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Privacy Policy

Last updated: June 4, 2024

Thank you for choosing to be part of our community at Enclave Global Inc. (“Enclave”, the “Company”, “we”, “us”, or “our”). We are committed to protecting the privacy of your personal information. This Privacy Notice applies to the personal information collected when you:

  • Visit and use our website (www.enclave.market) (the “Site”) and platform;
  • Communicate with us electronically such as via email; and
  • Interact with us offline including in person at sales or marketing events or via telephone.

We refer to the Site, our services, and other interactions with you collectively as the “Services” in this Privacy Notice. In this Privacy Notice, we describe how we collect, use, store, and disclose your personal information and what rights you may have with regard to the information we maintain about you. Please read this Privacy Notice carefully as it will help you make informed decisions about sharing your personal information with us. From time to time, we may supplement this Privacy Notice with additional information about our privacy practices related to a particular service. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at the email in the “Contact us” section.

Contents

  1. What kinds of information do we collect?
  2. How do we use this information?
  3. How do we disclose this information?
  4. International transfers
  5. Retention
  6. How do we secure this information?
  7. Minors
  8. Your privacy choices
  9. Notice to California residents
  10. Changes to this Privacy Policy
  11. Contact us

What kinds of information do we collect?

When we refer to personal information, we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular consumer or household (“Personal Information”). Personal Information does not include publicly available information, de-identified or aggregated information.

Information You Provide Us

We may collect Personal Information that you provide us through the Services, including when you use the Services, express an interest in obtaining information about our products or Services, participate in activities and events related to the Services, or otherwise contact us. The Personal Information that we may collect depends on the context of your interactions with us, the choices you make, the Services and the products and features you use. We may collect:

  • Identity: First and last name, date of birth, social security number, driver’s license or passport, and other identifiers. When required by law, we may request additional information such as identification documents to verify your identity.
  • Contact information: Email address, mailing address, and phone number.
  • Marketing data: Your preferences for receiving our marketing communications and details about how you engage with them.
  • User communications: Your communications when you contact us with questions or feedback, including feedback about the Services and customer support correspondences.
  • Technical data: Blockchain wallet address and network transactions.

Information We Automatically Collect

We automatically collect certain information when you access, use, download, or interact with the Services such as:

  • Device data: Browser and device characteristics, operating system, IP address, public blockchain wallet address, and language preferences.
  • Usage data: URLs, country location, page views, date/time stamps, how and when you use the Services, and other technical information.
  • Transaction data: Information about your purchase activity or other transactions such as product details, purchase price, and the date and location of the transaction.
  • Cookies: We may use cookies and similar tracking technologies (like web beacons and pixels) to collect information. Information about the cookies we use, how we use such technologies, and how you can refuse or opt out of certain cookies is set out in our Cookie Policy.

Information We Collect from Third Party Sources

We may obtain information from third party sources such as:

  • Service providers: Such as the service providers we use to perform identity verification services or transaction monitoring or to provide analytics. Your interactions with such third-party service providers are governed by those businesses’ own privacy policies. Identity verification partners may use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, employment information, public profiles, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.
  • Public sources: Including blockchains and social media companies.

How do we use this information?

We may use your Personal Information for the following purposes:

  • To provide and improve our Services: We may use your Personal Information to provide Services that you request, process and complete transactions, and send you related information.
  • Build and maintain our relationship with you: We may use your Personal Information to provide information about events that you indicate an interest in and provide support for the Services, including resolving issues and responding to your questions and feedback.
  • Maintain the security of the Services: We may use your Personal Information to maintain the security and integrity of our Services, prevent, detect, and investigate fraudulent, harmful, or illegal activity, including cyberattacks and scams, and enforce our Terms of Use.
  • Personalize your experience on the Services: We may use your Personal Information to gain a better understanding of your preferences and interests so we can improve and offer products, Services, and marketing to better serve you.
  • To comply with our legal obligations and respond to legal proceedings: We may use your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements, including anti-money laundering (AML) laws, know-your-customer (KYC) requirements, and risk assessment and transaction monitoring obligations. We may use your Personal Information to comply with lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities and to establish, exercise, or defend against legal claims.
  • To send marketing communications: With your consent, we may use your Personal Information for marketing purposes, such as to send you communications (including email, as permitted by law) about promotions, upcoming events, and other news about products and Services offered by us. You can opt-out of our marketing and promotional communications at any time (see the “Your privacy choices” section below).
  • For other purposes: We may use your Personal Information for other purposes consistent with the context of the collection of your Personal Information, as otherwise disclosed to you at the time your Personal Information is collected, or with your consent.
  • To send information: We may use your Personal Information to send information, including technical notices, updates, security alerts, and administrative messages.

