Privacy Policy

The Privacy Policy (“Policy”) explains how Mozaic and its affiliates collect, use, and share personal information, as well as your options for doing so.

Please read this Policy carefully and email us at contact@mozaic.finance if you have any issues.

 

This Policy governs the Sites and the Services (in each case, as defined in the Terms of Use). Do not access or use the Services, Sites, or any other aspect of our business if you do not agree with the terms of this Policy.

 

What We Collect

When you interact with our Services, we may collect the following information:

  • Contact information, such as your name, email address, physical address, and country of residence.
  • Financial information such as your Avalanche network address, cryptocurrency wallet information, transaction history, trading data, and fees paid.
  • Transaction Information, which includes information about the transactions you conduct on our Services, such as the type of transaction, the amount of the transaction, and the timestamp.
  • Correspondence, including feedback, questionnaire and other survey responses, and information you provide to our support teams, including through our help chat or social media messaging channels.
  • Online identifiers such as usernames, geolocation or tracking information, browser fingerprints, operating systems, browser name and version, and IP addresses.
  • Usage and Diagnostics Data, such as conversion events, user preferences, crash logs, device information, and other data collected via cookies and similar technologies.
  • Other sources, such as public databases, may be used to obtain information about you if required or permitted by applicable law. In order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities, we may combine information collected from these sources with information collected from this Site.
  • Cookies and other tracking technologies provide data. We, as well as third parties we authorise, may use cookies, web beacons, and other similar technologies to remember your preferences, track the use of our Sites, including our mobile applications, and collect information about how you use the Services and how we interact with you. Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, device information, date or time stamp, and clickstream data, as well as information about your interactions with the communications we send you, may be included in this information.
  • IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, device information, date or time stamp, and clickstream data, as well as information about your interactions with the communications we send you, may be included in this information. This automatically collected log information may be combined with other information we have about you. You can set your web browser to either reject cookies or notify you when cookies are sent. Please be aware that some parts of our Services may not function properly if you do so.

 

How We Use Information

We used your information as directed by you, including any applicable terms in the Terms of Use, and as required by law. The information we collect may also be used for the following purposes:

  • Providing Services and Features We may use the information we collect to provide, personalise, maintain, and improve our products and Services, including as described in the Terms of Use. This includes using data to:
  1. manage our business while operating, maintaining, customising, measuring, and improving our services;
  2. create and update user accounts;
  3. perform internal operations required to provide our Services, such as troubleshooting software bugs and operational issues;
  4. enforcing our agreements with third parties and dealing with violations of our Terms of Service or agreements for other products or services; and
  5. adhere to all applicable security laws and regulations.
  • Customer Service. We may use the information we collect to provide customer support, including but not limited to:
  1. Questions directed to the appropriate customer service representative.
  2. Investigate and respond to user concerns; and
  3. Monitor and improve our customer service responses and processes.
  • Development and research. We may use the information we collect to improve your experience through testing, research, analysis, and product development. This enables us to improve and enhance the safety and security of our services, as well as to improve our ability to prevent the use of our services for illegal or improper purposes and to develop new features and products related to our services.
  • Compliance with the law and regulations. We may check your personal information against third-party databases and public records to confirm your identity. We may use the information we collect to investigate or resolve claims or disputes relating to the use of our Services, as permitted by applicable law, or as requested by regulators, government entities, and official inquiries.
  • Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications about our Services, features, promotions, surveys, news, updates, and events, as well as managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by clicking “unsubscribe” in any marketing email we send you or by contacting us at contact@mozaic.finance.

 

How We Share & Disclose Information

In the following cases, we may share your information:

  • With Your Permission. For example, you may authorise us to share personal information with third parties for marketing purposes. These uses will be governed by their respective privacy policies.
  • To fulfil our legal obligations. We may share your information in the following circumstances: (a) to cooperate with government investigations; (b) when required to do so by a subpoena, court order, or similar legal procedure; (c) when we believe in good faith that disclosure of personal information is necessary to prevent harm to another person; (d) to report suspected illegal activity; or (e) to investigate violations of our Terms of Use, agreements for other products or services, or any other applicable policies.
  • With Service Providers and/or Other Third Parties We may share your information with service providers or other third parties that assist with business and compliance operations, such as marketing and technology.
  • During a Business Transition. We may share or transfer some or all of your information if we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities.
  • Aggregated or De-identified Data. We reserve the right to share aggregated or anonymized data with third parties for their own purposes.

 

Data Retention

To view or update your information, please contact us at contact@mozaic.finance. We keep your information for the duration of your use of the Services and keep it for a minimum of five years to comply with our legal obligations or to resolve disputes. Subject to this policy’s Additional Disclosure. If you stop using the Services, we will not use your information for any other purpose, nor will we sell or share it with third parties, unless it is necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this policy. Despite the foregoing, we will retain information pertaining to your initial deposit during the course of your use of the services and use such information in accordance with this Policy.

 

Security

We maintain administrative, technical, and physical safeguards to protect the personal information we keep from unauthorised access or disclosure, and we require appropriate safeguards from our third-party service providers. No system can be completely secure. As a result, while we take precautions to protect your information, we cannot guarantee that your information, searches, or other communication will always be secure. You are responsible for all Mozaic protocol activity involving any of your Avalanche network addresses or cryptocurrency wallets.

