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privacy_policy.md

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BitScreen Privacy Policy

This Privacy Policy is effective as of November 1, 2021.


This BitScreen Privacy Policy ("Policy") outlines the personal information that Murmuration Labs LLC ("Murmuration Labs," "ML," "we", "us" or "our") gathers in connection with the BitScreen software application, how we use that personal information, and the options you have to access, correct, or delete such personal information.


BITSCREEN'S PROMISE

Our mission to protect the Filecoin network from abuse is rooted in the importance we place on establishing trust with our Customers, users, and the Internet community globally. To earn and maintain that trust, we commit to communicating transparently, providing secure services, and protecting the privacy of data stored on our systems.

We keep your personal information personal and private. We will not sell or rent your personal information to anyone. We will not share or otherwise disclose your personal information except as necessary to provide our Services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.

1. POLICY APPLICATION

This Policy applies to ML's collection, use, and disclosure of the personal information of the following categories of data subjects:

  • Website Visitors: Those who visit our Websites, including those who may opt to provide an email address or other contact information to receive communications from ML, fill out a survey, or provide feedback. For the purposes of this Policy, "Websites" refer collectively to www.bitscreen.co as well as any other websites ML operates for its own behalf and that link to this Policy. For clarity, "Websites" does not include any sites owned or operated by our Customers or other third parties.
  • Customers: Individuals or entities who agree to the BitScreen Terms of Service and thereby enter into an agreement with ML, and to whom ML provides Services pursuant to such agreement. For purposes of this Policy, "Services" shall refer to all of the cloud-based or node-based solutions offered, marketed, or made available by ML that are designed to interact with storage or retrieval deals on the Filecoin Network, along with any Command Line Interface (CLI) software, and application programming interfaces ("APIs") made available in connection with the foregoing.
  • End Users: Those who (i) access or use our Customers' storage services, domains, networks, websites, application programming interfaces, and applications, or (ii) Customers' employees, agents, or contractors, who access or use Services.

This Policy also does not apply to our Customers' storage systems, domains, websites, APIs, applications, and networks, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information, in connection with the use of our Services by End Users with whom our Customers interact.

BitScreen's Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen. BitScreen does not knowingly collect personal information from any person under the age of eighteen. To the extent we become aware that we have the personal information of a person under the age of eighteen, we will expeditiously delete that information.

2. INFORMATION WE COLLECT (Categories of Data Subjects)

  • Website Visitors

    • Log files: Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Website, including the BitScreen site and app, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.
    • Cookies and other tracking technologies: We may use cookies and other information-gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites. Note that if you disable cookies entirely, BitScreen's Websites or Services may not function properly.
  • Customers and Administrative Users

    • Customer Account Information: When you register for an account, we collect contact information. Depending on subscription level, this contact information may include your Ethereum wallet address, business name, customer name, the email address(es) of your account administrator(s), telephone number, and address. In addition, when you use the Services, we collect information about how you configure your account and usage statistics for the Services. We refer to all of this information collectively as "Customer Account Information" for the purposes of this Policy. Customer Account Information is required to enable your access to your BitScreen account and Services. By providing us with any personal information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.
  • End Users

    • Logs: BitScreen processes logs of End Users' interactions with the Services. This information is processed when End Users access or use our Customers' accounts that use one or more of our Services, and when End Users access or use Services. The information processed may include but is not limited to IP addresses, system configuration information, and usage statistics.

Network Data. BitScreen collects and stores Network Data, which include models, observations, reports, analyses, statistics, databases and other information created, compiled, analyzed, generated or derived by BitScreen from server, network or traffic data generated by BitScreen in the course of providing the Service, including information required to help BitScreen identify, analyze, mitigate, prevent, and block malicious activities on BitScreen's network. Examples of Network Data include service uptime and service availability metrics, request volumes, error rates, cache rates, origin and nature of malware, and IP threat scores.

3. HOW WE USE INFORMATION WE COLLECT

BitScreen only processes personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized. As a general matter, for the categories of data described in Section 2 above, we may use the information (including personal information, to the extent applicable) to:

  • Provide, operate, maintain, improve, and promote the Websites and Services for all users of the Websites and Services;
  • Enable you to access and use the Websites and Services;
  • Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
  • Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  • For other purposes for which we obtain your consent.

