1. Introduction and Overview
This Privacy Policy (the “Privacy Policy”) provides a comprehensive description of how
Hatom Labs LLC. (“Hatom Labs LLC,” “we,” “our,” or “us”) collects, uses, and shares
information about you in connection with Hatom Labs websites, (the “Sites”) as well as your
rights and choices regarding such information. Hatom Labs refers to an ecosystem
comprising Hatom Labs websites (whose domain names include but are not limited to
https://hatomlabs.com/, https://hatom.com/), mobile applications, clients,
and other applications that are developed to offer Hatom Labs Services, and includes
independently-operated platforms, websites and clients within the ecosystem (e.g., Hatom
Labs, Hatom lending protocol. “Hatom Labs Operators” refer to all parties that run
Hatom Labs, including but not limited to legal persons, unincorporated organizations and
teams that provide Hatom Labs Services and are responsible for such services. “Hatom Labs”
as used in this Policy includes Hatom Labs Operators. These terms apply to the Sites and any
other online location that links to this Privacy Policy (collectively, the “Services”).
By accessing or using the Sites, you agree to our Terms of Service (the “Terms”) and
understand that the Terms represent a binding agreement between you and us. By using the
Services, you also agree to our collection, use, and disclosure practices, as well as any other
activities described in this Privacy Policy. If you do not agree with the terms of this Privacy
Policy, you should immediately discontinue the use of the Services and refrain from
accessing the Site. If you are a data subject in the European Economic Area, the United
Kingdom, or a resident of Canada, please see the additional disclosures at the end of this Privacy Policy.
2. Changes to Privacy Policy
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon our posting of the revised Privacy Policy. For the avoidance of doubt, your continued use of the Services indicates your consent to the revised Privacy Policy then posted.
3. Information Collection
A. Information You Provide
We may collect the following information about you when you use the Services:
B. Information Collected Automatically
Although at this time we do not automatically collect information from you when you access
the Hatom Labs Services, it is possible that we may in the future. We would utilize this
information to operate and ensure the security, reliability, and robust performance of our
Services.
We may also use tracking technologies to automatically collect information including the
following
4. Use of Information
We do not anticipate using, but we may collect and use, information for business purposes in
accordance with the practices described in this Privacy Policy. Our business purposes for
collecting and using information include:
5. Sharing and Disclosure of Information
If share or disclose information that we collect, we do so in accordance with the practices
described in this Privacy Policy. The categories of parties with whom we may share
information include:
For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
6. Other Parties
We may integrate technologies operated or controlled by other parties into parts of the
Services. For example, the Services may include links that hyperlink to websites, platforms,
and other services not operated or controlled by us.
Please note that when you interact with other parties, including when you leave the Site,
those parties may independently collect information about you and solicit information from
you. The information collected and stored by those parties remains subject to their own
policies and practices, including what information they share with us, your rights and choices
on their services and devices, and whether they store information in the U.S. or elsewhere.
We encourage you to familiarize yourself with and consult their privacy policies and terms of
use.
7. Analytics
We do not use analytics services for this Site. (To be confirmed)
8. Your Rights and Choices
If share or disclose information that we collect, we do so in accordance with the practices
described in this Privacy Policy. The categories of parties with whom we may share
information include:
Accordingly, unless and until the law isnterpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
9. Data Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. International Transfer
Please be aware that information collected through the Services may be transferred to, processed, stored, and used in the European Economic Area, the United Kingdom, and other
jurisdictions. Data protection laws in the EU and other jurisdictions may be different from
those of your country of residence. Your use of the Services or provision of any information
therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and
storage of information about you in the EU and other jurisdictions as set out in this Privacy
Policy.
11. Children
The Services are intended for general audiences and are not directed at children. To use the Services, you must legally be able to enter into the Agreement. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, please contact us at privacy@hatomlabs.com and we will remove the personal information in accordance with COPPA.
12. Contact Us
If you have any questions or comments about this Privacy Policy, our data practices, or our
compliance with applicable law, please contact us:
By email: info@hatomlabs.com
By mail
Hatom Labs LLC
Dubai Silicon Oasis
DDP, Building A2,
Dubai, United Arab Emirates
This Privacy Policy has been designed to be accessible to people with disabilities. If you
experience any difficulties accessing the information here, please contact us at
privacy@hatomlabs.com
13. Additional Disclosures for Data Subjects in the European Economic Area and the United Kingdom.
A. Roles
The General Data Protection Regulations in the European Economic Area and the United Kingdom (“GDPR”) distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Services.
B. Lawful Basis for Processing
The GDPR requires a “lawful basis” for processing personal data. Our lawful bases include where: (i) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; or (iv) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Data Subject Rights
If you are a user in the European Economic Area or the United Kingdom, you maintain
certain rights under the GDPR. These rights include the right to (i) request access and obtain
a copy of your personal data; (ii) request rectification or erasure of your personal data; (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.
Notwithstanding the foregoing, we cannot edit or delete information that is stored on a
particular blockchain. This information may include transaction data (i.e., purchases, sales,
and transfers) related to your blockchain wallet address and any NFTs held by your wallet
address.
To exercise any of these rights, please contact us via our email or postal address listed in the
“Contact Us” section above and specify which right you are seeking to exercise. We will
respond to your request within thirty (30) days. We may require specific information from
you to help us confirm your identity and process your request. Please note that we retain
information as necessary to fulfil the purpose for which it was collected and may continue to
retain and use information even after a data subject request in accordance with our legitimate
interests, including as necessary to comply with our legal obligations, resolve disputes,
prevent fraud, and enforce our agreements.
If you have any issues with our compliance, please contact us as set out in the “Contact Us”
section above. You also reserve the right to lodge a complaint with the data protection
regulator in your jurisdiction.
14. Additional Disclosures for California Residents
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and the means to exercise consumer rights.
A. Notice of Collection.
We collect the following categories of personal information enumerated in the CCPA
Internet activity – including information on visitors to the Site and their interactions with the
Hatom Labs Services.
Geolocation data of Site visitors.
For further details on the information we may collect, including the sources from which we
receive information, review the “Information Collection” section above. We may collect and
use these categories of personal information for the business purposes described in the “Use
of Information” section above, including to manage the Services. We do not “sell” personal
information as defined under the CCPA. Please review the “Sharing and Disclosure of
Information” section above for further details about the categories of parties with whom we
share information.
B.Right to Know and Delete.
You have the right to know certain details about our data practices within the past twelve (12)
months. In particular, you may request the following from us
The categories of personal information we have collected about you.
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose;
The categories of third parties to whom the personal information was disclosed for a business
purpose;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please submit a request by emailing us at
privacy@hatomlabs.com. In the request, please specify which right you are seeking to
exercise and the scope of the request. We will confirm receipt of your request within ten (10)
days. We may require specific information from you to help us verify your identity and
process your request. If we are unable to verify your identity, we may deny your requests to
know or delete.
C. Authorized Agent.
You may designate an authorized agent to submit requests on your behalf; however, we may require written proof of the agent’s permission to act on your behalf and verify your identity directly
D. Right of Non-Discrimination.
You have a right of non-discrimination for the exercise of any of your privacy rights
guaranteed by law, such as the right to access, delete, or opt-out of the sale of your personal
information.
Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal
information disclosed by us to third parties during the immediately preceding calendar year
for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third
parties to whom we disclosed such information. To exercise a request, please write to us at
the email or postal address set out in the “Contact Us” section above and specify that you are
making a “California Shine the Light Request.” We may require additional information from
you to allow us to verify your identity and are only required to respond to requests once per
calendar year.