Privacy Policy

Privacy Policy

DAO Labs Privacy Policy

  1. SM Labs Pte. Ltd., a Singapore based corporation registered under number 202145029K and having its registered address at 160 Robinson Road, 24-09, Singapore (068914) (hereinafter “DAO Labs”, also “We” or “us”), is a consulting agency and software provider. This privacy policy will explain how we use the personal data collected from you when you use one of the DAO Labs Social Mining Platforms. DAO Labs is the controller of your personal data provided to Us, meaning the entity which decides on how and what for your data is processed.

 

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website, and accessing and using the Social Mining Platform and the DAO Labs Services, you are accepting and consenting to the practices described in this Privacy Policy.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use DAO Labs Services and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the DAO Labs Services offered through the Social Mining Platform. By using the Social Mining Platform and the DAO Labs Services, you agree to the collection and use of information in accordance with this Privacy Policy. 

The Social Mining Platform and the DAO Labs Services are hereinafter referred to as the “DAO Labs Services”.

 

Topics:

1 What data do we collect?

2 How do we collect your data?

3 How will we use your data?

4 What is the legal base for processing your data?

5 How do we store and protect your data?

6 Storing period

7 Sharing your personal data with third parties

8 Automated decision-making

9 What are your data protection rights?

10 What are cookies?

11 How do we use cookies?

12 What types of cookies do we use?

13 How to manage your cookies

14 Privacy policies of other websites

15 Changes to our privacy policy

16 How to contact us
 

  1. What data do we collect?

Data Collection

We require people who register to access and use our DAO Labs Services to give us certain contact information and information necessary for provision of our services.

Depending on the services chosen, as to identify users of the Social Mining Platform and improve services, you may be asked to provide the following personal identifiable information:

  • Names, birthdates, addresses, phone numbers, email addresses, government identification numbers and copies of government identification documents, face photos, IP addresses, digital wallet address, browser fingerprints, cookie and device identifiers, usage data, and location data. 

  • In some cases, we may also collect scans of facial geometry (“Biometric Data”). We retain Biometric Data until the identity verification and/or fraud prevention purposes have been satisfied or for any shorter period required by applicable law, at which point the Biometric Data is permanently destroyed.

If you believe that someone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at our contact email as specified below.

We will hold the above information for as long as is necessary in order to provide you with the DAO Labs Services, deal with any specific issues that you may raise or otherwise as is required by the applicable law.

With regard to each of your visits to our Social Mining Platform and access to the DAO Labs Services we may automatically collect the following usage data:

  • information about your visits, including the full Uniform Resource Locators (URL) clickstream to, through and from the DAO Labs websites (including date and time);

  • products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and

  • technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

  • Information regarding the provision of DAO Labs Services we might receive from any other sources;

  • Public information from social media accounts connected to the platform: Twitter (number of followers, number of likes, name and screen name, profile description), Reddit (Karma, number of followers, name and display name), Telegram (user ID, username, first name), Github and Bitbucket (name, username, company, blog, bio, list of public repositories).

We may receive information about you from publicly available sources. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
 

  1. How do we collect your data?

You directly provide DAO Labs with most of the data we collect. We collect data and process data when you:

  • Register online and use the DAO Labs Services.

  • Provide your data for KYC and AML purposes;

  • Voluntarily complete a Client survey or provide feedback on any of our message boards or via email.

Additionally, we may receive information about you from publicly available sources or from Service Providers.

 

  1. How will we use your data?

DAO Labs collects your data so that the we and/or our Clients can:

  • Process your requests, manage your account;

  • Email you our newsletter. Users can opt out of this feature at any time through the platform; 

  • Verify your identity to comply with our Client’s KYC and AML requirements;

  • To respond to inquiries, comments, feedback or questions;

  • To manage our relationship with our users, which includes sending administrative information relating to DAO Labs Service and changes to our terms, conditions, and policies, and asking users to leave a review or take a survey;

  • To analyse how you interact with DAO Labs Service and provide, maintain and improve the content and functionality of the Social Mining Platform and our customer relationships and experiences, develop our business and inform our marketing strategy;

  • To administer and protect our business and the Social Mining Platform, prevent fraud, criminal activity, or misuses of our the Social Mining Platform, and to ensure the security of our IT systems, architecture and networks (including troubleshooting, testing, system maintenance, support and hosting of data); and

  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties, and recover debts due to us.

 

DAO Labs will share this data with the Client responsible for the platform instance you sign up to so that they may offer you their personalized community tasks and rewards. Your data will not be shared across platform instances. 

