SEROTONIN PLATFORM PRIVACY AND COOKIES POLICY

Last Revised on June 19th, 2024 

Welcome to the Privacy and Cookies Policy for the website platform.serotonin.co (the “Website”) operated by or on behalf of Serotonin Inc. and Serotonin Holdings LLC (together, “Company, “we or us”). This Privacy and Cookies Policy (this “Privacy Policy”) provides the legitimate basis or processing personal information and how us or third parties collect, use and disclose information from our users, including with respect to the Website, as well as the content, applications services, tools and features made available therein (collectively, “Services”). For purpose of this privacy policy, “you and “your” means you as the user of the Services. If you use the services on behalf of a company or other entity then “you” includes you as that entity, and you represent and warrant that (a) you are an authorized representative of the entity with the authority to bind the entity to this Privacy Policy and (b) you agree to this Privacy Policy on the entity’s behalf.

The services can only be accessed and used subject to Company’s Terms of Service and this Privacy Policy. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING, ACCESSING, OR DOWNLOADING ANY OF THE SERVICES, YOU AGREE THAT YOU ARE BOUND BY THE TERMS OF SERVICE AND PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF SERVICE AND PRIVACY POLICY, THEN YOU MAY NOT ACCESS AND USE THE SERVICES.

1. TYPES OF INFORMATION COLLECTED BY US OR THIRD PARTIES

  • We may partner with other companies (“Third-Party Partners”) to successfully provide you with some of the Services. In order to accomplish the aforementioned, we may need to share your Personal Information with the applicable Third-Party Partners so they can meet their legal and regulatory obligations. Us and/or Third Party Partners may collect the following categories of information from you (“Information”), which includes:
  • “Personal Information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s postal address and email. Personal Information includes registration information you provide when you create an account, such as your first and last name, wallet address and email address.
  • “Non-Personal Information” means Information that does not directly or indirectly identify, and cannot reasonably be used to identify, and individual user. When Non-Personal Information is directly or indirectly associated with Personal Information, this Non-Personal Information is treated as Personal Information.
  • Information you provide to us when you access or use the Services and each time you interact with the Services or Company, for example, when you update information in your control panel, communicate with us by telephone or email, and order or download new products or services. This information is collected for the purposes of providing customers services, improve the performance of the platform and may include engagement with our content, authentication data and links accessed on the platform. 
  • “Biometric Information” means personal data resulting from specific technical processing relating to the physical, physiological, or behavioral characteristics of a natural person, which allows or confirms the unique identification of that natural person, such as facial images or fingerprint data. When providing biometric checks to complete the purchase from any of our Services, we may ask for a picture or video of a user’s face as well as the image or video of their identity document. When our Third-Party partners perform biometric checks, they do not store the extracted biometric data once the check is complete.
  • Information you provide in public forums through services, including using our review comment, post or similar functionality.

2. HOW WE COLLECT YOUR INFORMATION

We collect information you provide to us when you register with us; create user generated content, request products, services, or information from us: participate in public forums or other activities through the Services; respond to our customer surveys; or otherwise interact with us. Please keep in mind that when you post information on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The Information we collect is covered by this Privacy Policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you make on the third-party site or platform will not apply to our use of information we collect directly through our Services.

Online Tracking

  • Do not track (“DNT”) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. Like many websites, the Company and the services do not recognize DNT.

3. USE AND PROCESSING  OF YOUR INFORMATION BY THE COMPANY

We may use your data for the following purposes:

  • To provide you with the Services and the products and services you request;
  • To Administer your account;
  • To communicate with you about your account or transactions with us and send you information about features of the Services or changes to our policies;
  • To ensure consistency with local law and choices and controls that may be available to you;
  • To personalize content and experiences;
  • To detect, investigate and prevent activities that may violate our policies or are  illegal;
  • To optimize or improve the content, products, services, and features of the Services;
  • To personalize and improve the Services and users experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match our users profiles and interest; and
  • To monitor and analyze the services usage and trends or otherwise measure the effectiveness of the Services.
  • To improve or augment your experience we may use information received from Google APIs to show you relevant information from your emails, contact-book, and calendars. Serotonin’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

The data may be processed for the following purposes: 

  • To verify your identity and location for purpose of AML and KYC compliance, and to help us connect you to your historical data and account. 

By registering and using the Services, you consent to receive follow-up questions, promotional and other communication, either from us or from relevant Third-Party Partners. We may also send you newsletters about the services, provided you have consented to receive these.

