General Privacy Policy

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Effective Date: 01 January 2021

1. Overview

This General Privacy Policy (“Privacy Policy”) explains what types of personal information, sometimes referred to as personal data, we may collect or obtain about our customers, business contacts, vendors, and website users as well as how it may be used.

In this Privacy Policy the terms “Chainalytics,” “ we,” ” us,” and “ our” refers to Chainalytics, Inc. along with its affiliates and subsidiaries.

While this Privacy Policy is intended to describe the broadest range of our information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we have adjusted our internal policies and practices to reflect the requirements of local law.

2. Chainalytics is a global company headquartered in the United States

Chainalytics is a global company with its headquarters located at: 2500 Cumberland Parkway, Suite 550, Atlanta, Georgia 30339, United States. Our main office number is +1 (770) 433-1566.

To facilitate our global operations as well as to fulfill our legal and contractual obligations, we may access, process, or transfer personal information in one or more countries or territories. A list of Chainalytics’ global offices is available at http://staging.chainalytics.com/locations/. This means that your personal information may be accessed, processed, and/or transferred to a country or territory other than the one in which you reside, and such country or territory may not offer the same level of data protection as your country or territory. Nevertheless, our internal safeguards and policies, which comply with the laws and regulations of the countries and territories where we conduct business, are consistent across all geographies.

3. Applicability of other Chainalytics privacy policies

Some of our services, products, and websites may have separate privacy policies and terms of use that apply to their use. Any personal information collected in connection with your use of those services, products, or websites are not subject to this Privacy Policy.

4. What personal information do we collect?

Chainalytics may collect or obtain the following personal information during our course of doing business:

  • An individual’s name
  • An individual’s phone number
  • An individual’s email address
  • An individual’s employer
  • An individual’s title and/or role
  • Inbound IP address

Such personal information is sourced directly from the individual or their employer.

5. How we use the personal information we collect

Chainalytics collects personal information for one or more of the following purposes:

  • Managing contractual relationships with individuals and their employers
  • Operating and managing our business
  • Complying with legal requirements
  • Monitoring the use of our systems
  • Improving the security and functioning of our websites and networks
  • Undertaking data analytics
  • Providing relevant content and advertisements
 

All of the above items are necessary to for us to fulfill our contractual obligations and/or to serve our legitimate business interests. Chainalytics is of the opinion that our legitimate interests are not overridden by your interests, rights, and freedoms given (i) the transparency we provide to our processing activities, (ii) our regular privacy reviews, and (iii) the rights you have in relation to how your information is processed.  You may contact us at privacy@chainalytics.com if you wish to obtain further information on the intended purposes of processing your personal information.

Please note that we will not process your personal information for purposes that are inconsistent with the purpose(s) stated above unless we receive your express consent or it is required or authorized by law.

6. Sensitive personal information

We do not generally collect sensitive data (also known as special data categories) through our websites or otherwise. In the limited cases where we do have access to such data, we will do this in accordance with data privacy laws and/or ask for your express consent.

7. Data security

We maintain organizational, physical and technical security arrangements for all the personal information we hold. We have protocols, controls, and relevant policies in place to maintain these arrangements. In addition, we have regular penetration testing performed by a third party provider, which continues to show the strength of our technical defenses.

8. Third party data sharing

In certain circumstances, in order to fulfill a legal or contractual obligation, or on the basis of your express consent, we may transfer personal information to the following types of third parties:

  • Service provider (including software vendor or other partner organization)
  • Professional advisor
  • Governmental authority
  • Third-party corporate entity in connection with a commercial transaction
  • Third-party corporate entities in connection with data analytics and/or providing relevant content and advertising
 

Such third parties may be located in other countries or territories. Before we transfer your personal information, we will take the necessary steps to ensure that your personal information is adequately protected as required by relevant data privacy laws and Chainalytics’ internal policies.

9. Cookies and other tracking technologies

To the extent that you agree, we may collect information about how you interact with our website and other media sites such as LinkedIn. The information that we collect may include IP address, device identifier, web browser, and browsing information collected through cookies and similar technologies. The information may be associated with a unique identifier as well as with any other personal information you have provided to us.

10. Retention of collected personal information

Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your personal information only for as long as we believe it is necessary to fulfill the purpose(s) for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirement or obligation).

As stated in Article 11, you may request that we delete your personal information. However, please note that there are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal information. In the event that we cannot delete your personal information, we will inform you of the reason(s) why, subject to any legal or regulatory restrictions.

11. Requests to access, delete, or correct personal information, or withdrawal consent

You may submit a request to access, delete, correct, or transmit your personal information to privacy@chainalytics.com. Note that any request to delete your personal information may not result in deletion of any personal information that you submitted to a third party. If you require the third party to delete any of your personal information, you must contact the third party directly to request such deletion.

In certain circumstances you may have provided express consent when providing certain personal information to us or provided consent for a specific use of your personal information. In certain countries you may have a right to withdraw such consent. Please submit requests to withdraw your consent to privacy@chainalytics.com.

12. Resolving your concerns

If you have questions or concerns regarding the handling of your personal information please contact privacy@chainalytics.com. Alternatively, you may report concerns or complaints, including information about potential data breaches involving personal information to the appropriate supervisory authority.

13. Changes to Privacy Policy

This Privacy Policy is reviewed by us periodically to ensure that it accurately captures all types of personal information collected as well as how we manage this information. We may, therefore, change this Privacy Policy at any time. The effective date of each version of this Privacy Policy is identified at the top of the page.