How do we disclose this information?

We may disclose your Personal Information to the following types of third parties:

  • Our affiliates: We may disclose your Personal Information to our subsidiaries and affiliated corporate entities for purposes consistent with this Privacy Notice.
  • Our service providers and professional advisors: We may disclose your Personal Information to our service providers and professional advisors that perform tasks on our behalf or help us operate the Services, such as providing customer support, marketing, hosting, analytics, email delivery, database management services, and identity verification and transaction monitoring services, as well as lawyers, bankers, auditors, and insurers in the course of the professional services that they render to us.
  • Third-party analytics companies: We use select third parties to collect data on how you interact with our Site. This information may be used to, among other things, improve the functionality of our Services.
  • Other third parties as reasonably necessary: We may disclose your Personal Information:
    • When we enter into a business transaction or negotiate a business transaction involving a corporate divestiture, merger, consolidation, acquisition, reorganization, bankruptcy, sale, or other transfer of all or a part of our business or assets;
    • To: (1) comply with laws applicable to Enclave or respond to a request from law enforcement, a regulatory agency, or other legal process; (2) protect the legitimate rights, privacy, property interests, or safety of Enclave, our customers, business partners, personnel, or the general public; (3) pursue available remedies or limit damages; or (4) enforce our Terms of Use and other agreements and policies.

We may also disclose your Personal Information for any purpose for which we obtained your consent.

International transfers

If you use the Services or provide us with information, then any Personal Information we obtain will be transferred to, processed, and stored in the Cayman Islands and other locations where Enclave or its service providers operate in accordance with this Privacy Notice and applicable laws. By using the Services or providing us with your Personal Information, you understand that your information will be collected from and processed in the Cayman Islands, and other countries where Enclave and its service providers operate and acknowledge that your Personal Information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

If you are a European user, please review the “Notice for EEA residents and others” section.

Retention

We retain personal information for as long as it is necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, such as tax, accounting, fraud prevention, to assist in investigations, to resolve disputes, to establish or defend legal claims, or other legal requirements.

How do we secure this information?

We maintain appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, the security of information transmitted through the internet can never be guaranteed. Users of the Services are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password-protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services without notice pending an investigation if any breach of security is suspected.

Minors

We do not knowingly collect Personal Information from or market to persons under the age of 18. If we learn that Personal Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records. If you believe a child under 18 years of age has provided us with Personal Information, please contact us at [email protected] with a brief description of your concern.

Your privacy choices

Opt out of marketing communications: You may opt out of receiving newsletters, promotional emails, and other marketing communications from us at any time by following the unsubscribe link in the footer of an email you receive from us or by contacting us at [email protected]. Please be aware that even if you unsubscribe from marketing emails, you will continue to receive emails from us concerning legal matters in connection with your registration and other important topics.

Opt out of Cookies: Please read our Cookie Notice for information about how to opt-out of the use of certain cookies.

Do Not Track: Some web browsers include a Do Not Track (“DNT”) feature setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We are committed to providing you with meaningful privacy choices about the information collected through the Site. However, like many websites, our Site is not currently designed to recognize a DNT browser signal.

Notice for EEA residents and others

If you are a data subject in the European Economic Area, the United Kingdom, or Switzerland, you may have certain rights with respect to your personal data pursuant to the General Data Protection Regulation of the European Union (“GDPR”) and the applicable local data protection laws.

Data subjects in other countries may have broadly comparable rights to those under the GDPR by virtue of the Data Protection Act (as revised) ("DPA") of the Cayman Islands to the extent that their data is either processed by Enclave, any affiliate of Enclave, or any service provider to Enclave in each case in the Cayman Islands.

