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Privacy Policy

Last Updated: November, 2023

Puffer Foundation, a Cayman Islands foundation company (as "Puffer", "we", "our", or "us"), currently provides services including, but not limited to, the website located at https://puffer.fi, and any content, functionality, and services offered on or through such website ("Services"). We take the protection of your personal data very seriously. We collect and use your personal data in accordance with this privacy policy and in compliance with the Cayman Islands Data Protection Act (as amended) and, in respect of any EU data subjects, the EU General Data Protection Regulation (together, the "Data Protection Legislation"). This privacy policy ("Privacy Policy") provides you with information about the collection and use of your personal data when using our website.

Information obtained when you access our website

When you access our website, we and our service providers may obtain or request information about you, your computer or mobile device, and your interaction over time with our website, as described below.

  • Personal information that is automatically collected. When you visit our website, we and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our website, our communications and other online services, such as:

    • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.

    • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

  • Personal information that you may be asked to provide. When you visit our website, you may be asked to provide the following information to us:

    • Contact and account information, such as your first and last name, email address, phone number, date of birth, photographic identification, government issued identification and other contact details.

    • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.

    • Usage information, such as information about how you use our website and interact with it, including information associated with any content you upload to our website or otherwise submit to us, and information you provide when you use any interactive features of our website.

    • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

  • Personal information that we obtain from third parties. When you visit our website, we may obtain information from the following sources:

    • Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

How we use your personal information

  • We may collect, store and use your personal data for purposes including the following. The processing is necessary for the performance of a contract, including:

    • administering or managing Puffer;
    • facilitating the continuation or termination of the contractual relationship between you and Puffer; and
    • administering and facilitating any transaction between you and Puffer.

  • The processing is necessary for compliance with applicable legal or regulatory obligations, including:

    • undertaking due diligence including anti-money laundering and counter-terrorist financing checks, including verifying identity and addresses (and, where applicable, in relation to beneficial owners);
    • sanctions screening and complying with applicable sanctions and embargo legislation;
    • complying with requests from regulatory, governmental, tax and law enforcement authorities;
    • surveillance and investigation activities;
    • carrying out audit checks, and instructing our auditors;
    • maintaining statutory registers; and preventing and detecting fraud.

  • In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, including:

    • complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;
    • assessing and processing requests you make;
    • investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
    • providing you with, and informing you about, products and services;
    • managing our risk and operations;
    • complying with audit requirements;
    • ensuring internal compliance with our policies and procedures;
    • protecting Puffer against fraud, breach of confidence or theft of proprietary materials;
    • seeking professional advice, including legal advice;
    • facilitating business asset transactions involving Puffer or related entities;
    • monitoring communications to/from us (where permitted by law); and protecting the security and integrity of our IT systems.

We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

Sharing your personal data

  • Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us provide the Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, and database management services).

  • Web3 partners. We may share your personal information with our web3 partners as necessary to provide the Services.

  • Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

  • For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

  • Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Sending your personal data internationally

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Data Protection Legislation. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of the Data Protection Legislation.

‍Retention and deletion of your personal data

We will keep your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

Automated decision-making

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.

Your rights

You have certain data protection rights, including the right to:

  • be informed about the purposes for which your personal data are processed;
  • access your personal data;
  • stop direct marketing;
  • restrict the processing of your personal data;
  • have incomplete or inaccurate personal data corrected;
  • ask us to stop processing your personal data;
  • be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);
  • complain to the Data Protection Ombudsman; and
  • require us to delete your personal data in some limited circumstances.

Changes

We reserve the right to change this policy from time to time by updating this Data Privacy Policy on the website.

Contact Us

We are committed to processing your personal data lawfully and to respecting your data protection rights. Please contact us at [email protected] if you have any questions about this notice or the personal data we hold about you marking your communication "Data Protection Enquiry".