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4. SHARING YOUR INFORMATION WITH OTHER COMPANIES

We will not share your personal information outside of the Company except in limited circumstances, including:

  • When you allow us to share your Personal Information with another company, such as directing us to share your personal Information with third-party sites or platforms, such as social networking sites;
  • When we contract or partner with a third party to provide services on our behalf, including Services development and maintenance. We require third parties to process your data in accordance with this Privacy Policy and as permitted as permitted by applicable data protection laws; and
  • When we share Personal Information with third parties in connection with the sale of business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings), to enforce our  Terms of Services or rules, to ensure the safety and security of our users and third parties, to protect our rights and property and the rights and property of our users and third parties, to comply with legal process, including judicial warrant, rule, order, or subpoena or in other cases if we believe in good faith that disclosure is required by law or regulation.

In addition, we may share Non-Personal Information with third parties, alone or in combination with your Non-Personal Information or the Non-Personal Information of other users.

5. PUBLIC VENUES AND SEMI-PUBLIC VENUES OF THE SERVICES.

If you use a message board, comment function, conversation pages, blogs, social community environments, profiles pages or other public or semi-public venue or forums of the Services, you will be identified on those venues by the information you submit.

6. YOUR CONTROL AND CHOICES

We strive to provide you with the choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information. Your controls and choices may include:

  • You may correct, update and delete your registration account;
  • You may change your choices for newsletters and alerts; and
  • You may request access to the Personal Information we hold about you and that we amend or delete it.

You may exercise your controls and choices, or requests access to your Personal Information at any time, by modifying visiting the opt out option, on your profile or by contacting us at platform@serotonin.co of following instructions provided in communications sent to you.  If access or control to your Personal Information is not available via the tools above, you can always contact us using to the email address below. Please be aware that, if you do not allow us to collect your Personal Information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interest and preferences. If you have questions regarding specific Personal Information about you that we process or retain, please contact us at platform@serotonin.co.

7. THIRD PARTY WEBSITES AND LINKS

Our services may contain links to other sites operated by third parties. The company does not control such other sites and is not responsible for their content, their privacy policies, or their use of Personal Information. Information you provide on public or semi-public venues, including information you share on third party social network platforms (such as Twitter and Discord) may be also viewable by other users of the Services and user from those third parties platforms without limitations as to its use by us or by third party. The Company’s inclusion of such links does not, by itself, imply any endorsement of the content on such sites or of their owners of operators except as disclosed on the Services. The company expressly disclaims any and all liability for the actions of third parties, including without limitation to actions relating the use and/or disclosure of Personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

8. CHILDREN’S PRIVACY

We do not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our databases.

If you are a parent or guardian of a minor child who has provided us with Personal Information, you may contact us to request to be deleted.

9. DATA SECURITY, INTEGRITY, AND RETENTION

We use reasonable security measures, including computer safeguards and secured files and facilities that comply with federal law to protect and limit access to Personal Information. Please note the information you send us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware thought that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal Information for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required, or for the establishment, exercise, or defense of legal claims, or for legitimate business purposes, or as provided by law.

Access tokens and data obtained from third-party APIs (Google, Telegram and Farcaster) is stored in a encrypted data-store using  AES-256 encryption format.

10. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to notify you, such as by e-mail, and/or by placing a prominent notice on the first page of the website, and/or by implementing a mandatory click-through process. In the event we implement mandatory click-through process for any material changes to these Terms, by clicking, you agree and acknowledge you have read the changes and acceptance of the modified Terms will become effective. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT ACCEPT AND AGREE TO THIS PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS OR USE THE SERVICES.

11. YOUR CALIFORNIA PRIVACY RIGHTS.

This privacy Policy describes how we me may share your Information for marketing purposes. It applies to all users of Services, including California residents.

If you are a user of the Services and a California resident under the age of 18, you may request to have your posted content o Information removed from the publicly viewable portion of this website by or contacting us directly at platform@serotonin.co. In certain situations, content or information cannot be removed. The Company does not sell (as such term is defined in the California Consumer Privacy Act (“CCPA”)) the personal information we collect (and will not sell it without providing a right to opt out). 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. 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.

As California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose information for such third parties’ marketing purposes and categories of information we may disclose. See “How to contact us” below.

