Privacy Policy

This Privacy Policy ("Policy") describes how, Inc. ("," "we," "our" or "us") collects, uses, processes and shares personal information collected through the website and associated Services offered under the User Agreement. This Policy applies to visitors and users (individually, "you") of’s websites, applications, social media accounts, and other services, as well as all other online and offline interactions with us (collectively, our "Services"). Please note that your use of our Services is additionally subject to the User Agreement at Any capitalized terms in this Policy that are not defined herein shall have the same meaning as such defined term in the User Agreement.

For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by third parties or their services, and we do not take responsibility for their privacy practices.


Information We Collect and Use When you use or visit our Services, we collect information directly from you (e.g., when you search for or make an online reservation). We may also generate information about you (e.g., information about your device). In some cases, we also obtain personal information from third parties (e.g., search engines, social media, or other third parties).
How We Use Your Information We use your information to provide our Services, tailor your experience, show you transactions made through you User Account, send you marketing communications, provide you with more relevant advertising and offers that may be of interest to you, and for other purposes described below.
How We Share Your Information We share your information with our service providers (including payment processors and hosting providers); with other business partners (including advertising partners); with social networking services; with third-party services or applications you use to log into your account; and others as described below. We share information to provide and improve our Services, for our own marketing purposes, to facilitate offers and advertising from others that may interest you, and for other purposes as described below.
How We Store Your Information We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as your User Account is active and for a period of time thereafter to allow you to re-activate your account without loss of information, and as necessary for purposes described below.
Cookies We use cookies and similar technologies to help provide our Services, and offer you a more personalized user experience.
Links to other Websites Our Services may contain links to other websites or services that are not owned or controlled by, [including links to websites of other business partners (including advertisers)].
Children Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age.
Changes to this Policy We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy).
Contact Information If you have any questions about this Policy or the way your personal information has been used, please contact us at or using the contact details set out below.

    “Personal information” includes any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with a particular individual or household, that is subject to the protection of applicable data protection laws in the jurisdiction where you reside. This Policy applies only to Personal Information collected in connection with the Services.

    We collect Personal Information directly from you. As you visit or use our Services, we collect the following categories of Personal Information directly from you:

    Personal details (such as your name);
    Contact information (such as email address, postal address, phone number);
    Service information (such transaction activity, including frequency, size, Virtual Currency preferences);
    Account information (such as account settings);
    Social media data (if you choose to link your account with a social media account, we may collect personal information such as name, age, gender, photograph, and other personal information relating to your social media account);
    Billing information (such as credit, debit, or other payment card information, as may be required to use certain Services);
    Your contacts (such Virtual Currency addresses you transact with through our Services);
    Your preferences (including survey and marketing responses);
    Communications you send us (such as customer support and other requests you make through our Services)
    Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms).

    You may choose not to provide some of the Personal Information described above. Please note, however, that many of our Services require some Personal Information to operate, so if you choose not to provide the Personal Information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
    We do not proactively collect sensitive Personal Information, such as health-related information. However, our Services include text boxes that are designed for you to describe support issues and to provide us with Feedback. Please be aware that information you freely submit in these boxes may reveal to us certain information that may be considered sensitive Personal Information under applicable law. We do not use this information for the purpose of marketing or advertising products to you, and we do not intentionally store any such sensitive Personal Information. Please contact us at if you believe you may have erroneously submitted any sensitive Personal Information to us.

    Personal information we generate. As you use our Services, we generate certain Personal Information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies. We generate the following categories of Personal Information about you (collectively “Usage Data”):