4. NOTICE TO UK AND EU RESIDENTS

Please note that the "personal information" referenced in this Privacy Policy means "personal data" as that term is defined under the European Union ("EU") General Data Protection Regulations ("GDPR") and its United Kingdom ("UK") GDPR counterpart. BitScreen is a data controller for the personal information collected from all categories of data subjects listed above.

If you are an individual from the European Economic Area (the "EEA"), the UK or Switzerland, please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the BitScreen Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, BitScreen will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object by emailing us at privacy [@] murmuration.ai.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy [@] murmuration.ai.

5. INFORMATION SHARING

We work with other companies who help us run our business ("Service Providers"). These companies provide services to help us deliver customer support, manage and contact our existing Customers and Administrators and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to sell any personal information we share with them or to use any personal information we share with them for their own marketing purposes or for any purpose other than in connection with the services they provide to us.

In addition to sharing with Service Providers as described above, we also may share your information with others in the following circumstances:

  • In the event of a merger, sale, change in control, or reorganization of all or part of our business;
  • When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • Where we have a good-faith belief sharing is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Website Terms of Use, or as otherwise required to comply with our legal obligations; or
  • As you may otherwise consent from time to time.

Notice to California Residents. We do not sell, rent, or share personal information with third parties as defined under the California Consumer Privacy Act of 2018 (California Civil Code Sec. 1798.100 et seq.), nor do we sell, rent, or share personal information with third parties for their direct marketing purposes as defined under California Civil Code Sec. 1798.83.

6. INTERNATIONAL INFORMATION TRANSFERS

BitScreen is a U.S. based company. We primarily store your information in the United States and the European Economic Area. To facilitate our global operations, we may transfer and access such information from around the world.

Whenever BitScreen transfers personal information originating in the EEA, the UK, or Switzerland with itself a third party service provider or partner outside the EEA, the UK, or Switzerland, we will work in good faith to implement appropriate safeguards, consistent with the laws of the territory from which the data is exported. For example, where transfers are made from the EEA, we rely on the EU standard contractual clauses, including supplementary measures as necessary.

If you are accessing or using our Websites or Services or otherwise providing information to us, we may transfer your personal information outside of the EEA, the UK, or Switzerland, ensuring appropriate safeguards are in place to protect your personal information.

7. DATA SUBJECT RIGHTS AND CHOICES

BitScreen recognizes individuals' data protection rights. You have the right to access, correct, update, port, or delete your personal information, and to restrict or object to the processing of your personal information (each of these a "Rights Request"). You may email us at privacy [@] murmuration.ai with any Rights Request, and we will respond within thirty (30) days. Customers and Administrative Users also can access, correct, export, or update their Account Information by editing their profile or organization record at app.bitscreen.co/settings.

For any Rights Request, we will need to verify a requestor is inquiring about their own information before we can assist. Where a Rights Request may implicate the personal information of another individual, we must balance the request against the risk of violating another person's privacy rights. We will comply with Rights Requests to the extent required by applicable law or the US-Swiss or US-EU Privacy Shield. In the EEA, the UK, and Switzerland, you also have the right to lodge a complaint with a supervisory authority.

8. COMMUNICATION PREFERENCES

BitScreen will send you service-related communications, including transactional communications, updates about the product, additional or modified features, or other relevant updates.

9. DATA SECURITY, DATA INTEGRITY AND ACCESS

We take all reasonable steps to protect information we receive from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical and administrative measures to safeguard and secure your information, and where appropriate we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at privacy [@] murmuration.ai.

10. NOTIFICATION OF CHANGES

If we make changes to this Policy that we believe materially impact the privacy of your personal information, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.

11. BUSINESS TRANSACTIONS

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all or part of our business.

12. CONTACT INFORMATION

Murmuration Labs LLC

655 Tennessee St, Unit 103

San Francisco, CA 94107

privacy [@] murmuration.ai