Privacy Policy

We are staunchly committed to protecting and meticulously safeguarding your privacy and personal data through advanced protection protocols and comprehensive security measures across our entire platform.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. In this role, we are responsible for maintaining comprehensive oversight of how your personal information is collected, used, and protected throughout our systems.

We may process usage data (“usage data”), which comprehensively includes browser type and version, operating system details, page view timestamps, time spent on pages, navigation paths, interaction patterns, feature utilization metrics, and device-specific information. This information is collected through automated logging systems, cookies and similar technologies, and user interaction tracking and may include frequency of visits, preferred features, common navigation patterns, typical session duration, and peak usage times. The source of this data is our analytics tracking system, user devices, and server logs. We process this information for several important purposes, including improving website performance, enhancing user experience, identifying technical issues, and analyzing usage patterns, which enables us to optimize our services, personalize content delivery, and maintain platform stability. The legal basis for this processing is our legitimate interests in monitoring and improving our website and services.

We may process account data (“account data”), which comprehensively includes email address, username, password hash, account creation date, subscription status, payment information, and account preferences. This information is collected through registration forms, account updates, and subscription management systems and may include billing details, communication preferences, and security settings. The source of this data is direct user input during account creation and management. We process this information for account authentication, service provision, payment processing, and communication management, which enables us to maintain secure user accounts, process transactions, and deliver personalized services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process profile data (“profile data”), which comprehensively includes name, professional title, company affiliation, industry sector, investment preferences, blockchain experience level, and areas of interest. This information is collected through profile completion forms, preference settings, and user surveys and may include professional background, investment goals, and platform usage preferences. The source of this data is your direct input and profile updates. We process this information for personalizing content delivery, matching services to user needs, improving user experience, and facilitating community interactions, which enables us to provide relevant content, targeted recommendations, and appropriate service levels. The legal basis for this processing is our legitimate interests in providing personalized services and maintaining appropriate user records.

You have the following rights regarding your personal data:

Right to Access
You have the right to access your personal data, which means you can request and receive a comprehensive copy of all personal information we hold about you. This includes the ability to verify the data we process, understand how we use your information, and confirm the legal basis for processing. To exercise this right, you can submit a formal data access request through our secure online portal or by contacting our data protection officer directly. We will respond within 30 days and may require government-issued identification, proof of address, and account verification details to verify your identity.

Right to Rectification
You have the right to rectification, which means you can request corrections or updates to any inaccurate or incomplete personal data we hold about you. This includes the ability to update contact information, correct profile details, and modify account preferences. To exercise this right, you can either use our account settings interface or submit a formal correction request through our support system. We will process your request within 15 business days and may require current account credentials, specific information to be corrected, and supporting documentation to verify the accuracy of the new information.

Right to Erasure
You have the right to erasure (also known as the right to be forgotten), which means you can request the deletion of your personal data when there is no compelling reason for its continued processing. This includes the ability to delete your account, remove specific data points, and withdraw processing consent. To exercise this right, you can submit an erasure request through our dedicated privacy portal or contact our privacy team directly. We will process your request within 30 days and may require account password verification, written confirmation of erasure request, and identity verification documents to protect against unauthorized deletion requests.

Right to Restrict Processing
You have the right to restrict processing, which means you can limit the way we use your personal data while still maintaining the information on our systems. This includes the ability to pause marketing communications, limit data analysis usage, and temporarily suspend account processing. To exercise this right, you can use our privacy preference center or submit a formal processing restriction request. We will respond within 10 business days and may require account verification, specific processing limitations desired, and confirmation of restriction period to implement your request accurately.

Right to Data Portability
You have the right to data portability, which means you can receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller. This includes the ability to download your data archive, transfer account information, and migrate profile details to other services. To exercise this right, you can use our data export tool or submit a portability request through our privacy center. We will fulfill your request within 30 days and may require two-factor authentication verification, specific data format preferences, and receiving controller details to ensure secure data transfer.Data Processing and Security Measures

We process Service Data which includes account credentials, user profiles, service preferences, and authentication details. This processing involves secure storage, encryption, and validation methods, enabling us to provide secure account access and personalized services. For example, in the context of finance, this includes managing digital wallet configurations and blockchain transaction preferences. The legal basis for this processing is contractual necessity and legitimate interests, specifically to maintain service security and user account integrity.

We process Technical Data which includes device information, IP addresses, browser details, and interaction patterns. This processing involves automated collection, analysis, and storage methods, enabling us to ensure platform security and optimize performance. For example, in the context of finance, this includes monitoring for suspicious transaction patterns and ensuring secure API interactions. The legal basis for this processing is legitimate interests, specifically to maintain platform security and prevent fraud.

We process Communication Data which includes email correspondence, support tickets, and platform notifications. This processing involves secure message handling, automated routing, and response management, enabling us to provide effective customer support and service updates. For example, in the context of finance, this includes transaction confirmations and security alerts. The legal basis for this processing is contractual necessity and legitimate interests.

