Privacy Policy

Effective Date: September 14, 2020

Thank you for visiting the WAX platform at https://wax.io (“WAX Cloud Wallet”). Exposition Park Holdings (“WAX,” “we”, “us” or “our”) provides WAX Cloud Wallet and, together with third parties, provides related products and services (together with WAX Cloud Wallet, the “WAX Products”).

This Privacy Policy covers any of your Personal Information obtained by WAX. If we make any material changes, we will post the new policy here, with a new effective date.

To the extent permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of this Privacy Policy, which together with the Terms of Service, govern your use of the Site.  By using WAX websites, which include WAX Cloud Wallet, www.wax.io, and other names under which we do business (collectively, “Site”), you consent to use of information that is collected or submitted as described in this Privacy Policy.

“Personal information” is data about an individual who can be identified from that data, or from that data and other information to which we have access. Personal Information is usually your name in combination with another identifier, such as date of birth or address.

What Personal Information Do We Collect?

We may ask you for your name and postal address, email address, and telephone number information when you participate in the WAX platform, use tokens and/or to create, complete or update your WAX account. 

We may seek Personal Information regarding your age to verify that you are not a minor in accordance with our policy against doing business with children, set forth below.

You are not required to provide the personal information we request, but if you decline, you may not participate in the WAX platform or use tokens, and we may not be able to respond to queries you may have.

How Do We Use Your Personal Information?

To transact business with you in connection with the WAX platform or token use and related transactions (e.g., requests for information about WAX, tokens or other products or services) and otherwise serve you as a customer;

To assess your interests, preferences and degree of satisfaction with the WAX platform, tokens and/or related products and services;

To keep you posted on new or updated WAX token offerings or related products, services and/or upcoming events;

To improve the effectiveness of the Site, products, services, operations, mobile experience or marketing efforts;

To verify your identity and eligibility for the Token Sale and/or related products and services;

To conduct auditing, data analysis, and research to improve WAX products, services, and customer communications;

To allow our employees to service your customer needs;

To prevent, deter and investigate violation of this Privacy Policy and our Terms and Conditions, or any fraud and other illegal activities; and

To send you important notices regarding your purchases and changes to our business policies.

With Whom Do We Share Your Personal Information?

We share your Personal Information with third party service providers who facilitate WAX, manage and enhance our systems or customer data, provide customer service, assess your interest in our products and services, and conduct customer research or satisfaction surveys. These third parties may include infrastructure and IT service providers, including cloud service providers, marketing, advertising and communications agencies, external auditors and advisors, cookie analytics providers, online advertisers and analytics services.  These companies have agreed to protect your information as a condition of receiving or processing it.

We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Service, this Privacy Policy or to otherwise protect our operations or users.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of service or use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. Upon such change, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.

We may share your Personal Information with our dealers, suppliers and partners, who may provide you with SMS, email and other communications and offers for products and services, including offers based on your interests, personal and business characteristics, stated preferences and location. We may also share your personal information with our corporate affiliates to provide or offer services to you.

How Do We Protect Your Personal Information?

We maintain a variety of security measures, including physical, electronic and procedural safeguards. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Access to Personal Information

You can ask us for the Personal Information we possess, so that you can determine if it is inaccurate or if you want it deleted, provided we not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to privacy@wax.io.

What Other Information Do We Collect?

We automatically gather information when you browse or view our Site. This log data may include your browser type (e.g., Chrome, Safari, Firefox or Internet Explorer), your domain, the Internet Protocol (IP) address assigned to your computer (or the unique device ID of your mobile device, or other unique identifier), the date and time of your visits, the pages on our site you visit and other information related to your visit.

We collect data that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose such non-personal information for any purpose.

If we combine non-personal information with your Personal Information, we will maintain the combined information as Personal Information for as long as it remains combined.

We may collect aggregated information regarding participant activities on our Site, mobile application, and from our other products and services we may offer.

We may collect details of how visitors to the Site use our services.

You may give consent for our Site to capture and record certain precise geolocation or global positioning data from your device in order to tailor information to your location. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Site. We will separately notify you and obtain your opt-in consent before collection or use of such geolocation or global positioning data.

How Do We Employ Cookies and Similar Technologies?

We also collect information from Site visitors using “cookies.”  Cookies are small text files stored on your device by our Site. They carry navigational information from your Site visits.  We use cookies to transact with you, personalize your experience, analyze usage patterns, and otherwise improve our Site, products and services.  The cookies we use do not store sensitive personal information, such as your address, your password, or your credit card data.

Our cookies generally fall into one of four categories:  Essential, Functional, Analytics and Target.

Essential Cookies are necessary to provide you with products and services available through our Website.  If you refuse them, it will impact your ability to access some of the Website’s functions and features.

Performance Cookies help us enhance the performance and functionality of our Website, products and service, but are not necessary for your use.  Still, certain functions or features may become unavailable if you refuse them.

Analytics Cookies collect information that is used to help us understand the use of our Website, products and services, the effectiveness of our marketing campaigns, or to help us customize our Website to enhance your experience.

Target Cookies record your visit to our Website, the pages you have visited and the links you have followed, so we can recognize you as a prior visitor and track your activity on our Website and others you visit. These Cookies remain on your device for us to use during a next visit to our Website.  In contrast to these “persistent” cookies, some cookies (“session cookies”) are deleted when your browsing session has ended.

