Privacy Notice
This Privacy Notice
Please carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with your access to and use of the Platform. This Privacy Notice explains which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on. We handle your data in line with this Privacy Notice and strive to comply with applicable data protection laws.
Interpretation
Unless otherwise provided in this Privacy Notice, capitalised terms used in this Privacy Notice have the meaning determined in the MIDL Terms of Use (the “Terms”). You should read the Terms carefully as they affect your obligations and legal rights. In this Privacy Notice, “personally identifiable information”, “personal data”, and “personal information” are synonyms. They refer to any information that identifies or can reasonably identify you, either directly or indirectly. The terms “business”, “controller”, “personally identifiable information”, “personal data”, “personal information”, “process”, “processor”, “service provider” shall have the same meaning as in and be inclusive of similar concepts under applicable data protection legislation.
Contact Details
We, MIDL LABS Inc, a company established under the laws of the State of Delaware, are a data controller (business) for the data collected under this Privacy Notice, meaning we determine how and why your data is processed. If you have any questions about this Privacy Notice or your data processing, please contact us at: [email address].
Our Principles
While processing your personal data, we stick to the following principles:
Lawfulness
We endeavor to process personal data in accordance with the applicable data protection laws and only on the basis of the appropriate legal grounds.
Transparency
We endeavor to make the processing activities transparent and understandable for you, including by providing you with all reasonably necessary information regarding the processing.
Purpose Limitation
We process your data only for the purposes it was collected. If we establish any other purpose, we will inform you reasonably in advance.
Control
We try to give you as much control over your data as reasonably feasible, taking into account the available functionality.
CIA Triad
We make efforts to comply with the best practices applicable to the development and maintenance of our security systems to ensure ongoing confidentiality, integrity and availability of your personal data.
Disclosure Accountability
If we disclose personal data to any person, we will do our best to ensure that such person will comply with the terms of the applicable data protection laws and this Privacy Notice.
Type of Data
The categories of personal data collected depend on how you interact with us, use the Platform, and the requirements of applicable laws. We collect and process the following types of personal data:
Wallet Data
This includes Wallet addresses, which are public blockchain addresses associated with your Wallets, and associated transaction data, which may include information about transaction ID, amount, status, time and date, etc. While a Wallet address alone does not identify a specific individual, when combined with other data (such as a name, nickname or email address), it may enable identification. As a result, such combined data could be considered personal information. However, since we do not process any additional information, your Wallet Data is typically not personally identifiable for us.
Analytical Data
This may include Internet protocol (IP) address, device details, operating system and browser information, session counts and other data regarding your use of and interactions with the Platform, collected automatically via cookies or similar technologies. The Analytical Data is collected via (i) Google Analytics, operated by Google Ireland Limited and its affiliates, including Google LLC (“Google”); and (ii) Vercel solution, operated by Vercel Inc. and its affiliates (“Vercel”). Google and Vercel gather information by means of cookies, which are, in effect, small data files placed on your device to recognize it during the Platform interactions or visits. They use unique identifiers and, in some cases, may qualify as personal data as they can uniquely identify a device’s user without revealing their real identity. With respect to Analytical Data, Google and Vercel act as our data processors. However, if they use this data for their own purposes, they act as independent data controllers, and we are not responsible for their actions. You can learn more about how they process personal data in their privacy policies: Google’s privacy policy and Vercel’s privacy policy.
reCAPTCHA Data
This may include Cascading Style Sheets (CSS) data defining web page layout and design, installed plug-ins, JavaScript objects used for dynamic content, clicks and cursor movements, device or browser language, date, and time settings, as well as other hardware and software information. The reCAPTCHA Data is collected via reCAPTCHA solutions, operated by Google, which gathers information by means of cookies. Please note that we cannot identify you as a particular individual based solely on the information provided by Google. More information regarding reCAPTCHA solution is available here. With respect to the reCAPTCHA Data, Google acts as our data processor (service provider). However, if it uses this data for its own purposes, Google acts as an independent data controller (business), and we are not responsible for its actions.
Marketing Data
This includes your email address.
Referral Data
This includes your referral link and code. When you participate in our referral program, we may assign you a unique referral code, made up of random letters and numbers, to identify you as a user sharing the referral link or code with others to use the Platform or join specific activities. Invited users also receive their own unique code for internal identification as referred users.
Contact Data
This may include name, contact details (such as email address, Telegram and Discord account handles), social media (such as X (Twitter), Telegram channel), and other data, depending on what information you provide to us. Please do not provide personal data unless it is reasonably necessary or requested by us. Note that we may also collect certain other information, which may be required under the applicable laws.
