# SPRING Privacy Policy

**_Last Updated: 22-FEB, 2020_**

Bitmark Inc. (“Bitmark”, “we”, “us”, “our”) provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information received from users of Bitmark’s SPRING App (the “Application”), and the related website (the “Website”), and any related services provided by Company (the Application, Website, and any related services are collectively the "Services").

**Other Definitions**

“Personal Information” or “Personal Data” is information that is identified or identifiable to a natural living person, consistent with the definitions in European and California law. It includes the Bitmark Account Number (defined below) and information associated with the Bitmark Account Number.

“Personally Identifiable Information” is information traditionally thought of as directly identifying a natural living person, such as full names, addresses, telephone numbers, government identification numbers, email addresses, social network identifiers and similar persistent and public or quasi-public identifiers.

**Application Information Collection and Use**

_The Bitmark Property System_

In order to use the Application, you will need to create a user account in the distributed, publicly available registry and ledger system on which we rely to track data rights and transactions (the “Bitmark Property System”). The Bitmark Property System uses blockchain technology to allow you to create unique identifiers (each a “bitmark”) to claim property rights to your data.

User accounts in the Bitmark Property System consist of a public and private key pair (the “Bitmark Account”). The public key is the “Bitmark Account Number”. You may establish a Bitmark Account through the Application or through another mechanism of your selection. Please note that any information recorded in the Bitmark Property System (whether through the Application or otherwise), including your Account Number, bitmarks, and transaction records, is made permanently public, and Bitmark does not act as the custodian or controller of that information.

Any information in the Bitmark Property System is _permanently and irrevocably public by design_. That includes the public encryption key that forms your Bitmark Account Number, the bitmarks themselves, and the records of any transactions in or with your Bitmark Account, including the fact of participation in any data analysis projects.

However, the data stored in the Bitmark Property System under your Bitmark Account will always be encrypted, and the social network data you access with the Application is stored separately from the Bitmark Property System, and will also always be encrypted..

Your Bitmark Account Number is used to identify you within the Bitmark Property System, and is visible to other users of the Bitmark Property System. It is not attached to personally identifiable information in the BitMark Property System unless you specifically choose to publicly identify your account with an email address or other personally identifiable information.

As described below, we do store your Bitmark Account Number with some of your other personal information in our encrypted servers. We do not correlate your Bitmark Account Number or other information you may store in the Bitmark Property System with information we collect through our Website – these systems are separate.

We will use your BitMark Account Number only to provide the Services to you.

_When Using the App._

We collect only the following personal information in connection with your use of the Application:

* Your Bitmark Property System Account Number;
* Your social network data downloaded by our server, and our initial translation of that data into a more readable format for viewing in the Application;
* A hash of your social network username;
* The operating system of the device that you use (e.g, iOS or Android);
* The push notification ID for your Application on your device; and
* A separate public encryption key we create for you for your future use, and you will receive (but we will not see) a private encryption key that is paired with that public encryption key.

We will use the personal information described above only to provide the Service to you, and as permitted on a case by case basis for data analysis projects, as described below.

Initially, we will be able to read the social network data we store for you, though we will do so only for the uses we describe in this Privacy Policy. We are working on a feature that will allow you to encrypt your social network data stored on our servers so only you can see it unless you specifically choose to allow us to see your social network data. We’ll update this privacy policy when that feature is available.

_Data Analysis Projects_

The only analysis we will do on your social network data without your separate permission is the initial translation to more readable format for display within the Application.

Participating in any given data analysis project (or any data analysis project at all beyond the initial translation) is completely up to you. If you decide not to participate, it will not affect your ability to use the Application. When you approve the use of your personal information for a data analysis project, you give your permission for us to use your personal information to study only the specific issue or issues disclosed to you when permission to use your personal information was requested and to collect your personal information from or access your personal information within the Application for those purposes. This permission ends only when you withdraw your data from the data analysis project, and we will then delete your personal information or cease accessing it, as applicable for the given project.

Keep in mind that we will not be able to delete your personal information entirely:

* as described below with respect to personal information stored in the Bitmark Property System;
* if you have participated in a project which requires that your personal information continue to be available for a certain period of time; and/or
* if your personal information has been de-identified or aggregated so that we can no longer identify it with you or any other individual.

