Privacy policy

Last Updated Date: January 3, 2019

Commonwealth Crypto, Inc. (“Company”, “we” and “us”) has prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at http://arwen.io (the “Website”), our trading application (“Application”) and services enabled via the Website and/or Application (collectively with the Website and Application, the “Services”).

Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

Commonwealth Crypto, Inc.

c/o Underscore VC

45 School St, Floor 2

Boston, Massachusetts 02108

A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at info@arwen.io.
A Note to Users Outside of the United States. If you are a non U.S. user of the Services, by accessing or using the Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
Types of Data We Collect. “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 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.
Information You Provide to Us.
We may collect Personal Data from you, such as your first and last name and e-mail address when you register for an account (“Account”) or download the Application.
The Application, once downloaded on your device, will collect (i) your login credentials, including API account keys, (“Credentials”) to certain cryptocurrency exchanges (each such exchange that is available through the Services at any given time, an “Exchange”) to which you want to integrate with the Services, (ii) your Application preferences, (iii) your password, and (iv) information on holdings, open orders and trading history for any Exchange you accessed through our Application. This information is stored locally within the Application on your device and is not collected or stored by us.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
We may also collect Personal Data, such as at other points in our Services that state that Personal Data is being collected.
Information Collected via Technology.
Information Collected by Our Servers. To make our Website 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, 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 Website, track users’ movements around the Website, 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 Website again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
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 Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs.
Pixel Tags. 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. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Website.
Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you access or use the Services. This includes third party analytics services, including but not limited to Deskmetrics and Loggly (“Analytics Services”), that we engage to help analyze how users use the Services, as well as third parties that deliver content or offers. 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 Services, 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 at info@arwen.io. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/.
Exchange Data. By providing your Credentials within the Application, (a) the Services may access, make available and store (if applicable) certain data and information that you have provided to and stored in such Exchange, such as holdings data, information on open orders and trade history, so that it is available on and through the Application via your Account, and (b) the Application may transmit and receive additional information to such Exchange (all such data and information, the “Exchange Data”) as necessary to provide the Services, such as to execute trades on your behalf through such Exchanges. This information is stored locally within the Application on your device and is not collected or stored by us.
Use of Your Personal Data
General Use. 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:

to operate, maintain, and improve our websites, applications, products, and services;
to respond to comments and questions and provide customer service;
to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
facilitate the creation of and secure your Account;
provide the Services you request;
improve the quality of experience when you interact with our Services;
send you administrative e-mail notifications, such as security, or support and maintenance advisories; and
to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

User Testimonials and Feedback. We often receive testimonials, feedback and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user’s consent prior to posting his or her name along with the content. If you make any comments on a blog or forum associated with our Services, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. In addition, Company may use and disclose such comments in accordance with our Terms of Use and this Privacy Policy. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
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 reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
Exchanges. The Application may transmit via API certain of your Personal Data for the purpose of providing the Services. However, this information is shared directly from your device and not via Company’s servers.
Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Services; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company.
Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
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.
Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (iii) to protect or defend the rights or property of Company or users of the Site or Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
Third Party Websites. Our Services may contain links to third party websites. When you click on a link to any other website or location, you will leave our Website or Application and go to another site or application and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:
Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.
Cookies. If you decide at any time that you no longer wish to accept Cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
Changing or Deleting Your Personal Data. You may change any of your Personal Data in your Application by via the “settings” screen of the Application. You may request deletion of your Personal Data collected by our Website by emailing us at info@arwen.io, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud, billing, or similar purposes.
Applications. You can stop all collection of information by the Application by uninstalling the Application from your device.
Security of Your Personal Data. Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security. Notwithstanding the foregoing, you, and not Company, are solely responsible for the security of your device(s) on which the Application is downloaded.
Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Website and/or Application. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data, you must, prior to the effective date of the changes, delete our Application from your device and notify us that you wish to deactivate your Account with us. Continued use of our Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.