Privacy Policy

1. Fundamentals:

We don’t ask you for personal information unless we truly need it.

We don’t share your personal information with anyone except to provide you with the Poet service, comply with the law, develop our products, or protect our rights.

We don’t store personal information on our servers unless required for the on-going operation of one of our services. We aim to make it as simple as possible for you to control what’s visible to the public, seen by search engines, and permanently deleted. Our privacy policy incorporates these fundamental principles.

2. Changes to the 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. Consent:

By using the Site, the App or our Services, you consent to the use of your Personal Information, as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Site and/or the Services.

Two types of information may be collected through the Site and our Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of Non-Personal Information (as defined further below).

"Personal Information" is any information about an identifiable individual, such as your name, telephone number, address, email address, and work experience or other resume information. Personal Information does not include information that is anonymous or aggregated so that it does not identify a specific individual.

"Non-Personal Information" is information of an anonymous nature that is not linked to an individual, and may include an Internet Protocol Address (IP Address), the domain used to access the Site, App and/or Services, and the type and version of browser or operating system being used by visitors to the Site. It also includes aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, subpages accessed, and average time spent on the Site and/or App. We may use Non-Personal Information for any purpose, including, but not limited to, developing, manufacturing and marketing products, and improving the Site, App and/or Services. Non-Personal Information is collected or derived by Us in the course of operating this Site and the Services. For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you choose to visit the Site and/or use the Services. We may also collect Non-Personal Information from third parties, such as our business partners, advertisers, and analytics providers.

Business contact information such as the name, title, business address, email address, or telephone number of a business or professional person or an employee of an organization is generally not considered Personal Information under applicable privacy laws. However, if such information is linked to an individual, it may be considered Personal Information.

We may also use tracking technologies to automatically collect information including the following

Log Files, which are records of actions taken on the Site and/or App, including the IP address of the device used to access the Site and/or App, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data.

Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We will only use strictly necessary cookies in connection with the Site and Services. For the avoidance of doubt, the cookies that we include are essential for you to browse the Site and use its features, including accessing secure areas of the Site. We do not use cookies to collect Personal Information.

4. Sharing and Disclosure of Personal Information:

We may employ third parties to help Us improve or otherwise make available features on the Website, App and/or the Services, whether through the provision of maintenance services, database management, Web analytics or otherwise. We may also use third parties to provide services to Us, such as hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing (including KYC and AML) and other similar services. We may share your Personal Information with these third parties, but only to the extent necessary to perform these services.

We have put in place contractual and other organizational safeguards with our agents to provide a reasonable level of protection for your Personal Information (see further Security below). In addition to those measures, We will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy.

We may share your Personal Information with our Professional Advisors for purposes of audits and compliance with our legal obligations.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities. We are not responsible for the privacy policies of those entities.

5. Security:

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff or other permitted persons or companies as are reasonably necessary to carry out the stated purposes We have communicated to you.

6. Retention:

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, Non-personal Information, Account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

7. Access and Accuracy:

You have the right to access the Personal Information We hold about you in order to verify the Personal Information We have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request by email to privacy@poet.network, We will confirm receipt of your request within ten (10) days. We will endeavour to deal with all requests for access and modifications in a timely manner. We will provide you with a copy of your Personal Information within thirty (30) days, although in certain limited circumstances, We may not be able to make all relevant Personal Information available to you such as where that information also pertains to another individual or as otherwise required or permitted by law. In such circumstances We will provide reasons for the denial to you upon request.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and We will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.

8. Additional Disclosures for California Residents:

A. 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.

B. We may collect and use information about your Internet Activity (automatically collected information about your usage of our Site and App) and Geolocation Data for the business purposes described in this Privacy Policy, 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.

C. Right to Know and Delete.You have the right to know certain details about our data practices within the past twelve (12) months. Once we receive and confirm your verifiable request, 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@poet.network. 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.

D. 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.

E. 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.

9. 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: privacy@poet.network