Privacy Policy
Last Updated: 2023-03-01
At Foundry, we value your privacy and strive to protect your personal data. Foundry Digital LLC and its subsidiaries (collectively, “Foundry”, “we”, “our”, and “us”) will only collect and use data in accordance with this Privacy Policy (“Policy”). By accessing and using our services, you signify acceptance to the terms of this Privacy Policy.
In the event of a change in this Policy, a revised Policy will promptly be posted to our website. You agree to accept the posting of a revised Policy electronically on the Foundry website as actual notice to you. You can determine when this Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to this Privacy Policy will become effective upon our posting of the revised Privacy Policy on our website. Any dispute over our Policy is subject to this notice.
This Privacy Policy explains:
- What data we collect.
- How we collect, process, use and share your personal data.
- The important security measures we maintain to secure your personal data.
- What rights you have with respect to your personal data we collect.
- Why and how we retain your personal data.
What data we collect.
To provide you with our products and services, or communicate with you, we may need to collect, process and in some cases, share personal data.
We may collect the following types of personal data. Note, this is not an exhaustive list.
- Institutional information such as employer identification number (or comparable number issued by a government), proof of legal formation (e.g., Articles of Incorporation), personal identification information for all material beneficial owners.
- Financial information such as your source of funds.
- Personal identification information such as your full name, date of birth, nationality, cellphone or mobile number, email address, place of residence, and/or national identification number or social security number.
- National identity documentation such as information related to your national identity document, drivers’ license or passport (including any relevant visa information) and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
- IP address.
- Additional information or documentation at the discretion of our Compliance Team may be required for compliance with law, regulations, or internal policies.
How we collect, process, use, and share your data.
Data is collected in various ways, including:
- When you provide it to us (e.g., when you sign up for or use our products and services or take part in customer surveys).
- When you communicate with us by email, chat, telephone, or any other means, we collect the communication and any personal data provided in it.
- When we obtain information from third parties including but not limited to identity verification services, Google Analytics and Datadog. Note: some of these services may use cookies.
We will only collect, use, share or otherwise process your personal data where it is necessary for us to carry out our lawful business activities and subject to data protection laws. In doing so, we rely on one or more of the following lawful grounds for processing your personal data:
- Commercial obligation: We may process your personal data where it is necessary in order for us to provide our products and services to you or to otherwise comply with our obligations under Foundry’s Terms of Use.
- Consent: In some cases, we will only process your personal data where you provide us with your express consent for such processing.
- Legal obligation: In some cases, we may need to process your personal data in order to comply with an obligation imposed by law.
- Legitimate interest: In some cases, we may need to process your personal data where it is in our legitimate legal interests to do so.
Foundry may use your personal data for one or more of the following purposes:
- Verify your identity.
- Perform sanctions screening.
- Detect and prevent fraudulent or unauthorized use of our products and services.
- Better manage our business and your relationship with us.
- Improve products and services.
- Market products or services to you.
- Respond to your inquiries and resolve disputes.
We may share your personal data with:
- Trusted third-party identity verification services in order to prevent fraud. This allows Foundry to confirm your identity by comparing the information you provide us to public records and other third-party databases.
- Trusted third-party service providers under contract who help with parts of our business operations such as professional advisers, consultants, technology services, and other similar services. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else.
- Companies or other entities that we plan to merge, combine or consolidate with or be acquired by (whether in whole or in part). Should a merger, combination, or consolidation occur, we will require that the new combined and/or surviving entity (as the case may be) follow this Privacy Policy substantially with respect to your personal data.
- Affiliates who require this information to provide the services you request. An affiliate is an entity that we own or control, or that is under common control with us.
- Regulatory agencies, law enforcement, or other government authorities, including during routine regulatory examinations.
International transfers of your personal data.
Foundry is a global organization and, while providing our products and services to you, your personal data may be transferred to, stored and processed outside of the jurisdiction in which you reside, and the laws of those countries may differ from the laws applicable in your own country. For example, data collected in the European Economic Area (EEA) may be transferred to, stored and processed at a destination(s) outside of the EEA (including the United States of America). By accepting this Privacy Policy, and then submitting your personal data, you expressly consent to the transfer, storing or processing of such personal data outside of your jurisdiction and subject to the laws of the applicable jurisdiction.
Electronic marketing.
Where you have opted-in to receive marketing communications and news, we may share information about our products, services, news and promotions with you. If you have opted-in to receive marketing communications, you may always opt out at a later stage by clicking on the “Unsubscribe” option included in every marketing communication sent to you. Please note that unsubscribing from marketing content will not stop you from receiving important communications from Foundry in relation to the security or operation.
Minor information.
Our website, as well as Foundry product and services, are not intended for anyone under 18 years of age (“Minor”). We do not knowingly or intentionally gather or process Personal Data about Minors. If we learn that we have collected any Personal Information from a Minor, we will promptly delete it from our systems.
The important security measures we maintain to secure your personal data.
Foundry places great importance on ensuring the security of your personal data. We regularly review and implement appropriate and reasonable technical and organizational security measures to keep your personal data safe. Employees of Foundry are trained to handle personal data securely and with the utmost respect, failing to do so may be subject to disciplinary action. Although we take steps to secure your personal data, we cannot guarantee that your personal data will always remain secure and, in the event of a data breach, we will notify you and, where applicable, the relevant supervisory authority, of any data breach in accordance with local law. Importantly, you are responsible for securing the login credentials and otherwise complying with the Account Security section of Foundry’s Terms of Use.
If at any time you choose to purchase a product or service offered by another company, any personal data you share with that company will be subject to the privacy policies of the applicable third-party companies and will not be controlled by our Privacy Policy. We are not responsible for the privacy policies or the content of third-party sites and/or services (each, a “Third-Party Service”) we link to and have no control of the use or protection of information provided by you or collected by those Third-Party Services.
We have security standards and procedures in place designed to prevent unauthorized access to your personal data. A key part of this process helps ensure that the personal data we have about you is accurate and up to date. You are responsible for helping us to maintain the accuracy and completeness of your personal data. If you would like to review your personal data or if you believe that any of your information is incorrect, or if you have any questions regarding your information, or this Policy, please contact us at [email protected].
What rights you have with respect to your personal data we collect.
You may submit a request that Foundry disclose the following:
- What information did we collect?
- Why did we collect that information?
- What types of information is requested?
- Who(m) did we share the information with?
- How long did we share it?
Additionally, California law permits residents of California to request certain details about how their personal information is shared with third parties or affiliated companies for direct marketing purposes. California consumers have the right to know what personal information is being collected. As a California resident, you may also submit a request that Foundry:
- Deletes your personal information, provided that the information is not required to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation; and
- Honors your request to opt out of the sale of your personal information. Under no circumstances does Foundry sell your personal data.
If you wish to exercise any of the rights set out above, please contact [email protected].
Why and how we retain your personal data.
Foundry will retain your personal data, in compliance with this Privacy Policy for the duration of your relationship with us, and afterwards for such a period as may be necessary for our legitimate business purposes (including compliance with our legal obligations, preventing fraud, resolving disputes and enforcing agreements), to protect the interests of Foundry and its customers, and as required by law.
Contact Us
If you have any questions that the Privacy Policy does not address, please contact Foundry at [email protected].