We process Transaction Data which includes blockchain transactions, wallet addresses, and financial operations. This processing involves secure recording, verification, and audit trail maintenance, enabling us to facilitate secure financial operations. For example, in the context of finance, this includes cryptocurrency transfers and smart contract interactions. The legal basis for this processing is contractual necessity and legal obligations, specifically to comply with financial regulations.

We process Preference Data which includes user settings, notification preferences, and customization options. This processing involves preference management and personalization engines, enabling us to deliver tailored user experiences. For example, in the context of finance, this includes trading preferences and risk tolerance settings. The legal basis for this processing is consent and legitimate interests.

Security Measures

Our comprehensive encryption protocols ensure end-to-end protection of your data, incorporating industry-standard algorithms and regular security updates to maintain data integrity. This includes regular security assessments and penetration testing by qualified professionals.

We implement multi-layered security infrastructure, including advanced firewalls and intrusion detection systems that continuously monitor for and prevent unauthorized access attempts. This infrastructure undergoes regular updates and enhancements.

Access to personal data is strictly controlled through role-based permissions, multi-factor authentication, and detailed access logs. We maintain comprehensive audit trails of all data access and modifications.

Our continuous monitoring systems provide real-time threat detection and automated response protocols, ensuring immediate action against potential security threats.

We maintain comprehensive backup procedures with encrypted offsite storage and regular recovery testing, ensuring data availability and integrity.

All staff undergo regular security awareness training and must comply with detailed data protection protocols, including specific training for handling sensitive financial data.

International Transfers

We may transfer your personal data to countries outside your jurisdiction. These transfers are protected by appropriate safeguards, including Standard Contractual Clauses, Binding Corporate Rules, and approved certification mechanisms. Each international transfer is conducted under strict protocols that ensure:

Adequate data protection standards
Compliant processing procedures
Enforceable data subject rights
Effective legal remedies

International transfers are protected by ISO 27001, GDPR standards, and industry-specific regulations, ensuring compliance with international data protection laws. We implement additional measures including:

Regular compliance audits
Data protection impact assessments
Documented transfer mechanisms
Continuous monitoring procedures

Regarding international transfers, you maintain specific rights including:

Right to information about transfers
Right to object to transfers
Right to withdraw consent
Right to data protection guarantees

Data Retention

We maintain specific retention periods for different data categories:

Account Information: Retained for the duration of account activity plus 5 years for legal compliance and fraud prevention
Usage Data: Retained for 2 years to support platform optimization and security analysis
Transaction Records: Retained for 7 years to comply with financial regulations and audit requirements
Communication History: Retained for 3 years to support customer service and dispute resolution
Technical Logs: Retained for 1 year for security monitoring and system optimization

These retention periods are determined by:

Legal requirements
Business purposes
Technical necessities
User preferences

Special circumstances affecting retention:

Legal obligations
Dispute resolution
Security investigationsCookie Policy for Factom.com

Essential cookies serve fundamental functions for our website’s core operations. These cookies process authentication tokens, session identifiers, and security parameters to enable secure access to financial services. For example, in our finance context, these cookies maintain secure login sessions for cryptocurrency wallet access and transaction verification.

Essential cookies are vital to website functionality. These cookies protect user accounts, verify transaction authenticity, and maintain secure connections throughout your session. We use them specifically for:

User authentication
Security measures
Basic site operations
Session management
Technical stability

Functional cookies enhance your experience by remembering your preferences. They process user settings and interface choices to optimize your interaction with our financial platform. They enable:

Language preferences
Region-specific content
User interface customization
Feature optimization
Personalized settings

Analytics cookies help us understand user behavior on our platform. They collect anonymized information about how users interact with our financial tools and services, including:

Page interactions
Navigation patterns
Feature usage
Session duration
User preferences

Performance cookies assess and improve website operation by monitoring technical aspects of our platform. They ensure optimal delivery of our financial services by:

Monitoring site speed
Identifying technical issues
Optimizing content delivery
Analyzing user experience
Tracking system performance

Cookie Management

You can control cookie preferences through:

Browser settings
Cookie consent tools
Privacy preferences
Account settings

Compliance Measures

For EU residents, we ensure:

Explicit consent mechanisms
Data minimization
Purpose limitation
Storage limitations
Processing transparency

California residents have additional rights:

Right to know about personal information collected
Right to delete personal data
Right to opt-out of data sales
Right to non-discrimination
Right to access collected information

Regarding users under 13:

Age verification requirements
Parental consent procedures
Limited data collection
Special protection measures
Parental access rights

Policy Updates

Policy updates involve:

Regular review procedures
User notifications
Consent renewal when required
Clear change documentation
Continuous compliance monitoring

For privacy-related inquiries:

Primary Contact: [email protected]
Response Time: Within 48 hours
Verification Required: For data-related requests
Available Support: Privacy concerns, data requests, rights exercise

This policy was created specifically for factom.com and covers all associated services within the finance industry.

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