Privacy Policy

Last updated: August 1, 2024

This Privacy Policy is part of the Pictor Network’s Terms of Service at https://docs.pictor.network/terms-of-service/. All terms, conditions, and terminology are consistent with the Terms of Service; and the Terms of Service are incorporated into this document by reference.

This Policy governs the use of the Pictor Network website at https://pictor.network/ and the associated tools and services. Collectively, the website and the associated tools and services are referred to as the “Services” in these terms. The operator may offer other tools and services.

The Services do not include outside websites or platforms that may be linked or interconnected to the Services. Such outside platforms may have their own terms of service, which control all transactions on such platforms.

Pictor Network Foundation operates the Services. It and its subsidiaries are referred to in this document as the “foundation”, “operator“, we”, “our”, or “us”.

For the purposes of this Policy, “you” and “your” refer to you as the Services user.

The Blockchain

Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and comprise digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to change once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ that usually replicate the ledger), there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.

This means that by design, a blockchain’s record cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain cannot be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens), it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this requires you to execute such transactions using your wallet’s private key.

In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit, or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event we learn that we have collected personal data from an individual under the age of 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and you are aware that your child has provided personal data to the Services, please contact us so that we may remove such data. 

Note that we cannot delete information stored on public cryptographic blockchains.

Data Collection and Usage

Information Provided by You and Others

Information and content provided by you: We collect the content, communications, and other information you provide when you use our Services, including when you create an account, initiate the use of the Services, create or share content, and message or communicate with others. This information may include, but is not limited to:

  • Name
  • Email

Financial information: In order to transfer funds, you may need to provide us and our third-party financial providers or partners with certain account and other payment information, such as information needed to make payment via wire, electronic checks, cryptocurrency, foreign currency, or any other payment methods. You may agree to your personal and financial information being transferred, stored, and processed by such third parties in accordance with their respective privacy policies.

Your usage: We collect information about how you use our Services, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency, and duration of your activities.

Information about transactions made on our Services: If you use our Services for transactions of any kind, we collect information about them.

Things others do and information they provide about you: We also receive and analyze content, communications, and information that other people provide when they use our Services.

Cookies

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

Device Information

As described below, we collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.

Information we obtain from these devices may include:

Device attributes: Information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

Device operations: Information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

Identifiers: Unique identifiers, device IDs, and other identifiers.

Network and connections: Information such as the name of your mobile operator or ISP, language, time zone, IP address, connection speed, and, in some cases, information about other devices that are nearby or on your network.

Cookie data: Data from cookies stored on your device, including cookie IDs and settings.

Information from partners.

Service Usage Data

When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you with the Services, debug issues, and provide support.

On the Blockchain, the following data may be stored:

  • Addresses of externally owned accounts
  • Transactions made
  • Token balances

The data will be stored on the Blockchain. Given the technological design of the blockchain, this data will become public and it will not likely be possible to delete or change the data at any given time.

In our web servers, we will store the following data:

  • Addresses of externally owned accounts
  • Transactions made

Log Data:

  • The Internet protocol address (“IP address”)
  • Transaction id/Hash

Tracking and Uses

We use the information we have (subject to choices you make) as described below to provide and support the Services. Here’s how:

Provide, personalize, and improve our Services

We use the information we have to deliver our Services, including to personalize features and content.

  • Information across devices: We connect information about your activities on different devices to provide a more tailored and consistent experience.
  • Location-related information: We use location-related information to improve our Services.
  • Product research and development: We use the information we have to develop, test, and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.
  • Ads and other sponsored content: We use the information we have about you – including information about your interests, actions, and connections – to select and personalize ads, offers, and other sponsored content that we show you.

Provide measurement, analytics, and other business services

We use the information we have (including your activity on our Services) to help advertisers and other partners measure the effectiveness and distribution of their ads and services and understand the types of people who use their services and how people interact with their websites, apps, and services.

Promote safety, integrity, and security

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.

Communicate with you

We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our Policies and Terms. We also use your information to respond to you when you contact us.

Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services do not recognize it for tracking purposes.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the Services to provide content, ads (including personalized ads), or functionality, or to measure and analyze ad performance, in or through the Services. These third parties include:

Retention

The Services may retain the information we collect about you for as long as you maintain an account with the Service.

To request that information collected about you be deleted, please contact us at the email provided in this policy. A valid request must include sufficient information to identify your personal data. 

Note that we cannot delete information stored on public cryptographic blockchains.

Sharing

The Services only share information about you with others as follows:

We employ other companies to perform functions on our behalf, such as service providers that assist in the administration of the Services and our advertising and marketing efforts, identity verification services, data analytics companies that help us target our offerings, marketing partners, and payment providers. We may need to share your information with these companies. These partners may access this information so long as you have an account on the Services.

We may also transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization, or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.

We will also share your information with third-party companies, organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our Terms of Service, meet any enforceable government request, defend against legal claims or protect against harm our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your data, give you an opportunity to consent to such changes. Any third party with whom we share your data will be required to provide the same or equal protection of such data as stated in our Privacy Policy.

To operate the Services, we share information about you as needed with our service providers, including financial institutions, 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 Services. The information is only shared so long as you have an account on the Services.

We routinely share information with companies closely related to us – our “affiliates” – for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights under this Privacy Policy and we will be responsible for our affiliates’ conduct related thereto.

We may share information about you with Singapore, or international regulators, MAS (Monetary Authority of Singapore) where we believe doing so is required or appropriate to comply with any laws, regulations, or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas.

The Services may contain links to third-party websites and may redirect you to third-party websites. These sites include, among others, service providers who have a relationship with the operator. Third-party websites are not under our control, and we are not responsible for any third-party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes, or updates. The inclusion or access to these websites does not imply an endorsement by the operator, or of the provider of such content or services, or of any third-party website. Please be aware that when you enter a third-party website, any information you provide, including financial information, is subject to the Terms of Service and Privacy Policy of that website.

Opt-Out

If you wish to stop receiving marketing or promotional communications or to opt out of the 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 [email protected] 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 Services.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact

If you have comments or questions about the Privacy Policies of the Services, contact [email protected].

Changes

The Services may change their privacy policy at any time. Check this page for the latest.