Communication Channels Data
When accessing or participating in our Communication Channels (e.g., X (Twitter), Discord, Telegram), you may provide personal data such as nicknames, names, photos, messages, comments, and other shared information. Additionally, the operators of the Communication Channels may automatically generate certain anonymised statistical and analytical data regarding the use of the Communication Channels. Under applicable laws, we may act as a data controller (business) or joint controller of this data. If we are deemed a joint controller, you may exercise your data protection rights with both us and the respective operator of the Communication Channel. However, we can only assist with processing operations explicitly covered in this Privacy Notice.
Data Use
The personal data is processed as follows:
Wallet Data
We use the Wallet Data (i) to ensure the Platform operation and enable you to use its functionality; (ii) to comply with the applicable laws and regulations; and (iii) to analyse the Platform usage and improve its functionality, prevent and detect fraud or abuse, as well as safeguard the security of the Platform and its users.
The lawful basis for such data processing is (i) the performance of a contract with you; (ii) if you act on behalf of an entity, our legitimate interest to ensure the use of the Platform by the entity you represent; (ii) our legal obligation to comply with the applicable laws; and (iii) our legitimate interest in analysing usage, improving functionality, and ensuring the Platform’s and its users’ security.
Analytical Data
We use the Analytical Data (i) to operate the Platform; (ii) to enhance your browsing experience by improving its functionality, usability, user flow, and interface; (iii) to analyse the Platform usage and your interactions with it; (iv) to prevent and detect fraud or abuse; and (v) to safeguard the security of the Platform and its users.
The lawful basis for such data processing is (i) the performance of a contract with you; and (ii) our legitimate interest to (i) ensure the security of the Platform and its users; (ii) to analyse the use of the Platform; and (iii) to improve the Platform functionality and user experience.
reCAPTCHA Data
We use the reCAPTCHA Data (i) to determine whether you are a real person; and (ii) to protect the Platform and our users from abusive and malicious bots and spam.
The lawful basis for such data processing is our legitimate interest in achieving the stated purposes.
Marketing Data
We use the Marketing Data to provide you with marketing and newsletter emails concerning the latest developments, news, and insights related to the Platform, our products and services.
The lawful basis for such data processing is your consent provided by subscribing to receiving our newsletter.
Referral Data
We use the Referral Data to enable your participation in our referral program, track invited users, and accrue due Rewards to you.
The lawful basis for such data processing is the performance of a contract with you. If you are an invited user, the lawful basis for your data processing is our legitimate interest to ensure a proper participation in our referral program by the Platform user, who invited you.
Contact Data
We use the Contact Data to respond to your inquiry and, where applicable, discuss and perform potential collaboration requests.
The lawful basis for such data processing is our legitimate interest to respond to your inquiry, and, where relevant, taking steps to enter into a contract upon your request or the performance of such a contract.
Communication Channels Data
We use the Communication Channels Data (i) to communicate with visitors, participants, and subscribers; (ii) to handle requests and inquiries received via the Communication Channels; and (iii) to gather statistical insights on audience reach and engagement.
The lawful basis for such data processing is our legitimate interest in achieving the stated purposes. If you intend to enter into a contract with us, the processing is also based on the necessity to take steps to enter into a contract upon your request or the performance of such a contract. However, beyond the data processing outlined in this Privacy Notice, we have no control over how the Communication Channels handle your personal data in connection with your use of their services.
Processing Period
As a general rule, your personal data is kept as long as it is necessary for the purposes it was collected. It may be retained longer if required to meet our legal obligations, in relation to legal proceedings, or to protect our rights and legitimate interests or those of third parties. The storage periods are as follows:
Wallet Data
We do not set a retention period for the Wallet Data that is not personal, and we are not able to identify any particular individual with such Wallet Data. If the Wallet Data becomes identifiable, it will be retained for six (6) years after the completion of the transactions to which such data relates. Note that due to the nature of a blockchain, the Wallet Data may be stored permanently on the applicable blockchain, not by us, and may be accessed and viewed by any person at any time. For more details, refer to the ‘Your Information and Blockchain’ section of this Privacy Notice below.
Analytical Usage Data
Technical Analytical Data, such as (IP) address, device details, operating system and browser information, is typically stored during the active user session or shortly after it ends. We do not set a retention period for the Analytical Data that does not allow us to identify any individual, such as aggregated analytical reports. If and to the extent we become able to identify any specific individual, we will update this Privacy Notice and set a specific processing period for this Analytical Data.
reCAPTCHA Data
For up to six (6) months. Please note that Google may retain certain data longer than outlined herein. You can learn more about data use and retention periods in Google’s privacy policy.