The processing is necessary to perform our contract with our Clients.

Collecting your personal data helps us provide you with a secure, smooth, efficient, and customized experience. Generally, we use personal data to create, develop, operate, deliver, and improve our services, content and advertising, and for loss prevention and anti-fraud purposes.

We use the information we collect to provide you with services as specified in our DAO Labs User Agreement. We may also use the information to contact Clients and prospects to further discuss their interest in our company, the services we provide, ways we can improve our services, and send information such as announcements of promotions and events regarding DAO Labs or our partners.

We may also email you a newsletter and/or updates about the Services or the company. You can easily opt out of receiving these communications by clicking the hyperlink at the bottom of each message, or at any time by contacting us at info@daolabs.com 

We may also use Personal Data for purposes set out in the https://community.daolabs.com/terms/ that govern our relationship with you and the Client. As stated above, DAO Labs may also collect information on your IP address, your web browser and device, your interactions with DAO Labs’s website as well as your location information (broadly referred to as “usage data”). This data collection enables us to analyze the use of our website so as to improve user experience.
 

  1. What is the legal base for processing your data?

Your data will be processed based on your consent to the processing activity. By registering on the Social Mining Platform, you agree with the use of your personal data as stated in this Privacy Policy. You have the right to withdraw consent at a later time.

You may ask Us not to process your personal data for a particular purpose, or to access such information, by contacting Us. Please note, however, that you shall remain liable for any fees or costs incurred at the time of the withdrawal of your consent to process your personal data and that your withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given your consent for processing Personal Data for one or more specific purposes.

Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with or between you and our Clients and/or for any pre-contractual obligations thereof.

Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.

Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

  1. How do we store and protect your data?

DAO Labs securely stores your platform data in a AWS RDS database located in Frankfurt, Germany.

The communication internally between our servers (e.g. between application server and database) is handled via secure socket layer (“SSL”) to provide AE-256 encryption and all information between our servers and your browser is handled via SSL (up to 256-bit encryption, depending upon your browser), providing an industry-standard level of protection for data in-transit.

You should always make sure that your browser can validate the Website’s certificate.

All encrypted data is signed using a message authentication code (MAC) so that the underlying value cannot be modified once encrypted.

We also implement an advanced security method based on dynamic data and encoded session identifications and host the Services in a secure server environment using preventive, detective and corrective technology and processes to safeguard information from attackers. Finally, we require unique usernames and passwords that must be entered each time a Client logs on. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data.

The security of your personal information is important to us. When you enter sensitive information our registration or order forms, we encrypt that information using transport layer security (TLS) technology. We also encrypt any information entered within the platform once users log into their accounts. If you have any questions about security on our website and DAO Labs Services, you can contact us at info@daolabs.com.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website and DAO LabsServices, you are responsible for keeping this password confidential.

Your passwords are stored on our servers in encrypted form using a one-way hashing algorithm.

Please be reminded that you must protect any passwords or other credentials associated with your account for the services provided, and take full responsibility for any use of the account under your password. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our website or DAO Labs Site, although we will do our best to protect your personal data. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We do not distribute or share any of your personal information, except as outlined in this Privacy Policy (see below), or as may be required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.

 

  1. Storing period

We shall store your personal data for as long as it is necessary in order to provide you with the DAO Labs Services on our website, deal with any specific issues that you may raise or otherwise as it is required by the applicable law to comply with our legal obligations (in particular, but not limited to tax purposes).

We have established internal policies for the deletion of data from your account following termination of your subscription to the service. Personal data whose retention period has expired or whose purpose of processing has been served, are deleted, destroyed, blocked or anonymized.We keep your personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your personal Data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

  1. Sharing your personal data with third parties

We may disclose and/or share your personal information to third parties in the following events and with the following persons:

  • With Google Analytics (for the purpose of analyzing the visits to our site);

  • i We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation;

  • We may share your personal information with Service Providers to verify your identity;

  • to keep you up-to-date on the latest service announcements, updates, special offers or other information that we think you’d like to hear, either from us, our business partners or third parties.

  • in order to enforce or apply our DAO Labs User Agreement and any other relevant agreements;

  • We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us;

  • We may share your information with our business partners to offer you certain products, services or promotions;

  • When you share personal information or otherwise interact in the public areas of the Platform with other users, such information may be viewed by all users and may be publicly distributed outside;

  • We may disclose your personal information for any other purpose with your consent.

  • or to protect the rights, property, or safety of DAO Labs, our Clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or

  • as otherwise outlined in this Privacy Policy.

