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Sandstorm Media Privacy Policy

Last Updated: 9/09/2022

Thank you for visiting Sandstorm Media Inc. (“Sandstorm Media,” “we” or “us”). This Privacy Policy describes the personal data handling policies of Sandstorm Media as a data controller, including the following:

1.    What personal data we collect when you access and use the Sandstorm Media services, including without limitation the website located at https://sandstorm.co/ and nft.sandstorm.co (collectively, the “Services”);

2.    How we use the data;

3.    With whom we may share the personal data;

4.    Legal basis for processing the data;

5.    Storage and security of your data;

6.    Your Privacy Rights, Choices and Disclosures, including those for Europe and California;

7.    Users outside the United States; and

8.    Links to other sites;

9.    Privacy Policy updates; and

10. Contact Information.

 

1.    Personal Data We Collect or Process

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

·       Data Provided Voluntarily

We collect information that you provide to us voluntarily.  We collect the information that you provide to us when you sign up to receive newsletters, advisories, announcements and invitations and contact us by email. We use this information to respond to your comments, requests or questions.

We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, address, and Sandstorm Media password when you create an account to log in to our network.

In connection with provision of the Services through our applications, we request information about your identity that is necessary for us to comply with our own Know Your Customer and Anti-Money Laundering requirements including without limitation: first and last name, date of birth, residential address, email address, Ethereum address, Polygon (matic address), copies of identification documents such as  a passport, national ID or driver license, and a photo/”selfie” of yourself.

If you use our Services on your mobile device, we may collect your phone number and the unique device id number.

Our Services let you store preferences like how your content is displayed, your location, safe search settings, notification settings, and favorite widgets. We may associate these choices with your ID, browser or mobile device, and you can edit these preferences at any time.

When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.

Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.

We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, address, and other requested information if you contact us via e-mail regarding support for the Services.

We may also collect Personal Data at other points in our Service that state that Personal Data is being collected

Data Collected Automatically

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, address, wallet type, and/or a date/time stamp for your visit.

Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Services, it will recognize you and the information could then be used to serve advertisements and/or other information appropriate to your interests.

Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.

Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Services. This includes third party analytics services, including but not limited to Google Analytics and Mixpanel (“Analytics Services”), that we engage to help analyze how users use the Services. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Services. The information generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us.

For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here:  https://tools.google.com/dlpage/gaoptout?hl=en.

For more information on what type of information Mixpanel collects, please visit the Mixpanel’s Terms of Use page at www.mixpanel.com/terms/. You can prevent Mixpanel from using your information for analytics purposes by opting out at www.mixpanel.com/optout.

 

Social Media Pages. We operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers.  Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

·       Information Collected from Third Party Companies

We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Service. In particular, wallets provide us with your address and certain other information you choose to share with wallets. These third party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Service or from other sources.

·       No Use By Minors.

We do not knowingly collect information from users of our Services under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. By using the Services, you represent that you are at least 18 years old and that you are of legal age to enter into legal agreements.

 

2.    How We Use the Data

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

·       facilitate the creation of and secure your account on our network;

·       identify you as a user in our system;

·       provide improved administration of our Service;

·       provide the Services you request, including but not limited to facilitating your cryptocurrency transactions through wallets;

·       improve the quality of experience when you interact with our Service;

·       send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;

·       protect you and other users from any conduct that violates these Terms and Conditions or to prevent abuse or harassment of any user;

·       display your username next to the digital assets you wish to sell on the Website;

·       send you administrative e-mail notifications, such as security or support and maintenance advisories;

·       send you e-mail notifications related to actions on Service, including notifications of offers on your digital assets;

·       respond to your inquiries related to employment opportunities or other requests;

·       make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;

·       send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Sandstorm Media,

·       fulfill legal obligations we have to governmental authorities or other third parties;

·       in any other way we may describe when you provide the Personal Data; and

·       for other legitimate business purposes.

 

Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

3.    With Whom We Share Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to confirm your identity for Know Your Customer and Anti-Money Laundering requirements; and/or to provide other services to Sandstorm Media.

Affiliates. We may share some or all of your Personal Data with our affiliates.

Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

As Legally Required. Regardless of any choices you make regarding your Personal Data (as described below), Sandstorm Media may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Sandstorm Media; (c) to protect or defend the rights or property of Sandstorm Media or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms and Conditions.

Other Disclosures. We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us. Sandstorm Media may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your Personal Data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

4.    Grounds for Using Your Personal Data

We rely on the following legal grounds to process your personal information:

Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent, such as marketing email communications.  To withdraw your consent, please contact us at team@sandstorm.co or click on the unsubscribe link in the communication.  You may refrain from providing, or withdraw, your consent for Cookies via your browser and mobile settings.

Performance of a contract. We may need to collect and use your personal information to enter into a contract with you and to perform Services that you request.

Legitimate Interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content contained thereon.  We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

5.    Storage and Protection of Your Personal Data

We may retain your personal information as long as you continue to use the Services, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Policy. You can ask to close your account by contacting us at team@sandstorm.co. We may, however, retain Personal Data for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

We implement various security measures to ensure the safety of your Personal Data when you enter, submit, or access your Personal Data. All supplied sensitive information is transmitted via Secure Socket Layer technology. We engage an independent analyst to perform penetration testing.

No Internet or e-mail transmission is ever fully secure or error free, however.  We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control.  Users assume the risk of security breaches and the consequences resulting from them.  Please be careful in deciding what information you send to us via email or over the Internet.

6.    Your Rights, Choices and Disclosures

(a)      General.

 This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at team@sandstorm.co or make changes to any user profile information connected to your account.

You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at team@sandstorm.co. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information.  If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.

You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Services.

·       Your European Privacy Rights and Choices. If you reside or otherwise find yourself in the territory of Europe, your privacy rights under the European data protection law include:

·       Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.

·       Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at team@sandstorm.co.

·       Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.

·       Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.

·       Right to data portability. You have the right to data portability of your own personal data by contacting us.

·       Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.

·       Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

·       California Disclosures.

 

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed.  If you are a California resident and want such a list, please send us a written request by email to team@sandstorm.co with “California Shine The Light Rights” in the subject line.

California Do Not Track Disclosure: We do not respond to Do Not Track browser settings.

California Consumer Privacy Act Disclosures. Sandstorm Media is not a “business” subject to the California Consumer Privacy Act (CCPA).

7.    Users Outside the United States

The Services are controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities.  Personal data may also be transferred from the country of your residence to other countries, including the United States.

8.    Links to Other Sites

Our Services may contain links to other websites for your convenience or information.  These websites may be operated by companies unaffiliated with Sandstorm Media, and we are not responsible for the content or privacy practices of those websites.  Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

9.    Privacy Policy Changes

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.  Please review this Privacy Policy periodically and especially before you provide personal data to us.  If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on our home page.  The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

10.     Questions and Contact Information

Please contact us if you have any questions about our Privacy Policy. You may contact us by emailing us at team@sandstorm.co.

Please contact us if you have any questions about our Privacy Policy. You may contact us by emailing us at team@sandstorm.co. Please read our Terms and Conditions