1. GENERAL

This Privacy Policy describes how (“HECKSOW LLC”, “we”, “us” or “our”) handles personal information that we collect through the HECKSOW LLC website available at HECKSOW LLC and application on the Google Play and Apple store by the name HECKSOW LLC (collectively referred to as “Website”) activities and features that link to this Privacy Policy, offering the HECKSOW LLC Platform with various utilities including mortgage services to eligible individuals and entities across the globe, participation in decision making via decentralised autonomous organisations (DAO), offering a payment method for mortgage payments, participating in activities to earn potential rewards (in non-fiat form) and other future applications and if you avail or inquire about services, and other activities described in this Privacy Policy (collectively, the “Services”, each a “Service”). Users, customers, visitors and vendors are collectively referred to as “you”, “your” or “User”.

This Privacy Policy describes the information, which shall mean to include personally identifiable information, that we collect about you (“Personal Information”), how we collect it, the purpose of such collection, processing of this Personal Information, how and why we share this Personal Information, the period of retaining this Personal Information with us, and how to review, update or request deletion of your Personal Information. By using or accessing the Website, you hereby agree to the terms of this Privacy Policy, especially the terms with respect to collection, storage, processing and sharing of your Personal Information. If you disagree with this Privacy Policy please do not use or access our Website. This policy applies where we are acting as a data controller with respect to the Personal Information of such persons; in other words, where we determine the purposes and means of the processing the Personal Information.

This Privacy Policy does not apply to any website(s), mobile sites and mobile apps of third parties, even if their websites/products are linked to our Platforms. Users should take note that information and privacy practices of our business partners, advertisers, sponsors or other sites to which HECKSOW LLC provides hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom they interact.

HECKSOW LLC is committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which Personal Information we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which Personal Information you supply through this Service is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (“EU GDPR”), the GDPR as it forms part of the laws of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR” and together with the EU GDPR, the “GDPR”) and the UK Data Protection Act 2018 (“UKDPA”). HECKSOW LLC will comply with all applicable data protection laws, including the GDPR, UKDPA and the California Consumer Privacy Act 2018 (“CCPA”).

Please read this Privacy Policy carefully as it contains important information about the following:

• What Personal Information  we may collect about you.
• How do we use the Personal Information we collect about you.
• Whether we disclose your Personal Information to any third-parties.
• How do we protect your Personal Information?
• Your choices and rights regarding the Personal Information we hold about you.

This Privacy Policy should be read in conjunction with our Terms of Service as may be applicable in respect of the Service. Where Terms of Service are applicable, they will be made available via the Service.

The Service may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them. They will govern the use of Personal Information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk. The third-party websites are not under the control of HECKSOW LLC and HECKSOW LLC is not responsible for the content of any third-party websites and/or any links contained in the third-party websites. HECKSOW LLC is providing these links to the third-party websites to you only for your convenience and HECKSOW LLC is not responsible for any kind of loss/ damage arising out of it and the access to or any other act on such third party links shall be entirely at your risk.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Services.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes through the Service.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following Personal Information from you when you use our Services (for example, our Website) (the “Services Information”):

1. Information that may be provided by you when creating a Service account 

• Your Wallet Address;
• Technical Information relating to the wallet interface;
• Name;
• Date of birth;
• Mobile phone number;
• Address;
• Email address;
• Identification proof;
• employer name;
• monthly salary;
• bank account details;
• bank statements;
• credit information;
• any alpha-numeric identifier of a tax paying status;
• GST information; and
• copies of identification documents.

2. Information that may be provided by you when you contact us for support (“Support Information”) 

• Your email address; and
• Your contact number if required.

3. Information from Third Parties

We obtain information from third-party sources. For example, we may collect information about you from identity verification services, data analytics providers, and mailing list providers (if applicable).

4. Information about your Activities (“Technical and Usage Information”) 

We may collect technical and usage information about your use of our Service through tracking technologies and analytics collection in our Services. Personal Information we may collect in this way includes:

• IP address;
• Geolocation information (i.e. longitude and latitude); Service user ID (a unique ID that we generate which identifies Service users);
• Device information (such as your device ID, operating system and version, device brand, device family, model and manufacturer);
• Mobile network carrier (if applicable);
• Country, market and region information;
• Language;
• Error and crash data (identifying a Service crash event);
• Advertising identifier numbers (such as IDFA (iOS devices) and ADID (Android devices)); and
• Events related to your Service usage, such as achievement of a milestone and the occurrence of other events during your Service usage (such as virtual currency balance, NFT information, session durations and your choices and progression for and in different parts of the Service).

