.4. In some cases, you may object to the processing of your Personal Data and request us to restrict the processing of your Personal Data. Similarly, in some cases, we have the right to reject your request even if you object or request us to restrict the processing of your Personal Data.
6.1.5. In some cases, you may withdraw your consent for the collection and processing of your Personal Data. In the presence of other legal grounds, we also have the right to continue using or processing without your permission.
6.1.6. Some information we collect about you may include special categories of personal data (such as information about racial or ethnic origin, criminal offenses committed, or suspected criminal offenses). Normally, we request your specific permission to process Personal Data related to these special categories of data. If you do not provide us with this information or object to us processing such information, the consequences may be that we are unable to provide our Services to you.
6.1.7. If you reside in the EEA and have concerns about our processing of your Personal Data that we cannot resolve through our internal procedures, you have the right to lodge a complaint with the data protection authority in your place of residence. Contact information for your local data protection authority can be found at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
6.2. We will consider all requests and complaints received and provide you with timely responses. We may ask you to provide a valid copy of an identification document so that we can fulfill our security obligations and prevent unauthorized disclosure of data. We have the right to charge you a reasonable administrative fee if your request for access to data is clearly unjustified or does not comply with our obligations, or if you ask us to provide additional copies of your Personal Data.
6.3. To facilitate the provision of Services to customers in the EEA, we request explicit consent for the transfer of Personal Data from the EEA outside this territory. If you are an individual located in the EEA and refuse to give consent for such transfer, you will no longer be able to use our Resources and Services.
7.1. When you visit our Resources, we use Google Analytics, which operates with the help of cookies, to monitor our performance and check the effectiveness of online advertising. A cookie is a small set of data that is sent to your browser and stored in the permanent memory of your computer. Cookies can only be saved on your computer when you use it to access our Resources.
7.2. Cookies are typically used to record visitor preferences when viewing the content of our Resources. The information collected through cookies is non-personalized aggregate statistical data and does not include Personal Data.
7.3. Cookies allow the technical system supporting the operation of the Resources and/or the provision of Services to recognize your browser and to store and retrieve the stored information. They cannot be used to obtain your data stored in the permanent memory of your computer, your email address, or your personal data. Most browsers support receiving cookies. You can configure your browser to reject cookies or immediately notify you when you are downloading cookies. However, if you configure your browser to disable cookies, you may not be able to use certain features of our Resources. For more information on how we use cookies and how you can disable them, please refer to our Cookie Policy.
8.1. We use the information we collect from you for the following purposes or in the following ways:
8.1.1. to provide you with our Services;
8.1.2. to identify and confirm your identity when using our Resources or Services;
8.1.3. to improve and enhance the Services and Resources (your information and feedback received by us can help us improve our Services, as well as the functionality and performance of the Resources, so that we can more effectively respond to your requests and needs);
8.1.4. to keep statistics on the usage of our Resources and use it for data analysis;
8.1.5. to account for your personal experience (your information will help us better respond to your personalized needs);
8.1.6. to support transaction processing (your information, both public and private, will not be sold, exchanged, transferred, or otherwise provided to any other company for any reason without your consent, except where expressly done for the purpose of conducting the transactions);
8.1.7. for regular email communication (the email address you provide for order processing may be used to send you information about your orders, as well as informational newsletters, notifications, information about related products or services, etc., that we may send you from time to time);
8.1.8. to communicate with you regarding matters related to your accounts, including requesting any additional information or documents;
8.1.9. to implement security measures to protect your account, including, among other things, conducting two-factor authentication;
8.1.10. to assess your credit risk and other risks in accordance with our defined parameters;
8.1.11. to detect and mitigate fraud risks and other unlawful activities;
8.1.12. to ensure compliance/protection of our rights;
8.1.13. to comply with applicable laws, regulations, and/or orders of competent authorities in relevant jurisdictions;
8.1.14. to achieve other purposes specified in the Mutual Obligations Accounting Agreement, using all lawful means applied to meet such purposes.
8.2. We do not sell, exchange, or otherwise transfer your Personal data, and we do not allow others to collect and use your Personal data; however, we may disclose and transfer your Personal data in the following circumstances:
8.2.1. to our affiliated entities, trusted third parties who assist us in maintaining our Resources, conducting our activities, and/or providing you with Services, provided that such parties agree to and have taken appropriate measures to maintain the confidentiality of such information;
8.2.2. in cases where we believe that the disclosure of relevant information is appropriate or required by any applicable laws, regulations, rules, or court orders or other competent authorities in relevant jurisdictions, as well as necessary to implement our strategies and ensure proper functioning of the Resources, or may be necessary to provide the Services, or to protect the rights, property, or safety of us or others. However, your information will not be provided to third parties for marketing, advertising, or other similar purposes.