 

Age Limitations

To the extent permitted by applicable law, we do not permit anyone under the age of 18 to use our Services or Sites. If you discover that someone under the age of 18 has unlawfully provided us with personal information, please contact us at contact@mozaic.finance, and we will take steps to delete such information, close any such accounts, and, to the greatest extent possible, prevent the user from using our Services.

 

Changes to This Policy

If we make any changes, we will update the Last Updated date above. We encourage you to review this Policy on a regular basis in order to stay informed. If we make significant changes, we will provide additional notice, such as via the email address specified in your account or through the Services or Sites.

Online Tracking Opt-Out Guide
We use Google and other companies that use tracking technology, as do many other businesses online. These services rely on tracking technologies like cookies and web beacons to collect information about your browsing activities, interactions with websites, and the device you use to connect to the Internet directly from your device. There are several ways to avoid having your online activity and device data collected by these services, which we have summarised below:

  • Blocking cookies in your browser. Most browsers allow you to delete or reject cookies, including interest-based advertising cookies. To do so, go to your browser’s settings and follow the instructions. Unless you change your settings, many browsers accept cookies by default. Visit www.allaboutcookies.org for more information on cookies, including how to see what cookies have been set on your device and how to manage and delete them.
  • Blocking the use of advertising IDs in your mobile settings. Your mobile device settings may allow you to restrict the use of the advertising ID associated with your device for interest-based advertising purposes.
  • Using privacy plug-ins or browser extensions. By using a browser with privacy features, such as Brave, or installing browser plugins, such as Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third-party cookies or trackers, you can prevent our websites from setting cookies used for interest-based advertising.
  • Platform opt-outs The following advertising partner provides opt-out features that allow you to opt out of the use of your information for interest-based advertising:

    Google: https://adssettings.google.com.
  • Tools for opting out of advertising. You can also limit the use of your information for interest-based advertising by participating companies by using the opt-out options set forth below. Because these opt-out mechanisms are device or browser specific, you must opt out on each browser and device that you use.

    Digital Advertising Alliance: http://optout.aboutads.info
    Network Advertising Initiative: http://optout.networkadvertising.org/

 

Notice to California Residents (“CCPA Notice”)

The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide this CCPA Notice to California residents to explain how we collect, use, and share their personal information, as well as the rights and choices we provide California residents regarding our handling of their personal information.

 

CCPA Scope and Exclusions

This CCPA Notice, including our Privacy Practices and your Privacy Rights, is only applicable to California residents whose interactions with us are limited to:

visiting our consumer websites; 

and signing up for email alerts; and

This CCPA Notice does not apply to the following types of personal information that we collect, use, or disclose:

Individuals who provide information to us in order to initiate or complete the trading process on our platform, who are subject to the notice set forth in the Additional Disclosure section of this Policy; 

or 

representatives of businesses seeking to obtain our products or services, or providing products or services to us.

 

Privacy Practices

We do not “sell” the personal information (as defined in the CCPA) we collect for monetary value (and will not sell it without providing a right to opt out). Like many companies, we may use third-party cookies for our advertising purposes. If you would like to learn how you may opt out of our use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide section of this Policy.

 

Privacy Rights

The following rights are granted to individuals under the CCPA:

  • Information. You have the right to request information about how we collected, used, and shared your personal information over the last 12 months. Please see the What We Collect section of this Policy for more information on the personal information we have collected in the last 12 months, including the sources. We collect this information for the business and commercial purposes described in the How We Use Information section of this Policy. We share this information with the third-party categories described in the How We Share and Disclose Information section of this Policy.
  • Access. You have the right to request a copy of the personal information we have on file for you.
  • Deletion. You have the right to request that we delete any personal information we have collected or maintained about you.

How to Submit a Request
To request access to or deletion of personal information, please send an email to contact@mozaic.finance.

Identity Verification
Before providing a substantive response to a request to access or delete personal information, we are required by the CCPA to verify the identity of the individual submitting the request. When you submit a request, we will ask you to verify your identity.

Authorised Agents
Residents of California can appoint a “authorised agent” to submit requests on their behalf. We will require a written authorisation from the authorised agent to confirm that authority.

Notice to European Union Residents (“GDPR Notice”)
We are providing this GDPR Notice to European Union (“EU”) residents in accordance with the General Data Protection Regulation (the “GDPR”) to explain how we collect, use, and share their personal data (as defined in the GDPR), as well as the rights and choices we offer EU residents regarding our handling of their personal information.

