Privacy Policy

Last update: January 1, 2023

I. Introduction

By using the PubliRare website and services, you consent to the following privacy policy.

PubliRare is committed to protecting your privacy. To ensure that you understand how we collect and use personal data as part of the Services, please note the information below.

II. Personal Information We Collect

  1. Personal Information we collect from you

We may collect the following categories of Personal Information directly from you:

  • Identification Information such as first name and last name, account username, company, email, phone number, postal address, cryptocurrency wallet address or other registration-related information;
  • Commercial Activity such as trading activity, order activity, deposits, withdrawals, account balances;
  • Correspondence such as information you provide to us in correspondence, including account opening and customer support;
  • Sensory Information such as images that you upload to your User Profile;
  1. Personal Information we collect automatically

We may collect the following categories of Personal Information automatically through your use of our services:

  • Online Identifiers such as IP address, domain name;
  • Device Information such as hardware, operating system, browser;
  • Usage Data such as system activity, internal and external information related to PubliRare pages that you visit, clickstream information;
  • Geolocation Data.

Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

  1. Personal Information we collect from third parties

We may collect and/or verify the following categories of Personal Information about you from third parties, including service providers and our affiliates:

  • Identification Information such as name, email, phone number, postal address
  • Transaction Information such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you);
  • Financial Information such as bank account information, routing number, credit card number, debit card number;
  • Additional Information at our discretion to comply with legal obligations.
  1. Accuracy and retention of Personal Information

We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

III. How We Use Your Personal Information

We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:

  • Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms of Use. For example, in order to facilitate fiat transfers out of your account, we need to know your financial information.
  • Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
  • Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
  • Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on PubliRare to maintain the security of your account and the PubliRare platform.
  • Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
  • Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
  • Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

IV. How We Share Your Personal Information

We will not share your Personal Information with third parties, except as described below:

  • Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with these service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
  • You authorize us to collect and share with our payments provider Dwolla, Inc. your Personal Information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data. Dwolla’s Privacy Policy is available here.
  • PubliRare Creators (authors or publishers). In some circumstances, PubliRare may share your contact information with PubliRare Creators to facilitate the delivery of Additional Items under the Terms of Use.
  • Affiliates. We may share Personal Information about you with our affiliates in the ordinary course of business and offering our Services to you.
  • Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
  • Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
  • Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
  • Consent. We may share your Personal Information with your consent.

If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.

V. Disclosure of Your Personal Data.

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

  • Third Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.
  • Affiliates. We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
  • Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
  • Legal Rights. Regardless of any choices you make regarding your Personal Data (as described below), PubliRare may disclose Personal Data if it believes in good faith that such disclosure is necessary:
    • in connection with any legal investigation;
    • to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on PubliRare;
    • to protect or defend the rights or property of PubliRare or users of the Service;
    • to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
  • Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

VI. Affected rights for users subject to GDPR

In connection with the data processing presented here, you have the right to:

  • Request information about your personal data processed by us. In particular, you can request information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right to rectification, deletion, limitation of processing or opposition, the existence of the right to complain, the source of their data, if not collected from us, and the existence of automated decision-making including profiling and, where appropriate, meaningful information about their details;
  • Demand the correction of incorrect or complete personal data stored with us;
  • Demand the correction or deletion of your personal data stored by us, unless the processing for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of Legal claims is required;
  • Demand the restriction of the processing of your personal data. Dispute the accuracy of the data that the processing is unlawful, or whether we continue need the data. You can exercise a defense of your legal claims where you have objected to the data processing in accordance with Art. 21 GDPR;
  • Receive your personal data provided to us in a structured, standard, and machine-readable format or to request transmission to another person responsible;
  • Revoke your once given consent to us at any time. As a result, we are not allowed to continue the data processing based on this consent cancellation.
  • Contact the supervisory authority of your usual place of residence or workplace or our Contact branch in Berlin, Germany.

Note that the Services employ Smart Contracts that collect information that is then stored on a Block Chain that we do not control. If you use the Services, you are consenting to allow your information to be cryptographically transmitted and stored on that blockchain, and any deletion or modification of that information (to the extent possible on a blockchain) is governed by the terms of the relevant Smart Contract.

VII. Withdrawal and Rights

You have the right to object to the processing of your personal data provided that there are reasons for this arising from your particular situation or the objection is directed against direct mail. In the latter case, you have a general right of objection, which is implemented by us without specifying any particular situation.

You also have the right to revoke a consent once given to us at any time. As a result, we will not continue the data processing based on this consent for the future. By the revocation of the consent, the legality the processing on the basis of the consent until the revocation is not affected. If you would like to exercise your right to revocation or objection, please send an email to privacy@publirare.com.

VIII. Registration Data in the European Union

In accordance with GDPR, we use the so-called Double Opt-in method. We will only send you e-mail if you confirm by clicking on a link in our notification e-mail that you are the owner of the given e-mail address. If you confirm your e-mail address, we will save your e-mail address and the time of registration until you unsubscribe. You can unsubscribe from e-mail at any time, except that we may still send you an email if you request a password reset. A corresponding unsubscribe link can be found in every e-mail. A message to the above or in the specified contact information (e.g. by e-mail or letter) is also sufficient. The legal basis of this being processed is your consent in accordance with. Art. 6 para. 1 lit of the GDPR.

In our email, we use commercially available technologies that measure the interactions with the e-mail (e.g. opening the e-mail, clicked links). We use this data in pseudonymous form for general statistical evaluations as well as for the optimization and further development of our content and customer communication. This is done with the help of small graphics that are embedded in the e-mail (so-called pixels). The data is collected exclusively pseudonymized and also not linked with your other personal information. Legal basis for this is our aforementioned legitimate interest. Through our e-mail, we want toshare content relevant to our customers and better understand what readers are actually interested in. If you do not want us to include your information in our analysis of usage behavior, you can unsubscribe from e-mails or deactivate graphics in your e-mail program by default. The data for the interaction with our e-mails may be stored pseudonymously for 30 days and then completely anonymized.

IX. Minors Informations

The Services we provide are intended solely for adults and for adult use. We do not knowingly collect any information from children under the age of 13. If a parent or legal guardian becomes aware that his or her child is using our services, or has provided us with any personally identifiable information, he or she should contact us at privacy@publirare.com. If we become aware that a child under 13 has provided us with any personally identifiable information, we will promptly delete such information along with the child’s account.

X. Cookies

Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.

Please note that if you reject cookies, you will not be able to use some or all PubliRare. If you do not consent to the placing of Cookies on your device, please do not visit, access, or PubliRare.

XI. Data Retention.

We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Service if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it.

XII. Data Security

No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect PubliRare and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the PubliRare website communications with SSL; optional two-factor authentication; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.