PRIVACY POLICY
Last Updated: January 1, 2023
Aleda, Inc. (“Aleda,” “we”, “us”, or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect, use, and share in connection with the Aleda website, mobile app, and other software provided on or in connection with our services, as described in our Terms of Service (collectively, the “Service”). “CDA” in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain.
Types of Data We Collect. “Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.
Information You Provide Us.
When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address, first and last name, username, and other information you provide. We also collect your blockchain address, which may become associated with Personal Data when you use our Service.
Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser, or mobile device.
If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.
We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.
Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third-party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, and date/time stamps.
Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
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.
Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
How We Respond to Do Not Track Signals. Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
Analytics Services. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. We may add this to the data we have already collected from or about you through our Service.
Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of CDAs, which may then be associated with other data you have provided to us.
Use of Your Personal Data.
We process your Personal Data to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your Personal Data to:
• facilitate the creation of and secure your account;
• identify you as a user in our system;
provide you with our Service, including, but not limited to, helping you view, explore, and create CDAs using our tools and, at your own discretion, connect directly with others to purchase, sell, or transfer CDAs on public blockchains;
improve the administration of our Service and quality of experience when you interact with our Service, including, but not limited to, by analyzing how you and other users find and interact with the Service;
provide customer support and respond to your requests and inquiries;
investigate and address conduct that may violate our Terms of Service;
detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;
display your username next to the CDAs currently or previously accessible account, and next to CDAs on which you have interacted;
send you a welcome email to verify ownership of the email address provided when your account was created;
send you administrative notifications, such as security, support, and maintenance advisories;
send you notifications related to actions on the Service, including notifications of offers on your CDAs;
send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services;
respond to your inquiries related to employment opportunities or other requests;
comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
act in any other way we may describe when you provide the Personal Data.
We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
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), Aleda may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Aleda; (c) to protect or defend the rights or property of Aleda or users of the Service; and/or (d) 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.
Third-Party Websites. Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service or third parties’ goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the Notifications preferences in your Settings page. Despite these preferences, we may send you occasional transactional service-related informational communications.
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.
Data Access and Control. You can view, access, edit, or delete your Personal Data for certain aspects of the Service via your Settings page. You may also have certain additional rights:
If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.
If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not “sell” your “personal information.”
If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us by using the “Submit a request” link here or at the address provided in Section 13 below, specify your request, and reference the applicable law. We may ask you to verify your identity or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and CDAs held at that address.
State Privacy Laws
If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you may have certain privacy rights under the applicable privacy laws in your state (“State Privacy Laws”). This section describes those rights and how you can exercise them with Aleda.
Rights Requests
Right to Know, Right to Deletion and Right to Correct
You can request what personal information we have collected, used, disclosed, and sold.
You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:
• Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
• Security: to detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
• Error Correction: to debug or repair any errors;
• Legal: to protect against fraud, harassment, malicious or deceptive activities, or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or
• Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
Please note that if we delete your personal information, many of our services will not work the same. Some examples include, but are not limited to:
• Returns: We will not have the ability to look up your receipt or order in our system. In order to process a return or refund, we will require proof of purchase from the customer and if the customer is unable to provide proof of purchase, the transaction will be treated as an unreceipted return in accordance with our return policy.
• Customer Service: Our ability to handle customer service requests may be limited. We will not have the ability to look up prior orders or account information and may request proof of purchase in order to service your needs.
• Online Account & Shopping: Your online account will no longer exist. Your shopping cart items, order history, saved addresses, saved recipes and any other saved preferences in your online account will no longer be available.
• Marketing Communications: We will no longer be able to provide you with any marketing communications directly from our family of brands, including personalized marketing communication such as information about new products, services and offers tailored to your interests.
• Opt Outs: Previous opt-out requests will not be saved.
You may also request that we correct certain inaccurate information that we have about you.
To submit a request to know, a request to correct or a request to delete, please email us at info@aleda.com. In order to verify your identity, you will need to provide at least three of the following pieces of your information: name, telephone number, e-mail address, mailing address, and last transaction amount. We will match this information to the information on our systems. For an online request to delete, we will also send you a second verification to confirm that you want your information to be deleted. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof at the time they make the request on your behalf. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information. We will maintain a record of your request to know or request to delete.