    Device information. When you visit or use our Services, we automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; device identifiers, such as IP address, IMEI number, MAC address, or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
    Usage and performance information. We also automatically collect Personal Information about your usage of the Services, including information about your interactions with features of our Services; sites or pages visited; access times; and performance of our Services.
    Location information. If you use our Services, we automatically collect generic location information about you (such as city or neighborhood) or, with your consent, precise geographic location data from your mobile device. For example, we may receive this information when you enter your local city in your account profile, when you are in proximity to certain beacons, or in your comments or other communications with us. We may use and store this information to provide and improve features of our Services.
    Wallet Information If you create a Wallet through our Services, you will generate private keys, and you will generate encryption keys to encrypt those private keys. Once generated, we collect the encrypted data that, when unencrypted, contains these private keys, as well as the corresponding unencrypted public keys derived from these private keys necessary for generation of Wallet addresses used by your Wallet to interface with the relevant Virtual Currency network(s). Under no circumstances do we ever collect an unencrypted private key from you, nor can we decrypt any encrypted private key data. Your Wallet address may be used to retrieve your Wallet’s transaction history from the relevant Virtual Currency network, via the Services or through other third party services.
    Inferences about you. We combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the offers we and our partners provide to you.
    Aggregate Information. We aggregate Personal Information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with Personal Information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “Personal Information” and may be subsequently used for any purpose.
    Anonymized Information. We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “Personal Information” and may be subsequently used for any purpose.

    Personal Information We Obtain from Third Parties. We may also receive certain categories of Personal Information from third parties, such as third-party websites, applications, social media networks, and services (which may include publicly-available sources; each of these is a “third-party platform”). If you are an existing customer, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of Personal Information we may obtain from third parties include:

    Your name;
    Email address or other contact information;
    Social media data, if you connect to our Services using a social media third-party platform or interact with by liking or commenting on our social media pages or content, or if any of your social media data is available to the public, we may receive information from that social media third-party platform or a third-party service about those interactions and your profile;
    Browsing, usage and advertising details, including how you use our Services and/or third-party websites, applications, and services; and information relating to your interactions with our advertising and marketing materials; and
    Purchase Information, transaction information about Virtual Currency transfers you make through our Services.

    We use your Personal Information for the following purposes ("Purposes"), to:

    Provide the Services, which includes providing you with the services, products, and functionality offered through our Services and fulfilling your requests, including but not limited to: operating Wallets and processing Virtual Currency Transactions;
    Authenticate your account credentials and identify you, as necessary to log you in to the Services and ensure the security of your account;
    Communicate with you about your account or use of our Services, products, and/or functionality; respond to, or follow up on, your comments and questions; and otherwise provide customer service;
    Operate and improve our Services and develop new products and services, including using analytics to better understand how you use our Services for purposes of product, website, application and service development and to enhance the user experience;
    Authenticate your credit or debit card account information;
    Tailor your experience with our Services, such as by making inferences or combining different pieces of information we have collected about you to suggest products or services that you may be interested in or otherwise tailor our Services to you according to your preferences;
    Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity;
    Develop new and enhance existing service and product offerings;
    Manage and develop our business and operations;
    Comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law; and
    As otherwise consented to by you and as required or permitted by applicable law. If you give your consent to any further use of Personal Information, you can withdraw that consent at any time by contacting us using the details set out below.

    You have choices about your Personal Information, and in some circumstances, you may have the right to opt-out or object to our uses of your Personal Information for these Purposes. Please contact us at if you have any concerns about our uses of your Personal Information. Please bear in mind that some of these uses are required for us to offer the Services and that your access of the Services may be impacted based on any choices you make with regard to our usage of your Personal Information.

    Electronic Communications. Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:

    Send you information relating to our products and Services. This may include technical notices, updates, security alerts, and support and administrative messages.

    With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, text messages and push notifications in connection with the above Purposes.

    We also use third party web analytic tools that help us understand how users engage with the website. These third parties may use first-party cookies to track user interactions to collect information about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose website trends without identifying individual visitors. You can opt out of such third party analytic tools without affecting how you visit our site – for more information on opting out, please contact

    We disclose the Personal Information we collect (or otherwise generate or obtain) as follows:

