Privacy Policy

Sturdy Exchange (“we” or “us”) respect the privacy of the individuals with whom we interact and information that we collect that is identifiable to those individuals. This Privacy Policy describes how we handle the information we collect from individuals who visit our website located at https://sturdy.exchange/ (the “Site”). By visiting the Site, you are deemed to agree to the terms of this Privacy Policy, so please read the Policy carefully before using the Site.

We may update this Policy at any time. Any changes to the Policy will become effective upon the date of our posting of the revised Policy on the Site. If you visit the Site following the effective date of the revised Policy, you will be deemed to have accepted the Policy’s updated terms.

What Information Does Sturdy Exchange Collect from You as a User? The information we collect about you when you visit the Site (“Your Information”) includes any information you actively provide, such as when you register and create an account or when you fund or remove funds from our exchange platform. We also collect information from your computer or device used to connect to the Site, which you provide passively simply by visiting the Site.

Information You Actively Provide To register on the Site, you will need to provide personally identifiable information (“PII”), including your first name, last name, state and country of residence, date of birth, telephone number, billing address, email address. And you have the option to provide your social media links, a nickname, or a picture of yourself for us to add to your profile.

When you fund your account, we process your payments through Circle (https://www.circle.com/en/) . Although we collect your billing details on the Site, such as credit card information, we do not store those details but rather transmit them to Circle for payment processing. Circle handles your PII as described in Circle’s own privacy policy, https://www.circle.com/en/legal/us-privacy?hsLang=en.

Information Collected From Your Computer or Device

If you seek to register with us, we will check your IP (Internet Protocol) address to confirm that you are located in a jurisdiction where we offer our services. We may do this by checking your identity through Trulioo (https://www.trulioo.com/) , which provides us with confirmation information about you.

We also use tracking tools, such as pixel tags and cookies, so that we can compile statistics about our daily number of Site visitors, specific page views, length of time spent by users on certain pages, or other patterns of use on the Site. Cookies are small data files that a website stores on the hard drive of the device through which a website user connects to the website and can recognize the user’s visits by identification of the computer or device used to access a Site. You can set your browser to reject cookies, but rejecting a cookie may in some cases preclude you from using, or negatively affect the display or function of, the Site or certain areas or features of the Site. To learn more about cookies, please visit http://www.allaboutcookies.org.

By visiting the Site, you are deemed to unambiguously agree to its use of any cookies that you do not disable.

Currently, our Site does not respond to a browser “Do Not Track” signal.

