June 24, 2021
Your privacy is very important to us. The Fractional Token Company, a Delaware Corporation, (together with its subsidiaries and other affiliated entities, “Fractional”) is committed to maintaining your privacy.
- The types of information we collect
- How we use information we collect
- How we share information we collect
- How we safeguard information we collect
- Other important privacy information
1. Types of Information We Collect
To provide our Services, and facilitate exchanges between users of the Website, we do not obtain personal information directly from you but may obtain information indirectly through electronic communications and third parties (e.g., email, discord, twitter).
We do not save or store any sensitive wallet information, private keys, or transaction details.
Automatically or Passively Collected Information: In addition to information you may directly provide us, we may automatically or passively collect information when you access or use our services,including your IP address, device identifiers, click path, use of our Website and other electronic data. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes. In order to determine whether your computer is supported by our system, we may collect additional technical information, including your operating system and browser, as well as the presence of any software that our Website may require to operate with your computer, or other third party software on your computer.
A “cookie” is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services. By using the Website, you consent to this use.
We may also use so-called "pixel tags" – small graphic images (also know as "web beacons" or "single-pixel GIFS") – to tell us what parts of our website have been visited or to measure the effectiveness of searches customers perform on our Site. Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this policy.
Some web browsers transmit “do-not-track” signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.
We may send email messages that use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphiclinks in the email, or notify us at email@example.com.
Information Related to Your use of the Services: We collect certain information about you when you visit the Website and interact with any of our Services. We collect information about when you useServices, the pages within the Website you visit, the links you click on, and the search terms you use.
2. How We Use Information We Collect
We may use your information for the following commercial purposes:
- Administer, operate, facilitate, and manage your relationship with Fractional and deliver the Services.
- To communicate with you about the Services and target our marketing, advertising and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content and promotional events.
- Provide you with information about our current Services, including onboarding materials, the availability and terms of new fractional NFTs, reminders.
- We also use your information to debug, identify and correct errors;
- On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas ripe for improvement;
- Contact you or, if applicable, your designated representative(s) by post, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with Fractional, including with information and updates about our Services.
In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Fractional’s assets, or other corporate transaction affecting Fractional, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract. If your relationship with Fractional ends, we will continue to treat your personal information, to the extent we retain it, as described in this policy.
3. How We Share Information We Collect
We do not share personal data with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your data.
The manner in which partners, service providers and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize whenone of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your personal information into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.
The primary situations in which we share your data are as follows:
Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Website and the Services.
Affiliates: We do routinely share information with companies closely related to us – our "Affiliates" – for certain purposes under this policy. By "Affiliate," we mean an entity that controls, is controlled by, or is under common control with Fractional , whether the control results from equity ownership, contract, overlapping management or otherwise. In this context, "control" means the ability to replace the officers or directors or otherwise materially influence or control management decisions. Our Affiliates will be entitled to enjoy our rights under this policy and we will be responsible for our Affiliate's conduct under this policy.
4. How We Safeguard Your Personal Information
Security Systems and Processes: We have put in place security systems designed to prevent unauthorized access to or disclosure of Personally Identifiable Information, and we take all reasonable steps to secure and safeguard this Information, including:
- We use industry standard encryption technology for any information we store;
- Fractional employees are required to acknowledge that they understand and will abide by this policy with respect to the confidentiality of Personal Information;
- Where applicable, companies that we do business with agree to abide by this policy and apply similar safeguards to Personal Information;
- We provide access to our databases containing Personal Information on a need-to-know basis only;
- We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems
Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. Please understand, though, that this information should not be construed as a warranty that our security systems are fail proof. Due to the nature of Internet communications and evolving technologies, we cannot provide and we also disclaim assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access
Credit Card Security: Fractional will safeguard the confidentiality and security of the information we obtain from you. This notice describes our policy as it relates to the collection, protection and disclosure of such information resulting from credit card transactions only (which the site does not currently support). Once enabled, Fractional will collect and use information obtained from credit card transactions only for business purposes. The credit card information provided by you to Fractional will be stored in a confidential manner. Our employees may access such information only when there is an appropriate business reason to do so, such as when a refund must be issued back to the credit card. We maintain physical, electronic and procedural safeguards to protect your information, and our employees are required to follow these privacy standards. Transmission of information, including any payment information, is encrypted and protected using TLS/SSL technology. Fractional does not disclose any nonpublic information (such as credit card number and their expiration dates), except as required by law. We disclose information only when it is necessary for the conduct of government business, or under circumstances where disclosure is required by law. Information may also be disclosed for audit purposes, to regulatory agencies or for other general administrative services
5. Other Important Privacy Information
Opting Out of Communications: If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at firstname.lastname@example.org to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Website.
Changing or Deleting Information: All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at email@example.com. If you request, we will take reasonable steps to remove your personal information from our databases. Please understand, however, that certain Personal Information may remain in our databases following the deletion of your account pursuant to our data retention policy.
Data Retention: We retain information we collect for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Website is lost, stolen or used without permission.
Download or Access Personal Information: You can ask us for a copy of your Personal Information,including a copy in machine readable form, by emailing us at firstname.lastname@example.org
Further Resources: If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the FTC’s website.
We Operate in the United States: Fractional is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
European Economic Area Residents: If you are an individual residing in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation (“GDPR”). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, perform a contract with you, take necessary steps prior to performing a contract or at your request, provide customer support, and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, to personalize services you receive, and to protect our legal rights and interests
You give us consent to do so for a specific purpose; or we need to process your data to comply with a legal requirement. If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please email us at email@example.com.
In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the GDPR. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
California Residents: Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business with which the California resident has an established business relationship what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third parties and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by email at firstname.lastname@example.org.
Vermont Residents: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at email@example.com, though we will no longerbe able to provide you Services or access to the Website.
Contact Us: If you have any questions about this policy, the practices of this Website, or your dealingswith this Website, please contact us by email as follows: firstname.lastname@example.org or by contacting us through our discord channel.