    With other business partners. We may share information with other third-party business partners for their own marketing purposes, including sharing with helpdesk hotline representatives, technical support specialists, and online advertisers or advertising technology (“ad tech”) companies to provide you with targeted advertising and marketing communications, where permitted under law. Sharing with our business partners may be additionally subject to the terms and conditions of such business partners.
    For further clarity, we enable third parties (e.g., Google Analytics) to track your interactions with our Services that we use to improve the Services, but we do not directly share the data received from such tracking directly with any third party. However, in the case of Google Analytics, for example, Google will have access to certain data collected from such tracking unless you disable tracking through Google Analytics.
    With cloud service providers. We may share information with cloud service providers to store certain Personal Information and for disaster recovery purposes, as well as to provide hosting for the Services.
    • Our Services may also allow you to connect with us on, share on, and use third-party platforms, including those on which has a presence (e.g., Twitter, Facebook, Reddit). Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. also does not control the privacy practices of third-party platforms. Please contact those sites and services directly to learn about their privacy practices.
    To process payments. We require credit or debit card information to allow you to pay us and we share payment information with third-party payment processors, and other third-party service providers (such as fraud detection services).
    • When you use a credit or debit card to secure a reservation through our Services, we provide your credit or debit card account information (including card number and expiration date) to our third-party payment service providers. These third parties may store your credit or debit card account information so you can use our payment services through our Services in the future, to the extent permitted by local law.
    With other service providers. We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (e.g., our accountants, lawyers, etc.).
    In the event of a corporate transaction. We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
    To protect rights and property. We may disclose your information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, the integrity of the Services, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.
    To comply with and as required by law. We may disclose your Personal Information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities.
    Aggregate information. We share aggregate statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.
    At your request. We also share your information as directed or requested by you, or subject to your consent.
  4. HOW WE STORE AND PROTECT YOUR INFORMATION maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

    When your credit or debit card account information is being transmitted to our Services or through our Services, it will be protected by cryptographic protocols. To be clear, does not itself store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We use third party payment processors that are the controllers of your credit card information. Our contracts with third parties that receive your credit or debit card account information require them to keep it secure and confidential.

    However, we cannot guarantee that transmissions of your credit or debit card account information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.

    You play an important role in keeping your information secure. You should not share your user name, password, or other security information for your account with anyone. If we receive instructions using your user name and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately at

    Retention. We may retain your Personal Information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your Personal Information as necessary to:

    • Maintain logs and business records for analysis, security, and/or audit purposes
    • Comply with record retention requirements under the law
    • Deal with any complaints regarding the Services; and
    • Comply with our legal obligations, protect or defend our rights, resolve disputes and enforce our contracts

    We generally aim to retain the least amount of Personal Information for the minimal amount of time possible for us to provide the Services. Any Personal Information captured in logs that is not flagged for additional scrutiny (e.g., for regulatory, compliance, or legal purposes) is automatically deleted within one week. Device information such as IP addresses may be stored temporarily, or as required for regulatory, compliance, or legal purposes.

    Except where prohibited by law, we may retain your Personal Information beyond the end of your relationship with us but only for so long as we are contractually bound to do so, or so far as is necessary for audit, regulatory or other accounting purposes. When Personal Information is no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form.

    After you have terminated your use of our Services, we reserve the right to maintain your Personal Information as part of our standard back-up procedures in an aggregated format.

    Once the retention period expires, information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability will not be available to you after expiration of the retention period.

    We use third party cloud hosting services and payment processors that may transfer your information outside of the United States for hosting, retention, or disaster recovery purposes. These third party services are contractually required to secure any information they store, and additional safeguards have been implemented (e.g., encryption) to secure your information, but we cannot guarantee that your information will always be secure. Under ordinary circumstances, your information will be located in data centers in your geographical region in the United States to provide the Services to you with optimal latency. Any information submitted to a Virtual Currency network is completely out of’s control. Accordingly, any information submitted to a Virtual Currency network by you may be transferred anywhere in the world according to the protocols of such Virtual Currency network.

    When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website. On mobile websites and mobile applications, we use device IDs and / or Advertising IDs in a similar manner to which we use cookies.

    We and certain third-party partners (e.g., Google) may use cookies on our websites, our mobile applications and within emails or other communications we send to you. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. uses “first party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own websites, or to provide functionality such as remembering your language preference. Many of these first party cookies are what we consider “required” cookies, without which we are unable to provide our Services to you. You are free to delete any cookies from your devices at any time, but be aware that deletion may affect the functionality of the Services. You acknowledge and accept our use of first party cookies to provide the Services.

    Other “third party cookies” are used by our third party business partners to improve the quality of their services, for example, to target you for advertising purposes (including to receive advertisements from us). These cookies do not necessarily affect the functionality of the Services, but the terms of their use may be governed by the policies of our third party business partners.

    The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.