Although we will describe each data analysis project to you before you decide to participate, as a general matter, we will report to you and other participants the aggregate statistical results of the data analysis project. We will report directly to you, and only to you, any results of the data analysis project which are specific to you. We may also publish aggregate statistical results which do not contain personal information.

**Website Information Collection and Use**

It is not necessary to provide Company with your personally identifiable information to the Website, and Company does not collect personally identifiable information in connection with the ordinary operation of the Website. We do collect personal information from the Website, as described below, but we do not associate that personal information with the personal information in the Bitmark Property System or with correspondence you may send us as described in the next paragraph.

If you contact Company by email through the Website or any support feature provided in the Application, Company may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to Company in your message, to respond to you. Company uses commercially reasonable efforts to keep this information and to delete it when keeping it is no longer necessary, but has no obligation to keep this information confidential, nor to take any specific security measures to protect this information.

When you visit the Website, Company’s servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting. For most users accessing the Internet from an Internet service provider, the IP address may be different every time you log on. Company uses Log Data to monitor use of the Website and the services we offer via the Website and for the Website’s technical administration.

**Do Not Track**

We do not use cookies to collect personally identifiable information or track users’ online activities over time and across different websites. For more information regarding Do Not Track mechanisms, see [http://allaboutdnt.com](http://allaboutdnt.com/).

**Information Shared with Others**

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We may engage third party service providers to work with us to administer and provide the Services. These third-party service providers have access to personal information collected through the Services only for the purpose of performing services on our behalf.

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As described above regarding data analysis projects, we may share or publish the statistical results of data analysis which does not contain personal information.

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Information we collected through the Services, including personally identifiable information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, the information collected through the Services may be disclosed or transferred to the third-party acquirer in connection with the transaction. Please note, however, that we don’t claim ownership of your information stored in the Bitmark Property System – that information is simply publicly available in a system that both we and you can access.

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It is our policy to protect you from having your privacy violated through abuse of the legal systems, whether by individuals, entities or government, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (a) to satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders; (b) to enforce our agreements with you or third parties, to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and (c) to prevent or stop activity we consider to be illegal or unethical.
**Security**

We take reasonable measures to protect your information from unauthorized access, use or disclosure the information that we collect. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

**Your Rights in Your Data**

Bitmark doesn't collect, process, or disclose your personal data in connection with the Services except as we describe in this Privacy Policy. You may have the right under applicable laws of various countries or US States, you may have certain rights concerning your personal data, such as under EU or California law, the right to access to, rectification or erasure of, and/or restriction of processing or objection to processing of your personal data. If you wish to exercise your rights with respect to personal data collected or processed by Bitmark in connection with the Services, contact us via e-mail at [[e-mail]](mailto:[e-mail]), and we will respond to you with specific instructions to follow.

Please note, that as described above, we do not control or act as custodians for the information you may store in the Bitmark Property system, and the blockchain technology used in the Bitmark Property System is incompatible with the ability to erase or rectify your personal data stored in the Bitmark Property System.

If you are a resident in the European Union, you also have the right to at no cost to lodge a complaint with EU data protection authorities. This right may also exist in other countries.

**International Transfer**

Your information (including personally identifiable information) may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. By using the Services, you consent to this transfer.

**Links to Other Sites**

The Website may contain links to other websites ("Linked Sites") operated by Bitmark or third parties. Linked Sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. This Privacy Policy addresses only the use and disclosure of information that Bitmark collects through the Services. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. Bitmark does not exercise control over third party Linked Sites. Your use of any Linked Site operated by Bitmark is subject to the terms and conditions provided by Bitmark for such Linked Site. Bitmark encourages you to read the privacy policies or statements of the other websites you visit.

**Our Policy Towards Children**

The Services are not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [[e-mail]](mailto:[e-mail]). If we become aware that a child under 13 has provided personally identifiable information to us, we will remove such information from our files and will not make further use of it, although we cannot remove such information from the Bitmark Property System.

**Changes to this Privacy Policy**

We reserve the right to change this policy at any time without prior notice. Any changes to this policy will be posted here, and we will attempt to notify you through the Application. You are advised to consult this Privacy Policy regularly for any changes. If you have any questions or comments about this Privacy Policy, please contact us at [[e-mail]](mailto:[e-mail]).