We process personal data for the purposes described in the section of this Policy titled “How We Use Information.” As an EU resident, you have the following rights in relation to the processing of your personal data:

  • You have the right to receive information about your personal data that we process, as well as the following information: (a) the processing purposes; (b) the categories of personal data being processed; (c) the recipients or categories of recipients to whom the personal data have been or are being disclosed, in particular recipients in third countries or international organizations; (d) if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration; (e) the existence of a right to rectification or deletion of your personal data, to restricting the processing of your personal data or to objecting to such processing; (f) the existence of a right of appeal to a supervisory authority; (g) if the personal data is not collected from you, all available information about the origin of the data; (h) the existence of automated decision making and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject; and (i) in the case of the transfer of personal data to a third country or an international organization, on the appropriate safeguards in relation to the transfer.
  • You have the right to request the immediate rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data, taking into account the purposes of the processing, by providing a supplementary statement.
  • You have the right to request the immediate deletion of personal data relating to you, and we are required to do so if one of the following conditions is met:

    • (i) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
    • (ii) you revoke your consent on which the processing was based under Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing;
    • (iii) you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for processing or you object to the processing pursuant to Article 21(2) of the GDPR;
    • (iv) your personal data has been processed unlawfully;
    • (v) the deletion of your personal data is necessary to fulfill a legal obligation under EU law or the law of the member states to which we are subject;
    • (vi) the personal data have been collected in relation to information society services provided in accordance with Article 8(1) of the GDPR. If we have made personal data public and are required to erase personal data in accordance with Article 17(1) of the GDPR, we will take appropriate measures, including technical measures, taking into account available technology and implementation costs, to notify controllers who process the personal data you have requested the erasure by such controllers of any links to, copies or replications of, such personal data.
      The rights set forth in the preceding paragraph do not apply to the extent that processing is required (A) to exercise the right to free expression and information; (B) to fulfil a legal obligation imposed by EU law or the law of the member states to which we are subject; or (C) to assert, exercise, or defend legal claims.
  • You have the right to request us to restrict processing if one of the following conditions is met: (1) the accuracy of the personal data is contested by you, for a period of time that enables us to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose to delete the personal data and instead requests the restriction of the use of your personal data; (3) we no longer need your personal data for the purposes of processing, but you do need it to assert, exercise or defend legal claims; or (4) you have objected to the processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate interests of our company override your legitimate interests.
  • You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without hindrance, provided that the processing is based on a consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means. When exercising your right to data portability, you have the right to have your personal data transferred directly by us to another controller, to the extent that such transfer is technically feasible.
  • You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions. We will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.
  • You have the right to revoke your consent to the processing of your personal data at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.

Please send an email to contact@mozaic.finance if you want to assert your rights to information, correction, deletion, or restriction of processing, object to data processing, or revoke your consent to data processing. If you believe that the processing of your personal data violates the GDPR, you can file a complaint with a supervisory authority, preferably in the member state of your habitual residence, your place of employment, or the alleged infringement.

 

Additional Disclosure for Our Consumers and Customers (“Additional Disclosure”)

This Additional Disclosure governs the collection, use, and sharing of personal information provided by users to us in order to initiate or complete the trading process on the Mozaic protocol. If there are any provisions in this Additional Disclosure that conflict with those in other sections of this Policy, this Additional Disclosure will take precedence.

The types of personal information we collect and share can include:

  • Contact details
  • IP addresses
  • Trading history 
  • Cryptocurrency balances and wallets 
  • Conversion events

Notwithstanding anything to the contrary in this Policy, when you are no longer our customer, we continue to share your information as described in this Additional Disclosure.

 

Reasons We Can Share Your Personal Information

We need to share users’ personal information in order to run certain aspects of Mozaic and our business. The following are examples of whether we share your personal information, the reasons for sharing your personal information, and whether you can limit this sharing.

  • We share users’ personal information for routine business purposes, such as processing and matching orders, responding to court orders, and conducting legal investigations. You cannot limit our ability to share this information.
  • We share personal information about users for marketing purposes, such as offering you our products and services. You cannot limit our ability to share this information.
  • We do not share users’ personal information for joint marketing with financial companies.
  • We do not share users’ personal information for our affiliates’ everyday business purposes.
  • We do not share users’ personal information for our affiliates to market to you.
  • We share users’ personal information for nonaffiliates to market to you.

How Does Mozaic Protect My Personal Information?
We use federally mandated security measures to protect your personal information from unauthorised access and use. Computer safeguards, as well as secured files and buildings, are among these measures.

 

How Does Mozaic Collect My Personal Information?

We collect your personal information when you deposit cryptoassets in the Mozaic protocol, make trades with the Mozaic protocol, or withdraw cryptoassets from the Mozaic protocol, for example.

We may also obtain your personal information from other companies.

 

Why Can’t I Limit All Sharing?

You have the right under applicable laws to limit only (a) sharing for affiliates’ everyday business purposes, (b) affiliates from using your information to market to you, and (c) sharing for nonaffiliates to market to you.

State and regional laws, as well as individual companies, may provide you with additional rights to limit sharing. See the preceding section for more information on your legal rights under state law.

As used in this Additional Disclosure section, “affiliates” refer to companies that share common ownership or control; “nonaffiliates” refer to companies that do not share common ownership or control; and “joint marketing” refers to a formal agreement between non-affiliated financial companies to market financial products or services to you.

 

Contact Us

If you have any questions about this Policy or wish to exercise any of your statutory rights, please contact us. We will get back to you as soon as possible. You can reach us at contact@mozaic.finance or at the mailing address listed below:

Privacy Officer

Mozaic Finance.