References to “Personal Information” in this Privacy Notice are equivalent to “personal data” as defined under the GDPR and the DPA.

For all purposes of the GDPR and other relevant legislation and to the extent applicable, Enclave Global Inc. is the "controller" of your Personal Information as described in this Privacy Notice. The address of Enclave Global Inc. is as follows: c/o CO Services Cayman Limited, P.O. Box 10008, Willow House, Cricket Square, George Town, Grand Cayman, KY1-1001, Cayman Islands.

We process your personal data for the purposes and in reliance on the legal bases below.

PurposesCategories of personal dataLegal bases
Provide and improve our Services
  • Identity
  • Contact information
  • User communications
  • Technical data, including device data
  • Usage data
  • Transaction data
  • Cookies
Performance of the contract / Steps prior to entering into a contract
Build and maintain our relationship with Services’ users
  • Identity
  • Contact information
  • Marketing data
  • User communications
  • Cookies
Performance of the contract
Maintain the security of the Service, including compliance and fraud prevention
  • Technical data, including device data
  • Usage data
  • Cookies
Legitimate interest of Enclave to ensure the security of its Services
Personalize the experience of Services’ users on the Services
  • Identity
  • Contact information
  • User communications
  • Technical data, including device data
  • Usage data
  • Cookies

Consent of the Services’ users pursuant to the ePrivacy Directive, where required by the applicable law; and

Legitimate interest of Enclave for the further processing of data resulting from cookies

Comply with the legal obligations and respond to legal proceedings
  • All data categories
Legal and regulatory obligations to which Enclave is subject
Send marketing communications
  • Identity
  • Contact information
  • Marketing data
Consent of the Services’ users to receive marketing communications, pursuant to the ePrivacy Directive and/or applicable law

Your rights

If you are an EU or Cayman Islands resident, or if your data is processed by Enclave or any affiliate of Enclave or any service provider to Enclave in each case in the Cayman Islands, you have the following rights with respect to your personal data pursuant to the GDPR and/or the DPA (as applicable), which rights may also be available in another EEA jurisdiction or Switzerland:

  • Right of access. The right to obtain: (i) confirmation of whether, and where, we are processing your Personal Information; (ii) information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your Personal Information; and (iv) a copy of the Personal Information we hold about you.
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
  • Right to withdraw consent. If you have provided consent for the processing of your Personal Information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Information before your withdrawal. However, in certain circumstances, if you withdraw your consent, we might not be able to continue providing Services to you as a result.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

Under the GDPR and/or the DPA, the exercise of these rights is based on the legal basis of each processing, as described in this Privacy Policy, as follows:

AccessRectificationErasureRestrictionInformation portabilityObjection
ConsentYesYesYesYesYesWithdrawal of consent
Steps prior to entering into a contractYesYesYesYesYesNo
ContractYesYesYesYesYesNo
Legitimate interestYesYesYesYesNoYes
Legal obligationYesYesNoYesNoNo

If you would like to exercise any of these rights, please contact us at the email in the “Contact us” section by filling out the “Data Subject Application Form”. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.

If you would like to exercise any of these rights, please contact us at the email in the “Contact us” section by filling out the “Data Subject Application Form”. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government issued identification documents.

You may also lodge a complaint with your local data protection authority or, where appropriate, with the Office of the Ombudsman in the Cayman Islands (contact details for the latter are: The Ombudsman, PO Box 2252, Grand Cayman KY1-1107, Cayman Islands; Email: [email protected]; Phone: +1 (345) 946 6283).

Third-party links

While browsing our Site, you may encounter and choose to access websites or online services operated by our business partners, companies or agencies that may not be associated with us by clicking on hypertext links or icons. These websites may collect data or Personal Information about you and your online activities. We do not control and are not responsible for what these other parties do in connection with their websites or online services, or how they handle your Personal Information.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Privacy Notice for the latest information on our privacy practices.

Any modifications to this Privacy Notice will be effective upon our posting of the updated terms.

Contact us

We welcome your comments or questions about this Privacy Notice. You may contact us at [email protected].