8.3. You agree that we have the right to transfer your Personal data:
8.3.1. to members of our group of companies, including our subsidiaries, companies under common control, as well as their respective contractors, affiliated entities, employees, or representatives;
8.3.2. to our suppliers, contractors, and other third parties who help us provide you with the Services;
8.3.3. to entities in connection with any financing, acquisition, merger, or acquisition procedures that involve the disclosure of a specific portion or all of our business or assets;
8.3.4. to competent authorities and government bodies, officials, regulatory authorities, or other third parties – for the purpose of complying with the legislation of relevant jurisdictions, court orders, or other jurisdictional authorities.
9.1. We take appropriate physical, electronic, managerial, and technical measures to protect and ensure the security of your Personal Data. We will do everything possible to ensure that any Personal Data collected through our Resources is not accessible to any third party not affiliated with us. The security measures we can take include, among others:
9.1.1. Physical measures: carriers with your Personal Data will be stored in a securely closed place.
9.1.2. Electronic measures: your Personal Data will be stored in computer systems and data carriers with restricted access.
9.1.3. Management measures: only employees duly authorized by us may access your Personal Data, and these employees must comply with our internal rules regarding the confidentiality of Personal Data.
9.1.4.Technical measures: methods of encryption, such as Secure Socket Layer, may be used to transmit your Personal Data.
9.1.5. Other measures: our network servers are protected by an appropriate firewall.
9.2. If you become aware of any security vulnerabilities on our Resources, please contact us immediately so that we can take appropriate measures as soon as possible.
9.3. Despite the aforementioned technical and security measures, we cannot guarantee that the information transmitted through the Resources is absolutely secure, so we cannot guarantee that the Personal Data you provide us will always be secure. We are not responsible for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your Personal Data, and we are not responsible for compensating for such losses or damages.
10.1. We strive to maintain the relevance, reliability, accuracy, completeness, and timeliness of the personal information we store, as well as to protect its confidentiality and security.
10.2. We store Personal Data only for as long as reasonably necessary for the purposes for which it was collected, or to comply with any applicable legal or ethical reporting or document retention requirements. We will not store your Personal Data in a form that allows the identification of the data subject for longer than is necessary for the lawful purpose or purposes for which we originally collected them, including for the purpose of satisfying any legal requirements, accounting or reporting requirements.
10.3. In order to determine the appropriate retention period for Personal Data, we consider the volume, nature, and confidentiality of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, as well as applicable legal requirements. In some cases, we may anonymize your personal information so that it can no longer be associated with you, and in that case, we will use such information without further notice.
10.4. Upon the expiry of the retention period, we will securely delete or destroy the stored data and require the same from our contractors or third-party providers.
11.1. Our Resources and Services are not intended for individuals who can be defined as minors according to the applicable legislation of the respective jurisdictions. Therefore, if you are under 18 years old, immediately cease any access to our Resources and Services. We reserve the right (but not the obligation) to request proof that you are over 18 at any time. If you are under 18 or if we have reason to suspect that you are under 18 and you cannot prove otherwise, all your use of the Services and access to our Resources, including but not limited to registration, subscriptions, and purchases from us (if available) will be immediately terminated, and you will not be eligible for any refunds.
11.2. We do not knowingly collect Personal data from minors. However, in the conditions of the internet, we cannot determine from our end whether individuals are minors or not. Therefore, parents or guardians are responsible for ensuring that their minors do not access our Resources, use our Services, download Wallets and other applications, access our respective applications, email us, or access our applications by providing us with Personal data without the consent of their parents/guardians. If a parent or guardian becomes aware that a minor has accessed our Sites or provided us with Personal data without their consent, he or she must immediately contact us at legal@mauaccounts.com.
For the sake of convenience and to comply with any changes in the legislation of the respective jurisdictions, we reserve the right to make changes to this Privacy Policy from time to time at our sole discretion without prior notice to you. We may inform you of the changes made to the Privacy Policy by updating and publishing the effective date of the new versions of the Privacy Policy. We may also occasionally issue a notice informing you of the change made to the Privacy Policy, but this is not an obligation for us. You agree to regularly review the Privacy Policy, and if you do not agree with such updates, you must immediately cease access to the Resources and/or use of the Services. You agree that you are solely responsible for being informed of any changes by regularly reviewing this Privacy Policy on our Resources, including the Site.
13.1. If you have any questions or comments, you can send an email to legal@mauaccounts.com. This is the only valid and official email address through which we communicate with you. We are not responsible for any actions or omissions that do not use this method of communication.
13.2. We only provide accurate information through our Resources, including the Site, or using the official feedback address. We are not responsible for any losses incurred due to your reliance on information that was not obtained through the aforementioned means.
13.3. In the event of any disputes arising in connection with this Privacy Policy and your use of our Resources and Services, you should first contact us at legal@mauaccounts.com regarding your issue and make every effort to achieve an amicable resolution of any dispute.
13.4. If you have any questions regarding our Privacy Policy, you can contact us at any time.