Euler Privacy Policy
Updated and effective: 28 August 2024
Introduction
The Euler Foundation is committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) describes how Euler and its affiliates (“we”, “us”, or “our”), might collect, use, and/or share your personal data when you access our company websites, including but not limited to, euler.finance (including the Euler app) and its sub-domains, and euler.foundation and its sub-domains, and all of our other properties, products, and services (collectively the “Services”).
For the purposes of this Policy, personal data is any data related to an identified or identifiable individual. Your use of the Services is subject to this Policy as well as our Terms of Use. If you do not agree with the terms of this Policy, do not access or use these Services, or any other aspect of our business.
What Personal Data We Collect
When you visit our company websites and use our Services, we may collect the following data:
Publicly available blockchain data when you connect your non-custodial wallet to the Services. When you connect your non-custodial blockchain wallet to the Services, we collect and log your publicly-available blockchain address in order to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
Information from localStorage and other tracking technologies. We and our third-party services providers may access and collect data from localStorage, mobile deviceID, cookies, web beacons, and other similar technologies to provide and personalise the Services and features of the Services for you across sessions.
Direct Communications that you send to us. Whenever you reach out to us through email, social media, or other support channels like Twitter, Discord, or Telegram, or engage in surveys or questionnaires, we will receive the data and communications you share. It's important to note that we will not try to link any of this data to your wallet address, IP address, or any other personal details.
Information from job applicants. When you apply for a position with us, we collect all data you provide through our Jobs form, including name, email phone, work and immigration status, and any other resume, cover letter, or free form text you include.
How We Use Your Data
As the operator of the Websites and Services, we take the protection of your personal data very seriously. We may use your personal data for the following purposes:
User support and communication. We may use the data we collect to provide you with support and to answer any requests you may have about the Services, and to share information with you about our Services.
Providing services if applicable. We use the data we collect to provide, maintain, customise and improve our Services and features of our Services. We may use this data in an aggregated form, to compile information across multiple users.
Safety and security. We may use the data we collect to protect against, investigate, and stop fraudulent, unauthorised, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users.
Legal and regulatory compliance. We may use the data we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
Due diligence processing. If applicable, we may use the data we collect to process your job application (or other relevant counterparty due diligence required).
Data anonymization and aggregation. We may aggregate or anonymize your personal data, so it no longer identifies you as an individual. We may use this aggregated or anonymized data for statistical analysis, research, or other purposes to improve our Services and better understand our customer base.
Other. If we need to use your personal data for any other purpose, we will ask you for consent and will use your data only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.
You may opt-out of direct marketing communications by writing to us at [email protected]. Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.
We may use personal data relevant to any legal claims, disputes, or regulatory inquiries to comply with applicable laws and regulations. This includes using such data to investigate or address claims or disputes relating to the use of our Services, or as required by regulators, government entities, and official inquiries.
We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (such as web beacons, pixels, and scripts) (collectively, “Cookies”) to provide you with certain functions on our Services and help collect data. This section explains how we use Cookies to collect information about the way you use our Services and how you can control them.
How We Use Cookies
We use Cookies to track how you use our Services by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Services. We may combine the information we collect from Cookies with personal information that we have collected from you to learn more about how you use our Services to improve it.
Types of Cookies
We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Services can be grouped into the following categories:
Strictly Necessary: These Cookies are necessary for the Services to work properly. They include any essential authentication and authorization Cookies for our Services.
Functional: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Services, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
Performance/Analytics: These Cookies allow us to collect certain information about how you navigate the Services and services running on your device. They help us understand which areas you use and what we can do to improve them.
Targeting: These Cookies are used to deliver relevant information related to our Services to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our Services. Some of these types of Cookies on our Services are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our Services.
How to Control and Delete Cookies
Cookies can be controlled, blocked, or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access the Services, you will need to manage your Cookie preferences across these environments.
Find out how to manage Cookies on popular browsers:
Google Chrome, available at https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop\&hl=en
Microsoft Edge, available at https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Mozilla Firefox, available at https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-webServices-preferences
Microsoft Internet Explorer, available at https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Opera, available at https://www.opera.com/help/tutorials/security/privacy/
Apple Safari, available at https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
If you are using a mobile device to access the Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
Please note that if you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to our services available through the Services. We are not responsible for your inability to use our Services or any degraded function you may experience that may be caused by your settings and choices regarding Cookies.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
How We Share Your Data
We may share or disclose the data we collect in the limited circumstances as described below:
With regulators, government entities, and law enforcement to comply with our legal obligations
With service providers and vendors who may assist us in providing, delivering, and improving the Services (hosting provider, mailing provider, etc)
With blockchain security analytics providers to ensure the safety and security of our Services and to screen your wallet for any prior illicit activity
To enforce your agreements with us, including this Privacy Policy, and to respond to claims that your use of the Service violates any third-party rights
We require such third parties to use the personal data we share with them only for the purpose for which the data was transferred and not to retain it for longer than is required for fulfilling the said purpose.
International Data Transfers
We, along with our affiliates, subsidiaries, and trusted third-party providers, may handle your personal information in countries outside of your own. The data privacy laws in these countries may differ from, and potentially offer less protection than, those in your home country.
When transferring your personal information internationally, and in accordance with applicable legal requirements, we will implement appropriate safeguards to ensure your data is adequately protected and compliant with relevant data protection laws. For further details on how we manage international data transfers, please contact us through the information provided in the “Contact Us” section of this policy.
This section will ensure that users are informed about how their data is managed when transferred internationally, in line with the rest of the privacy policy.
Security
The security of your data is important to us, and we take reasonable security measures to prevent the loss, misuse, unauthorised access, modification, or disclosure of your personal data under our control. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
However, given the inherent risks, we cannot guarantee absolute security and give no guarantee that such loss, misuse, unauthorised access, modification, or disclosure will not occur. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.
Age limitations
Our Services are not intended for use by anyone under the age of 18. If we learn that we have collected personal data from an individual under 18 without verification of parental consent, we will delete that information promptly. If you believe we may have any information from or about a person under 18, please contact us.
Links
There may be links from our Sites to other websites and resources provided by third parties. This Privacy Policy applies only to our Sites. Accessing those third-party websites or sources requires you to leave our Sites. We do not control those third-party sites or any of the content contained therein, and you agree that we are in no circumstances responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.
Changes to the Policy
Please note that we may modify this Privacy Policy at any time without any prior notice. The revised Policy will be effective immediately from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We encourage you to regularly review the latest version of this Privacy Policy
Retention of Personal Information
We retain the personal data we collect only for as long as necessary to fulfil the purposes for which it was collected, to provide our Services, to resolve disputes, to enforce our agreements, and to comply with legal obligations. This period may vary depending on the nature of the data and the reasons for collecting it, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements.
Contact information
If you have any questions, comments, or concerns regarding our Privacy Policy, please contact us at [email protected].
Acknowledgment of Risks
By using the Euler Protocol, you acknowledge that you have read, understood, and agree to this privacy policy.
Updated and effective: 28 August 2024