Marketing Data
As long as you remain a subscriber. You can unsubscribe from marketing emails at any time by (i) contacting us, or (ii) clicking the unsubscribe button at the bottom of each marketing email. Then your email address will be removed from our marketing database. Please note that administrative or service-related communications (like email verifications or maintenance notifications) are not considered marketing and may not include an unsubscribe option.
Referral Data
As long as you use the Platform, and for six (6) years thereafter.
Contact Data
For six (6) years from the last date when you contacted us regarding the same matter. However, if our collaboration begins following your request, such as by entering into a contract, we will retain the data for the duration of the collaboration and for six (6) years after its conclusion, or longer if any outstanding obligations, including confidentiality obligations, remain.
Communication Channels Data
We do not set retention periods for statistical and analytical data, as it does not allow for the identification of any individual. Any other data is stored as long as they are not deleted by either you or the respective operator of the Communication Channel.
Data Sharing
General
We do not sell or rent out your data. We may share it in line with this Privacy Notice, applicable laws, the Terms, or with your consent. Appropriate measures will be taken to protect your data during such transfers.
Recipients
Given the purposes outlined above, your personal information is shared with the following categories of recipients: (i) Affiliates; (ii) marketing, support, technical, legal, and compliance teams; (iii) hosting service providers; (iv) email delivery systems; (v) security and analytical solution providers; (vi) government authorities, upon their request or if necessary to comply with our legal obligations; (vii) another entity if we sell or otherwise transfer the Platform or its parts; and (viii) other third-party solutions, which may be from time to time integrated in relation to the Platform. Please note that data that was put into a blockchain will be accessible to any person.
Your Information and Blockchain
Please kindly note that the Wallet Data interacts with a decentralised blockchain network: essentially, you enter this data to the blockchain using your Wallet each time you make a blockchain transaction or interact with blockchain smart-contracts. We do not control nor operate blockchain networks. This means that due to the structure of the blockchain network, certain rights or abilities may be limited. It also means that your Wallet Data is publicly available to any person who has access to the blockchain. Please be aware that any transaction within the blockchain network is irreversible and information put into the blockchain cannot be deleted or changed. The ultimate decision whether to transact on a blockchain or carry out any transactions rests with you.
Automated Decision-Making
Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. We do not make any automated decisions based on your personal data. If we intend to process your personal data by any automated means, we will do our best to inform you about the same prior to such processing.
Data Subject Rights
Verification
In case you wish to exercise your data subject rights, we may request certain information from you to verify your identity and confirm that you are entitled to exercise such rights.
Blockchain Data Processing
Please note that when interacting with blockchain networks, you may not be able to fully exercise certain rights under applicable data protection laws regarding your Wallet Data. For example, we may be unable to delete, correct, or restrict your Wallet Data. For more details, refer to ‘Your Information and Blockchain’ section of this Privacy Notice.
Data Subject Rights
According to the applicable legislation, you may have the following rights:
Right to Access
You can request to see if we process your personal data. If we do, you can ask for details about the processing, such as data processed, purposes, recipients, and data source.
Right to Correction
You can request to correct or complete any incomplete or inaccurate data. We may need to verify the accuracy of the new information you provide.
Right to Deletion
You can request the deletion of your personal data if we no longer need it, or we must erase it to comply with the law. We may not always be able to fulfil your request due to legal or technical reasons, which will be explained in our response.
Right to Withdraw Consent
You can withdraw your consent at any time if we are processing your data based on your consent.
Right to Manage Your Marketing Preferences
If we send or intend to send marketing materials to you, you may ask us to stop processing your data for such purpose.
Right to File a Complaint
You can file a complaint with a supervisory authority if we violate your rights or legal obligations. The competent authority may depend on your location.
Third-Party Services
The Platform may provide access to or integrate with certain Third-Party Services, including Wallets, websites, decentralised applications, or plugins. These Third-Party Services act as independent data controllers in relation to your Personal Data, and your use of them is governed solely by their own terms and privacy policies. By accessing any Third-Party Services, you acknowledge and agree that you are leaving the Platform, and we do not control, endorse, or assume any responsibility or liability for such Third-Party Services or your interactions with them. You are strongly encouraged to review the applicable terms and privacy policies of Third-Party Services you use to understand how your personal data is collected, used, and protected.
Personal Data of Children
The Platform is not intended for children under 18 years (or older if local laws set a higher age). We do not knowingly collect or use personal data from children. If we learn that a child has provided us with personal information, it will be promptly deleted. Parents or guardians who believe their child’s data has been collected should contact us.
Modifications and Updates
This Privacy Notice is under regular review, and may be updated at any time. If any changes to this document are made, we will change the “Last Updated” date and version number at the top of this Privacy Notice. Please review this Privacy Notice to check for the updates.