The personal data may also be disclosed to our external data processor, as well as our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers.

We will not otherwise provide your personal data to a third party without obtaining your prior consent.
 

  1. Automated decision-making

Your data is not subject to automated decision-making, including profiling.
 

  1. What are your data protection rights?

DAO Labs would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

Your rights under the EU and UK GDPR 

The right to access - You have the right to request DAO Labs for copies of your personal data. We may charge a reasonable fee for the administrative costs of complying with the request if it is manifestly unfounded or excessive; or an individual requests further copies of their data following a request.

The right to rectification - You have the right to request that DAO Labs correct any information you believe is inaccurate. You also have the right to request DAO Labs to complete information you believe is incomplete.

The right to erasure — You have the right to request that DAO Labs erase your personal data, provided it does not go against any conditions set in the Terms of Service.

The right to restrict processing - You have the right to request that DAO Labs restrict the processing of your personal data, provided it does not go against any conditions set in the Terms of Service.

The right to object to processing - You have the right to object to DAO Labs’s processing of your personal data, where you have a particular reason for wanting the restriction as set out in GDPR.

The right to data portability - You have the right to request that DAO Labs transfer the data that we have collected to another organization, or directly to you, provided it does not go against any conditions set in the GDPR.

The right to withdraw your consent - You have the right to withdraw your consent on using your personal Ddata. If you withdraw your consent, we may not be able to provide you with access to the Social Mining Platform and to the DAO Labs Services.

You may ask us not to process your personal data for a particular purpose, or to access such information, by contacting us at the email address specified below. Please note, however, that you shall remain liable for any fees or costs incurred at the time of the withdrawal of your consent to process your personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:

Contact us at: info@daolabs.com

If you think your rights are not respected, you can lodge a complaint with the regulator.

For any other questions regarding your rights or if you believe that someone has provided us with your personal information and you would like to request that it be removed from our database, you can contact our data protection officer via this email:  privacy@daolabs.com 

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

 

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the United Kingdom or in the European Economic Area (EEA), please contact your local data protection authority in the UK or in the EEA.

 

California Privacy Rights Disclosures

If you are a consumer located in California, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This section provides additional details about the personal information we collect and use for purposes of CCPA.

How we collect, use, and disclose your personal information

Section 1 above describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the How Will We Use Your Data section. We share this information as described in the Sharing Your Personal Data With Third Party section.

 

Your CCPA Rights and Choices

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

 

Exercising the right to know

You may request the following information about the personal information we have collected about you:

  • the categories and specific pieces of personal information we have collected about you;

  • the categories of sources from which we collected the personal information;

  • the business or commercial purpose for which we collected the personal information;

  • the categories of third parties with whom we shared the personal information; and

  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

Exercising the right to delete

‍You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.

 

Exercising the right to opt-out from a sale

You may request to opt out of any “sale” of your personal information that may take place. 

 

Non-discrimination

The CCPA provides that you may not be discriminated against for exercising these rights.

 

To submit a request to exercise any of the rights described above, contact our privacy department at privacy@daolabs.com

 

Children's Privacy

DAO Labs Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

 

  1. What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information,  about the cookies used on our website, please refer to our Cookie Policy, which forms part of this Privacy Policy. 


 

  1. How do we use cookies?

DAO Labs uses cookies in a range of ways to improve your experience on our website:

  • Keeping you signed in

  • Understanding how you use our website

  • Memorize your platform preferences

 

  1. What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality - DAO Labs uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. The following first-party cookies are used:

  • Analytics cookie;

  • CSRF token for protection against attacks;

  • Tour cookie;

  • Session ID cookie;

  • Browser local storage cookie.

 

  1. How to manage cookies?

You can set your browser not to accept cookies, and you are shown a one-time consent you can refuse. However, in a few cases, some of our website features may not function as a result.
 

  1. Privacy policies of other websites

The DAO Labs Social Mining Platform and website may, from time to time, contain links to other third-party websites or to our Service Providers to verify your identity.

If you follow a link to any of these websites, please note that these websites have their own privacy policies (including, as the case may be, landing pages of other DAO Labs products or services; i.e. other than DAO Labs Site) and that we do not accept any responsibility or liability in respect of these policies.

Please check these policies before you submit any personal data to these websites.
 

  1. Changes to our privacy policy

DAO Labs keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on March 27th, 2022.

We will let you know via email and/or a prominent notice on our Platform, prior to the change becoming effective and update the "Last updated" date at the top of this clause.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

  1. How to contact us

If you have any questions about DAO Labs’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@daolabs.com