Privacy Policy

Gelt Finance Inc of 2261 Market Street, San Francisco, California, USA (“us”, “our”, “we”, “the company”) is the controller of your personal data collected through our website and services hosted on opencover.com (the “Website”, “Service”, “OpenCover”). We are committed to protecting and respecting your privacy.

This privacy policy (the “Policy” or “Privacy Policy”) sets out the types of personal data we collect and use when users access and visit the Website (including prospective customers and mere browsers of the Website) and when our customers share personal data with us. The Policy sets out how we may use that data.

1. Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through your use of the Website and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

In general, our services do not involve the processing of personal data and rely on blockchain interactions managed through your self-custodial wallet. However, some OpenCover features necessitate the sharing of personal data with us and this privacy policy takes into account those options.

When you supply any personal data to us, we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:

1. Introduction
2. What information can we collect?
3. How is your personal information collected?
4. How and why do we use your personal information?
5. For how long do we keep your personal information?
6. International data transfers
7. Contact details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Policy supplements other OpenCover notices and is not intended to override or replace them.

By visiting or otherwise using OpenCover, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using OpenCover.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Website know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please note that the Website is not directed at children under the age of 18 (each a "Child" or "Children") and we do not knowingly collect personal data about Children.

2. What information can we collect?

The data we collect from you may include:

• Self-custodial wallet address used for purchases;
• Email address, if and only if, you choose to receive email notifications or subscribe to our newsletter (not required);
• Usage Data which includes direct and customer support interactions, feedback and survey responses and automated tracking.

3. How is your personal information collected?

Direct interactions

When you use the OpenCover website or products we may collect, store and use the personal data that you disclose to us.

Automated technologies or interactions

We may also collect information about you when you visit and interact with OpenCover through the use of technologies such as cookies. The following are examples of information we may collect:

• information about your device, browser or operating system;
• information about links that you click and pages you view on the Website;
• length of visits to certain pages;
• page response times;
• records of download errors and/or broken links;
• page interaction information (such as details of your scrolling, clicks, and mouse-overs);
• the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).

We use the data described above to help us deliver the best products and experiences possible.

4. How and why do we use your personal information?

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

• Where you have asked us to do so;
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Sharing your personal data

• We may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, where subsidiaries and holding companies are those under common control such that either more than 50% of the beneficial interest in the issued share capital or the legal power to direct or cause the direction of the general management of the company belongs to the same entity.

We may also disclose your personal data to third parties in the following events:

• If we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
• If OpenCover or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or;
• In order to enforce or apply the Website’s terms of use or terms and conditions of sale; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Links to third party sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with OpenCover such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

Cookies

Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

We use cookies for a number of purposes including cookies that are strictly necessary for the functioning of the website. The website may operate properly without these cookies and for analytics that help us understand how you and other users interact with our website by collecting data that does not directly identify you.

5. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

By law we have to keep basic information about our customers (including contact, identity, and financial data where applicable) for six years after they cease being customers for compliance purposes. In some circumstances you can ask us to delete your data by directly contacting us (see below).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data does directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

6. International Data Transfers

Please note that some of our service providers may be based in territories around the World. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information and the provision of services or support services.

Where we transfer your data to a service provider, we seek to ensure that appropriate safeguards are in place to make sure that personal data is held securely and that data subject rights are upheld. Where we use certain service providers, we may use either specific contractual clauses mandated by regulators or require additional safeguards to be in place in order to give personal data greater protections.

7. Contact details

If you have any queries regarding this Privacy Policy or if you wish to exercise any of your rights or if you think that the Privacy Policy has not been followed, please contact us by emailing at legal@opencover.com