Categories of Personal Information Collected in Connection with the Services:

  • Internet and other network activity information, including online identifiers, such as your email address, mailing address and name.

Sources of Collection

  • You.
  • Any other individual you have authorized to provide us with your personal information.
  • Devices you use to access this Website.

Business/Commercial Purpose for Collection

  • To provide you with information or services that you request from us.
  • To improve this Website and present its contents to you.
  • To prevent, detect, and investigate fraud or other security incidents.

Categories of Third Parties Receiving Personal Information

  • Affiliates. 
  • Technology services.

In the past twelve months, we have disclosed Personal Information collected through the Services for business or commercial purposes to our affiliates and technology service providers.  

The categories of personal information we have disclosed to third parties for business or commercial purposes are:

  • Internet activity information, including online identifiers, such as your email address, mailing address and name.

In the past twelve months, we have not sold Personal Information collected through the Services to third parties. Because we do not sell Personal Information, we do not offer an opt out.

Right to Know

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their Personal Information.

Right to Delete

California residents have the right to request deletion of the Personal Information we have collected from them.

Request Submission

You or your authorized agent can submit a request by emailing platform@serotonin.co. You will need to provide us with Personal Information for us to match with information we have on file in order to verify your identity and residency. The Personal Information that we use to verify your identity and residency will not be used for any other purpose.

Right Against Discrimination

California residents have the right to not be discriminated against for exercising their rights under the CCPA.  We do not discriminate against California residents who exercise their CCPA privacy rights.

12. OPT OUT OF MARKETING COMMUNICATIONS

Promotional Offers. We may send you communications (through email or by other means) concerning our products, services, blog, or newsletter as well as those of third parties or partners. You may opt out of promotional emails by following the unsubscribe instructions in the promotional email itself or by contacting us at platform@serotonin.co.

We do not control third parties; collection or use of your information to serve interest-based advertising, however, these third parties may provide you with ways to choose not to have your information collected or used in this way.

13. COOKIES

What are cookies. 

Cookies are small, often encrypted text files, located in browser directories (also known as browser cookies or tracking cookies). Cookies are used to collect information about you and your use of the websites and/or mobile apps. They are downloaded to your computer or smart device when you visit the Website. Cookies allow us to recognize your device and preferences and provide us information which can be used to improve your experience with us.

How we use cookies.

This section sets out information about our use of cookies. We use cookies or other tracking technologies to help us enhance and understand your user experience on the Website. We also use cookies for honoring your preferences and settings, enabling you to sign in, provide you with personalized advertising and fulfilling other legitimate purposes. 

Types of Cookies we use

A cookie can be classified by its lifespan, purpose and the domain to which it belongs. Our Website uses the following types of cookies:

  • Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.
  • Analytics Cookies: These cookies collect information about how you use the Website, for instance, which pages you visit most often. This information is used to improve how the Site works and improve the user experience.
  • ‍Tracking Cookies: These cookies collect information on a users tendencies and preferences on the Website including clicks, device specifications, locations and search history.

Manage the use of cookies.

You have the right to manage the use of cookies.  You can adjust your cookies settings through our Website.  Below you can determine if you want to remove, manage, or block cookies. Please keep in mind that deleting and blocking cookies may have an impact on your user experience.

Removing cookies from your device.

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (e.g. saved login details, site preferences, etc).

Managing Website-specific cookies. 

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

Blocking cookies. 

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit the Website, and some services and functionalities may not work properly at all (e.g. profile logging-in). The website www.allabaoutcookies.org contains comprehensive information about the process of opting out different browsers. If you are in the EU and would like to opt out of third-party cookies relating to behavioral advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

In the US, the Network Advertising Initiative offers a means to opt out of a number of advertising cookies. Please visit http://www.networkadvertising.org/choices/ to learn more. 

Cookie Retention.

We retain cookies as long as we receive consent from you and as long as we have a legitimate basis to do so. This legitimate basis is based on our use of strictly necessary cookies which in any case, the retention period shall not exceed a period of thirteen (13) months. Once this period has expired, we will be required to renew your consent for the use of  cookies.

Third Party Cookies.

Some of our pages display content from external providers. To view this third-party content, you first must accept their specific terms and conditions. This includes their cookie policies, which we have no control over. However, if you do not view this content, no third-party cookies are installed on your device.

14. HOW TO CONTACT US

You may contact us regarding the services or this Privacy Policy at platform@serotonin.co or by e-mail at platform@serotonin.co.