    We use cookies to:

    • track traffic flow and patterns of travel in connection with the Website;
    • understand the total number of visitors to our Website on an ongoing basis and the types of internet browsers (e.g. Firefox, Chrome or Internet Explorer) and operating systems (e.g. Windows or Mac OS) used by our visitors;
    • monitor the performance of the Website and Services and to continually improve them; and
    • customize and enhance your online experience;

    How to control or delete cookies

    You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Website and the Services.

    Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

    • Cookie settings in Internet Explorer
    • Cookie settings in Firefox
    • Cookie settings in Chrome
    • Cookie settings in Safari web and iOS.

    If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:

    Network Advertising Initiative
    Digital Advertising Alliance

    Please bear in mind that there are many more companies listed on these sites than those that drop cookies via the Website.

    You may also be able to change your mobile device settings to opt-out of personalized advertising. For example, for iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” Also, for location-based ads, you may go to “Settings” from your device’s home screen; select “Privacy”; select “Location Services”; select “System Services”; and de-select “Location-Based Apple Ads.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”

    When you opt-out of personalized advertising, you may continue to see non-personalized online advertising on the Services and/or our ads on other websites and online services.

    The and its partners may also use data relating to past use of the Services by you (including your Personnel) to inform the future development and optimization or, or in advertising or, our Services (“Remarketing”). Remarketing is based on data collected by us from tracking Usage Data and by using cookies. Remarketing information is transferred to our partners (listed below) that manage such remarketing activities including marketing based on behavioral targeting . Our Remarketing partners collect and process Usage Data (including Cookies) only in the United States. In addition to any opt-out offered by any of the services below, you may opt-out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

    Facebook Remarketing: FAQ.
    Twitter Remarketing and Twitter Tailored Audiences: Opt Out.
    Google Ads Remarketing: Opt Out.

    Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. Without limiting the generality of the foregoing, in some circumstances, you may have the right to opt-out or object to our uses of your Personal Information for the Purposes. Please contact us at if you have any concerns or questions about our uses of your Personal Information. Please bear in mind that some of these uses may be required for us to offer the Services and that your access of the Services may be impacted based on any choices you make with regard to our usage of your Personal Information. Please also note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.

    Do Not Track
    Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. At this time, does not respond to browser DNT signals. For information about DNT, visit

    California Residents

    Access to Specific Information and Personal Information Portability Rights. You have the right, subject to certain exceptions defined in the California Consumer Privacy Act (CCPA) and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past twelve (12) months. This right of access includes information about:

    • The categories of Personal Information we collected about you
    • The categories of sources for the Personal Information we collected about you
    • Our business or commercial purpose for collecting that Personal Information
    • The categories of third parties with whom we share that Personal Information
    • The categories of Personal Information that each recipient received
    • The specific pieces of Personal Information we collected about you

    Deletion Rights. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained.

    Non-Discrimination. California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed herein.

    Exercising Access, Personal Information Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

    • Emailing us at; or
    • By mail at:, Inc. 95 Third St, Second Floor, San Francisco CA 94103.

    When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request, but we cannot process a request if we cannot verify your identity.

    You will be required to submit your first and last name and email address and may be asked to provide your telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.

    We are not required to respond to your requests for access or disclosure of Personal Information more than twice in a twelve (12) month period.

    Sale or Sharing of Personal Information. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your Personal Information and refrain from doing so in the future. We are not currently selling your Personal Information.

    California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain Personal Information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send an e-mail request to Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

    Nevada Residents

    Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request to

    Our Services may contain links to other websites or services that are not owned or controlled by, including links to websites of our advertisers, and other business partners. This Policy only applies to information collected by our Services. We have no control over these third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third party websites linked to our Services. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Services.

    Our Services are not directed at or intended for use by children. We do not knowingly collect information from, children under 18 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at

    This Policy should be read in conjunction with the User Agreement, and as such shall be governed by and construed in accordance with the laws of the state of California.

    Except to the extent limited by applicable law, we will update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, and other factors by prominently posting notice of the update on our Services. Changes to our Privacy Policy will be effective when posted and the new effective date will be identified.
    If we make any changes to the Privacy Policy that materially impact previously collected Personal Information about you, we will make reasonable efforts to provide notice and obtain consent to any such changes as may be required by law.

    If you have any questions about this Policy or the way in which your Personal Information has been used, please contact us by email at