5. Analytics and profile information (“Analytics and Behavioural Data”) 

We may collect, or create by analysis of other Services Information, analytical information in connection with your Service usage including without limitation:

• When you first launched / began using the Service;
• Whether you use our free Services, or whether you use paid-for Services and how much you spend;
• Whether you discovered our Service organically, or whether you discovered the Service through an advertising campaign;
• What your Service usage habits are (for example, whether you use the Service in a particular way or only use a part of the Service and how often you use it); and
• We may associate your account with a user segment group which we think have shared characteristics, such as perceived interest in particular parts of our Services.

3. HOW DO WE USE THE PERSONAL INFORMATION COLLECTED

1. We process your Submitted Information for the purpose of ensuring that the funds held in the ETH wallet do not present a risk of money-laundering. We may conduct verification checks through the transaction history associated with the ETH address, as publicly viewable on the Ethereum blockchain. We may do this for our legitimate interests of ensuring that your use of our Services is lawful and in compliance with our agreement (being the Terms of Service agreed between us), to prevent disruption to our Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.
2. We may process certain of your Services Information (including your Support Information and certain other Services Information which might be relevant) so that we are able to properly respond to your enquiries and support requests, in accordance with the Terms of Service agreed between us.

 For the above purposes, we rely upon the legal basis of the performance of a contract (being our Terms of Service with you for the Service)

3. We may use and share this anonymous, aggregated or de-identified information for any lawful business purpose, including to better understand customer needs and behaviours, analyse and improve the Services, promote our business, conduct business intelligence and marketing, perform analytics or enable analytics provided by third parties, and detect security threats.
4. Enable your use of the Services and features on the Website.
5. Inform you about new features on the Website.
6. Develop, enhance, market and deliver the Services to you.
7. Understand your needs and your eligibility for availing the Services.
8. Send statements, invoices and payment reminders to you, and collect payments from you.
9. Enable you to download information/white papers/documents you have requested.
10. For analytics and statistical purposes.
11. To conduct audits and quality assessment procedures.
12. Conduct surveys and receive feedback from you.
13. Meet HECKSOW LLC legal and regulatory requirements, comply with KYC, AML and other applicable laws.
14. Keep our Website secure and prevent fraud.
15. If we believe your actions are inconsistent with our terms of service and applicable terms or policies.
16. We may also process your Personal Information where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. COOKIES 

A cookie is a text file placed onto your device when you access our Services. We use cookies and other similar or equivalent online tracking devices such as web beacons, standard development kits (for mobile) and flash object storage to deliver, improve and monitor our websites, applications and games, including in the following ways:

1. Authentication: To log you into our Service and keep you logged in.
2. Service delivery: To deliver our Services and third-party services which may be embedded into our own Services.
3. Preferences: To remember information about your preferences such as your preferred language and configuration.
4. Analytics: To help us understand how you use our Services, such as how often, so we can improve Services and deliver a better experience and also for us to carry out research and statistical analysis to help us develop new products and services. 
5. Advertising: To help us deliver in-Service advertising to you (which may be served by, or facilitated by, third parties). These are also used to help us and our partners measure the effectiveness of advertising and whether it was actually served to you.

The information we obtain from our use of cookies will not usually contain your Personal Information. Although we may obtain information about your device such as your advertiser ID, IP address, your browser and/or other internet log information, this will not usually identify you personally. Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Services or may not have the same quality of experience. We may work with third parties who may also set cookies and equivalent technologies on our Services, for example: Google Analytics, Google AdWords, YouTube, Facebook, Twitter and LinkedIn, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Services.

5. DATA SHARING & PROCESSING

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy.

1. Group members, personnel, suppliers or subcontractors from time to time: We keep your Personal Information confidential but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries), our personnel, our advertising and analytics service providers and our other suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. By using the Website and availing our Services, you accept the terms hereof and hereby consent to the storage and processing of Personal Information by third parties.
2. Payment providers: Where you initiate a payment with us, your payment related information will be processed by our payment providers.
3. Corporate Restructuring: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this Personal Information, as well as any choices you may have regarding this Personal Information.
4. Required by law: We may disclose your Personal Information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
5. Third party suppliers: we will share your Submitted Information with third-party suppliers, for the purposes of running checks to seek to prevent money- laundering and other illegal activities.
6. Access and data portability: You may request that we provide you a copy of Personal Information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law). In certain circumstances, you may request to receive your Personal Information in a structured, commonly used and machine-readable format, and to have us transmit your Personal Information to another data controller.
7. Correction of incomplete or inaccurate personal information: You may request that we correct any of your Personal Information held by us that is incomplete or inaccurate.
8. Erasure: You may request to erase your Personal Information, subject to applicable law.
9. Withdraw consent: To the extent the processing of your Personal Information is based on your consent, you may withdraw your consent at any time. This withdrawal will not affect the lawfulness of HECKSOWS LLC processing based on consent before your withdrawal.
10. Restriction of processing:In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your Personal Information under certain circumstances. We may continue to process your Personal Information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.
11. Automated individual decision-making, including profiling:HECKSOW LLC relies on automated tools to, for example, help determine whether a transaction or a User account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your Personal Information, including profiling, which produces legal effects concerning you, or similarly significantly affects you, save for the exceptions applicable under relevant data protection laws.
12. Declining to provide information: We may need to collect Personal Information in the future. If you do not provide the Personal Information we designate as required or mandatory, we may not be able to provide our Services.
13. Make a complaint to a Supervisory Authority: If you are unhappy with the way we are processing your Personal Information, please let us know by contacting us via the support services.

6. DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain Personal Information in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

7. SECURITY 

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the Personal Information transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of our Service and your Personal Information a high priority, no security system can prevent all security breaches. Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your Personal Information but we cannot always guarantee the complete security of your Personal Information transmitted through our Service; subject to applicable law, the sharing of your Personal Information with us and any transmission of the data is at your own risk.

8. CALIFORNIA RESIDENTS (CCPA)

You have the following privacy rights under the CCPA:

• Request to Know: You have the right to request to know the following information about our practices over the past 12 months: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which we collected the Personal Information about you; (iii) the categories of third parties with which we share Personal Information, (iv) the categories of Personal Information we sold or disclosed about you and for each category, the categories of third parties to which we sold or disclosed that particular category of Personal Information; (v) our business or commercial purpose for collecting or selling your Personal Information; and (vi) the specific pieces of Personal Information we collected about you.

You may exercise your right to request to know twice a year, free of charge. If we are unable to fulfill your request to know, we will let you know the reason why. Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s licence number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions or answers, and unique biometric data generated from measurements or technical analysis of human characteristics.

• Request to Delete:You have the right to request that we delete the Personal Information that we have collected from you. We may deny your request under certain circumstances, such as if we need to retain your Personal Information to comply with our legal obligations or if retaining the information is necessary to complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason why.
• Right to Non-Discrimination: If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Websites.

If you would like to make a Request to Know or Request to Delete or are an authorised agent of a California consumer who would like to make such a request, contact us at HECKSOW LLC.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the individual about whom we collected Personal Information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we will not require you to create an account with us but we may request additional information about you so that we can verify your identity.  We will only use the Personal Information you provide to verify your identity and to process your request, unless you initially provided the information for another purpose.

You may use an authorised agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorises your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorised by you to act on your behalf. You may also make a verifiable consumer request on behalf of your minor child.

California residents may also request information from us once per calendar year about any Personal Information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us at HECKSOW LLC.

Your inquiry must specify “Shine the Light Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.

9. YOUR CHOICES

1. Unsubscribe from Email Alerts

Should you receive an email alert from us, you may unsubscribe from receiving additional email communications by following the unsubscribe instructions in the emails we send. Additionally you may send us a message requesting to unsubscribe by contacting us at HECKSOW LLC. Please note that even if you opt-out of receiving email alerts from us, we may continue to send you other email communications.

2. Ability to Opt-Out of Tracking Technologies

Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options,” “tools” or “preferences” menu. You may also consult the browser’s “help” menu. You can learn more about cookies and how to block cookies on different types of browsers by visiting http://www.allaboutcookies.org. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other tracking technologies.

For information on disabling Flash cookies, visithttps://helpx.adobe.com/flashplayer/kb/disable-local-shared-objects-flash.html. Please be aware that if you disable or remove these technologies, some parts of our Websites may not work and when you revisit our Websites, your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.

3. Ability to Opt-Out of Analytics

You may exercise choices regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

4. Changes to this Privacy Notice

HECKSOW LLC reserves the right to modify this Privacy Notice at any time. Changes will be effective immediately upon posting of the revised Privacy Notice, as indicated by the “Last Updated” date at the top of this page. We encourage you to periodically review this page for the latest information on our privacy practices.

10. CONTACT INFORMATION

All questions, comments or enquiries should be directed to us at LLC. We will endeavour to respond to any query or questions within a reasonable amount of time.

11. MISCELLANEOUS

1. Severability 

If any provision of this Privacy Policy is invalid, illegal, or unenforceable, the balance of this Privacy Policy shall remain in effect, and if any provision is inapplicable to any person or circumstance, it shall nevertheless remain applicable to all other persons and circumstances.

2. Limitation of Liability

HECKSOW LLC will not be liable for any consequential, incidental, punitive, special, exemplary, or indirect damages. Lost profits or penalties of any nature are hereby waived; these limitations apply without regard to the cause of any liability or damage, including the negligence of HECKSOW LLC. There are no third-party beneficiaries to this Agreement.

3. Governing Law and Jurisdiction

This Privacy Policy, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation, shall be governed by, and construed in accordance with, the laws of America. You irrevocably agree that the courts shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Privacy Policy or its subject matter or formation.