Do Not Sell or Share/Use My Personal Information for Targeted Advertising
Personal Information that We Sell or Share/Use for Targeted Advertising
Under California law, “share” means disclosing your personal information by us to a third party for cross-context behavioral advertising, in exchange for money or anything else of value. Thus, when we use the term “share” under this section, we are using it in the narrow meaning of how it is defined under California law. Other State Privacy Laws do not use the term “share,” but describe the concept as using personal information for targeted advertising.
Under the laws of California, Colorado, Connecticut and Utah, “sell” means exchanging your personal information by us with a third party for money or anything else of value. Under Virginia law, “sell” is the exchange of personal information for money only.
Through our participation in digital advertising networks and in connection with our Select Partners, we may sell or share/use for targeted advertising, the following categories of personal information:
• Identifiers
• Characteristics of protected classifications under California and federal law;
• Internet/electronic activity;
• Commercial information; and
• Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.
We do not knowingly sell or share/use for targeted advertising the personal information of minors under the age of 16.
Right to Opt Out of Sale or Sharing/Using Your Personal Information for Targeted Advertising
You can opt-out of us selling or sharing/using your personal information for targeted advertising for online activity by enabling an opt out preference signal for a browser or plug-in that makes it clear that such signal is meant to have the effect of opting you out of the sale and sharing of your Personal Information. To opt out of online and offline selling or sharing, please email us at info@aleda.com. Note that if you are logged into your online account, we will process such request for offline sales also, but if we only can identify your device or browser, we will only be able to apply the request to that specific device or browser and only for cookie or pixel based selling and sharing. Note that if you clear your cookies, your opt out request will no longer be saved for that browser.
In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof at the time they make the request on your behalf.
We do not “sell” or “share” Sensitive Personal Information (as defined under State Privacy Laws).
Non-Discrimination
We will not discriminate against you for exercising any of your rights under State Privacy Laws and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your rights under State Privacy Laws.
Financial Incentives
We offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at info@aleda.com, or by unsubscribing to our email marketing by vising our website. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.
Right to Opt out of Profiling
If you are a resident of Colorado, Connecticut or Virginia, you have a right to opt out of any form of automated processing performed on personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements (“Profiling”). To submit a request to opt out of Profiling that is not cookie-based or digital advertising-based Profiling, please email us at info@aleda.com. In order to verify your identity, we will send you a verification email. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof mailed to the address below so that it is received prior to the time the agent makes the request on your behalf. To opt out of cookie-based or digital advertising-based Profiling, please opt out of the selling/sharing of your information for targeted advertising, as described above. Note that if you opt out of profiling, your experience with our brands will be less personalized.
We will not be able to opt you out of Profiling where one of the following exceptions applies:
• Legal: to comply with applicable laws, rules or regulations; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities; to cooperate with law enforcement; to investigate, exercise, prepare for or defend actual or anticipated legal claims; or to assist another party with any of its obligations under applicable laws;
• Security: to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
• Improvement of Services and Products/Internal use: to conduct internal research to improve, repair or develop products, services or technology;
• Transactional: to provide a product or service specifically requested by you; to complete a transaction with you or to complete a contract we have with you; and
• Public Interest: to protect your vital interests or those of another individual.
Right to Appeal
If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal our request by emailing us at info@aleda.com within fourteen days of our decision, and submitting an appeal request, with a detailed reason for your appeal, as well as your state of residence.
Sensitive Personal Information
We do not collect or process Sensitive Personal Information, as defined by California Law, for inferring characteristics or use or disclose Sensitive Personal Information for purposes other than those permitted by law.
Retention
We will store your personal information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.
Metrics:
We have no metrics for 2024.
Security
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, our web sites use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your contact information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from our web sites, and you do so at your own risk.
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
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.
Data Protection. We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
Minors. We do not intentionally gather Personal Data from visitors who are under the age of 13. Our Terms of Service require all users to be at least 18 years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s Aleda account, but only with the involvement of the account holder. If a child under 13 submits Personal Data to Aleda and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us by using the “Submit a request” link here or at the address indicated in Section 13 below.
Users Outside of the United States. If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.
Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://Aleda.store/privacy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.
Questions; Contacting Aleda; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us by email at info@aleda.com or at the following address: 126 Solace Ct., Encinitas, CA 92024.