We also allow third parties to use cookies on our Site to collect information about your online activities over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest based advertising, and to analyze the effectiveness of such advertising.

You may restrict, block or delete the cookies from this Site at any time by changing the configuration of your browser. You can find out how to do this, and find more information on cookies, at https://www.allaboutcookies.org/. In addition, while each browser has different settings and configurations, cookies settings can typically be adjusted in the "Preferences" or "Tools" menu. Your browser’s "Help" menu may provide additional information.

There are “do not track” or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Site will not operate any differently when a “do not track” signal is received.

Social Networking Sites

You may be able to post content to Social Networking Sites (such as Facebook, Instagram or Twitter) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Sites in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network Sites.

Third Party Links

Our Site may have links or be linked to other sites we do not own, control or maintain. We are not responsible for and make no representations or warranties about the privacy practices of those sites. We recommend that you check the privacy policies of other sites and contact the operator if you have concerns or questions. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third party sites.

Children

If you are under the age of majority where you live, you must obtain consent from your parent or guardian to use the WAX Products. Notwithstanding the foregoing, you may not use the services if you are under the age of majority where you live if you use PayPal in association with your account.  If we learn that we have collected personal information from anyone under the age of 13, we will endeavor to delete such information as soon as reasonably possible.

Opting Out of Communications

You may opt-out of receiving marketing-related emails by clicking the "unsubscribe" link at the bottom of any email you receive from us or by changing the communication preferences on your online account or profile. If you no longer want to receive promotional text messages from us, please follow the cancellation instructions contained in the last text message. If you are having difficulty unsubscribing from our marketing communications using the above methods, please contact us at privacy@wax.io.

If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your orders, customer service inquiries, promotions participation and other matters.

If you agreed to receive future marketing communications directly from a third party through our Site, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s Privacy Policy.

Privacy Rights of California Residents

If you are a California resident, you may have certain rights with respect to your personal information, including the following:

the right to know, by way of our Privacy Policy and any specific inquiries you direct to us, the source of the personal information we have about you, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;

the right to “opt-out” of WAX’s sale of your personal information to any third parties;

the right, with some exceptions, to have your personal information deleted from WAX’s possession or control; and

the right to receive equal service and pricing from WAX even if you exercise any of your privacy rights.


California Civil Code Section 1798.83 permits California residents who use our Site to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, or if you have any questions or concerns about your California privacy rights, our Privacy Policy or our use of your personal information, please send an e‐mail to privacy@wax.io, or contact us at:

California Privacy Rights

Exposition Park Holdings

Floor 4, Willow House, Cricket Square

Grand Cayman KY1-9010, Cayman Islands


For all California residents, any such inquiries shall be responded to within forty-five (45) days and at no cost to you.  We must verify your identity with respect to such inquiries.  Depending on the nature of the Personal Information at issue, we may require additional measures or information from you as part of that verification. 

For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are registered user of any Site where this Policy is posted.  To make such a request, please send an email with a detailed description of the specific content or information to privacy@wax.io. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that the law may not require or allow removal in all instances, even if requested.

If you are a California resident, you may have the right to request and receive certain information about a company’s disclosure of your personal information to third parties for their own direct marketing use, and your choices with respect to such disclosures.

California Civil Code Section 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wax.io, or write us at:

Floor 4, Willow House, Cricket Square, Grand Cayman KY1-9010, Cayman Islands

EU Resident Privacy Rights

For individuals in the European Economic Area, please click [here] for information about your rights to your personal data.

Changes to our Privacy Statement

We may update this Privacy Statement from time to time, so please check the effective date at the top of this page as the date of last revision. Changes will become immediately effective upon posting on our Site unless otherwise noted. Your use of the Site following these changes indicates your consent to the practices described in the revised Privacy Statement.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information at privacy@wax.io.

 


Privacy Rights of European Union Residents  [separate link]

WAX has a legitimate interest in learning more about user preferences to offer products and services that better meet your needs and desires.  In our Privacy Policy, we explain how we use your online activity and personal data for such purposes and the controls you have over those uses.  If you are a resident of the European Union or the European Economic Area or the United Kingdom, you are afforded certain rights regarding your personal data. Specifically, EU, EEA and UK residents have the following rights:

To be informed about what happens with your Personal Data (information relating to an identified or identifiable natural person), including how it is collected from you, how it is used as well as the right to access that Personal Data, to modify it when it is incomplete or incorrect, and the right to withdraw consent for its use;

To access Personal Data held by organizations about an individual;

 To rectification allowing individuals to correct inaccurate information or complete incomplete information;

To erasure (or the right to be forgotten) allowing, with some exceptions, an individual to have their Personal Data deleted upon request;

To restriction and withdraw consent for data processing;

 To data portability allowing individuals to ask for the transfer of their Personal Data or to obtain and use their Personal Data for their own purposes;

 To object, with some exceptions, to the processing of an individual’s Personal Data; and

To prevent automated decision making or profiling and to require that those decisions be made by natural persons.

You also have the right to lodge a complaint with a Supervisory Authority.  If you have questions or concerns about these rights and how they relate to this Privacy Policy or the Site, please direct your inquiries to privacy@wax.io or write us at:

WAX
Attention: European Data Privacy
Floor 4, Willow House, Cricket Square, Grand Cayman KY1-9010, Cayman Islands
Email: privacy@wax.io