Privacy Policy

Last Revised: September 13th, 2024

This privacy Policy ("Policy") outlines the practices of Anywhere Blockchain Corp ("Company", "we", "our", or "us") regarding the collection, usage, sharing, and preservation of personal data from users of its internet properties, including https://anywhereaccess.io/, https://regencard.app, and the Regen Card Mobile Applications for iOS and Android (the "Websites"). This Policy is applicable to the Websites, applications, products, and services (collectively, "Services") where it is displayed, linked, or mentioned.

By using the Services, you acknowledge the conditions of this Policy and our Terms of Service, and you consent to our collection, usage, disclosure, and storage of your data as outlined in this Policy. If you haven't yet, we also recommend reviewing our terms of service. The terms of service include clauses that limit our responsibility towards you and mandate that any disagreements be settled individually, not as part of any class or representative action. IF YOU DISAGREE WITH ANY PORTION OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, THEN YOU SHOULD REFRAIN FROM USING ANY OF THE SERVICES.

DATA COLLECTION METHODS

We acquire data about you in various methods.

Data Provided by You. The data we collect from you may encompass:

- Personal identifiers, such as your first and last name;

- Contact details, such as your mailing address, email address, and phone number;

- Feedback and communication, such as the information you provide in survey responses, during market research activities, when reporting an issue with an Service, receiving customer support, or communicating with us in any form;

- Financial data, such as your credit card or other payment method details;

- Purchase details, including information about transactions made through the Service and billing information;

- Behavioral data, such as information on how you utilize the Service and interact with us;

- Marketing preferences, such as your interest in receiving marketing communications and how you interact with them;

- Additional financial information, such as bank account numbers and routing numbers; holdings in financial assets; and

- Technological data, such as your Ethereum wallet address, application programming interface (API) keys, and network information related to transactions.

COOKIES AND TRACKING TECHNOLOGIES

General Information on Cookies and Tracking Technologies

Standard cookies can usually be disabled or removed using tools available as part of most commercial browsers, and in some cases can be blocked in the future by selecting certain settings.

Google Analytics

Choices regarding the use of cookies from Google Analytics can be made by visiting https://tools.google.com/dlpage/gaoptout/ and downloading the Google Analytics Opt-out Browser Add-on.

COOKIES

Setting your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies, is an option. However, please note that some parts of the Websites may become inaccessible or not function properly if cookies are disabled or refused. For more details on the cookies we use, please refer to our Cookies Policy.

Data We Do Not Collect. We will never request you to share your private keys or wallet seed. Never trust any person or website that asks you to enter your private keys or wallet seed.

PERSONAL DATA USAGE

To Deliver Our Service

Your personal information will be used in the following manners:

- To facilitate your access and use of the Services;

- To deliver and provide products and services you might request;

- To process and complete transactions, and send you related information, including purchase confirmations and invoices;

- To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages;

- To comply with legal obligations;

- To communicate with you regarding promotions, events, and other news about products and services offered by us and our selected partners;

- To optimize our platform for your user experience;

- With your consent, for any other purposes.

For Legal Compliance, Fraud Prevention, and Safety

We may use your personal information to protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.

SHARING OF PERSONAL INFORMATION

Your personal information is not shared with other organizations without your explicit consent, except as outlined in this Privacy Policy. We may disclose personal information to third parties under certain conditions, such as:

- To affiliates for purposes consistent with this Privacy Policy;

- During negotiations or completion of a business deal involving the sale or transfer of our business or assets;

- For legal compliance, protection, and safety purposes;

- To professional advisors and service providers who perform services for us;

- With your permission, to other parties of your choosing, subject to their privacy policies;

- Aggregated and/or anonymized data may also be shared with others for their own uses.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, processed, and stored in the United States or other countries outside of your local jurisdiction, where privacy laws may not offer the same level of protection. For users in the European Union, additional information is provided regarding the transfer of personal information outside of the European Economic Area (EEA).

DATA SECURITY

We retain the collected information as long as necessary to fulfill the purposes outlined in this privacy Policy and comply with our legal obligations. Industry-standard security measures are employed to protect your information, though the security of data transmitted over the internet cannot be guaranteed.

YOUR DATA RIGHTS AND CHOICES

You have the ability to access, update, correct, and delete your information through your account settings on the Services or by contacting us directly. 

ELIGIBILITY

The Services are intended for users who are the age of majority in their place of residence. Users under the age of majority must have the consent or supervision of a parent or legal guardian.

MARKETING COMMUNICATIONS AND SHARING

You have the option to instruct us not to use your contact information for marketing purposes by contacting us directly. Certain operational communications may still be sent to you as required by law.

THIRD-PARTY LINKS AND CO-BRANDED WEBSITES

This Privacy Policy does not cover third-party practices or any websites that link to or from our Websites.

For Privacy Policies for Third Party Companies used in our Services refer to the following website for those companies’ privacy policies and terms of use:

https://www.pimlico.io/ - RPC and API services

https://transak.com/ - Onboarding and Offboarding Services

https://www.base.org/ - Ethereum Layer 2 Network Information

In all cases, your continued use of the Sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

AMENDMENTS TO THIS PRIVACY POLICY

We reserve the right to modify this privacy Policy at any time. Changes will be posted on this page, and the "Last Revised" date will be updated accordingly.

NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please refer to our Cookies Policy for more information regarding the types of third-party cookies, if any, that we use.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us through our contact page at https://anywhereaccess.io. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

NOTICE TO EU DATA SUBJECTS

Personal Information

With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

Sensitive Data

Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.

Legal Bases for Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below.

Processing Purpose - Legal Reason

To provide our service - Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Service.

To communicate with you/To optimize our platform/For compliance, fraud prevention, and safety/To provide our service - These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law - We use your personal information to comply with applicable laws and our legal obligations, including anti-money laundering (AML) laws and know-your-customer (KYC) requirements.

With your consent - Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us using the contact page at https://anywhereaccess.io

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

Your Rights

Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct. Update or correct inaccuracies in your personal information.

• Delete. Delete your personal information.

• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

• Restrict. Restrict the processing of your personal information.

• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by our contact page at https://anywhereaccess.io We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us through our contact page at https://anywhereaccess.io or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Sites or using our service.

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.