How Does Sturdy Exchange Use the Information It Collects from You? PII. We may use the PII that we collect about you for any or all of the following purposes: To provide you with our services. We use the PII you provide to provide you with our services, such as facilitating your payment in an NFT transaction. To respond to your inquiries. If you pose questions to us or request information from us, whether by email or otherwise, we will use your PII to respond to you. To offer you additional information. Once you have engaged with us, we want to provide you with information regarding our resources that may be of interest to you, and we may use your PII to do that, such as, for example, by using your email address to email to you notices of additional products or services. Our commercial email messages to you will provide you with the opportunity to opt out of receiving additional commercial emails. To detect fraud and for legal compliance purposes. We use your PII as needed to detect and prevent fraud against you or others, and for our legal compliance purposes more generally. For our general business purposes. We use PII about you for our legitimate business purposes, such as to help us expand, refine and improve the Site and to tailor them more to your interests and needs, including by requesting feedback from you, and for related internal purposes such as data analysis, data security, and internal audits. Other Information. We use the non-PII that we collect automatically about your use of the Site to help us improve the Site, such as by revising the Site based on Site visitor trends, including usage of certain pages or functions on the Site. With Whom Might Sturdy Exchange Share Information About You? PII. Sturdy Exchange shares the PII that we collect in very limited circumstances, such as with: Service Providers. We share PII with third parties who provide us with services, such as Circle, Trulioo, and vendors who assist us with technology, accounting, auditing, data analysis, or similar services. We do not share PII with unaffiliated third parties for their own marketing purposes. Other Site Users. If you purchase an NFT, your age and purchase history will be shown on the profile account page, accessible to the public. Likewise, if you place a bid on the auction page, the history of the previous bid on the NFT as well as your bid will be shown. This information may or may not be PII. Acquirers or Assignees. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Sturdy Exchange or its assets, we may transfer any and all information that we collect from Site users to the proposed or actual acquiring party or assignee. Entities Entitled Under Law. We may disclose PII as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Site, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of Sturdy Exchange or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law. Other Information. We may share non-PII that we collected from or about you for any legitimate purpose. How Do We Protect the PII We Collect? We use reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the information under our control, including two-factor authentication and flow blockchains. However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure. Please do not send us information you consider confidential via e-mail. Collection of PII by Others. Tracking on Our Site. We do not allow others to collect the PII of visitors to our Site by tracking individuals’ usage of our Site and other websites over time. Other Websites. The Site may contain links to websites operated by parties not affiliated with Sturdy Exchange, including Circle. These linked websites are not under our control and we are not responsible for the privacy practices or the contents of any such unaffiliated parties or their websites. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. Use of the Site by Children. Our Site is not targeted toward or intended for use by minors, and we do not knowingly collect PII from children under age thirteen (13). If we were to discover that we had collected any PII from a child under age 13, we would promptly delete it. International Transfers of Information. By using the Site, you are deemed to understand and unambiguously consent to the collection and processing of your PII in the United States, with the awareness that the laws of the United States may not provide as much protection for PII as the laws of certain other countries or territories. For Users in the European Economic Area and the United Kingdom. If you are located in the European Economic Area or the United Kingdom, you may wish to understand how your PII (the equivalent of “personal data”) is treated in accordance with your rights under data protection legislation applicable in your local jurisdiction. This section explains our policies and practices as relevant to such legislation, including the European Union General Data Protection Regulation (“GDPR”). Controller. Sturdy Exchange is the controller of the PII it collects about you. EU PII Representative. The EU representative of Sturdy Exchange to whom to address PII related inquiries is: Ametros Group. Legal bases for processing. Our legal bases for processing the PII we collect, use and share as described in this Privacy Policy are set forth in the table below. PROCESSING PURPOSE LEGAL BASIS To operate the Site and provide our services Processing is necessary to perform our services pursuant to the Site Terms of Use. We process your PII based on our legitimate interest in providing the services you access and request. To improve our Site and services and to support analytical and related activities We use and disclose your PII to conduct these activities as an exercise of our legitimate interests. We do not use or disclose your PII for these purposes where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). To comply with law We process your PII as necessary to comply with our legal obligations. With your consent We may process your PII in any manner to which you consent. If you provide your consent, you have the right to withdraw it any time in the manner indicated when you consented. Use for new purposes. We may use your PII for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your PII for an unrelated purpose, we will notify you and explain the applicable legal basis. Retention. We retain PII for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for PII, we consider the amount, nature, and sensitivity of the PII, the potential risk of harm from unauthorized use or disclosure of your PII, the purposes for which we process your PII and whether we can achieve those purposes through other means, and the applicable legal requirements. Data anonymization. In some circumstances we may anonymize your PII (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you. Your rights. Your local data protection laws may give you certain rights regarding your PII. If you are located in the European Economic Area or the United Kingdom or other jurisdictions whose laws apply, you may ask us to take the following actions in relation to your PII that we hold: Provide Access. Provide you with information about our processing of your PII and give you access to that information. Correct. Update or correct inaccuracies in your PII. Delete. Delete your PII. Transfer. Transfer a machine-readable copy of your PII to you or a third party of your choice. Restrict. Restrict the processing of your PII. Object. Object to our reliance on our legitimate interests as the basis of our processing of your PII. You can submit these requests by email to privacy@sturdy.exchange or by mail to our postal address provided below. We may request specific information from you to help us confirm your identity and to respond to your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you would like to submit a complaint about our use of your PII or response to your requests regarding your PII, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.

Contacting Us. If you have any questions or concerns related to this Privacy Policy or Sturdy Exchange’s information practices, please reach out to us through the “Contact Us” page on the Site or send us an email at privacy@sturdy.exchange. 156 N Larchmont Boulevard, Los Angeles, CA, 90004.


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