1. VOICE AND DATA PRIVACY
Accountability for and transparency about the way in which we handle your personal data are extremely important to us where we are acting as a data controller with respect to your data. This Privacy Notice is given by and on behalf of the relevant contracting Voice entity specified in the Terms of Service.
Where law or regulation requires us to provide you with a notice, or other explanation of the information about you that we collect and process (or similar), this Privacy Notice shall be understood as fulfilling our obligation to provide you with such notice or explanation.
2. INFORMATION THAT VOICE COLLECTS
In addition to the personal data you make publicly accessible on Voice, we collect certain personal data which is not generally publicly accessible. As explained below, we only process your non-publicly accessible personal data to the extent required for platform administration and certain other limited uses which are necessary for the services we provide to you.
2.1 INFORMATION THAT WILL BE MADE PUBLICLY ACCESSIBLE
Information on Voice that will be publicly viewable by all, whether the person accessing the information is a registered user or a visitor to Voice, includes the following:
- The username you provide when you sign-up for an account.
- Content that you choose to share on the Voice platform. Depending on the content you choose to share, this could consist of text, images, videos, audio, or other material, including:
- NFTs you create, co-create, curate; mint; purchase; sell; or otherwise interact with
- Descriptions, metadata, and other details you provide associated with your created or purchased NFTs
- Information you provide about yourself (for example, any profile photo, display name, bio, links to your handles or profiles on other social platforms, or other information) in your Voice profile.
- Information about actions you take on Voice. This includes:
- Actions you take to mint, sell and buy NFTs
- Blockchain records associated with your activity in creating, minting, owning, purchasing, and selling NFTs
- The content that you engage with
- The features that you use
- Any actions you take in relation to content
- Any actions you take in relation to other users.
2.2. INFORMATION THAT WILL NOT BE MADE PUBLICLY ACCESSIBLE
We collect certain information about you which will not be made publicly accessible in connection with the following processes:
- User information. When you sign up for a Voice account, and in order to access certain features on Voice, you may be asked to submit:
- Your email address;
- Your residential location or address;
- The jurisdiction or country where you reside
- Your social security number (for U.S. residents only), or other identification number (for non-U.S. residents)
- Other identifying or contact information you provide to us.
- Personal information, which may include your legal name, address, and/or date of birth
- A scan of your government-issued photo identification document (ID)
- A photo of you (“selfie”), taken through a liveness and face detection software, that is used to verify that you match the person displayed on your government-issued photo identification.
- An identification number; such as a social security number (for U.S. residents), a taxpayer identification number, a passport number and country of issuance, an alien identification card number; or a number and country of issuance of any other unexpired government-issued document evidencing nationality or residence, and including a photograph or similar safeguard.
- On an ongoing basis, data related to sanctions screening and transactions monitoring.
- Transactions processing: Voice uses Circle Internet Financial Ltd.
(“Circle”) to process all financial transactions on the Voice platform. Data you submit in connection with
information may be collected in order to complete transactions on the Voice platform:
- Credit Card Transactions:
- Name as it appears on your credit card
- Valid credit card number
- Card expiration date
- Card security code
- Billing address linked to your credit card
- Credit Card Transactions:
- USDC Transactions: If you choose to complete USDC transactions on the Voice platform,
including withdrawing funds in USDC, you may be asked to submit the following information to Circle:
- A valid digital wallet QR code for a blockchain wallet that supports USDC transactions
- The blockchain associated with your wallet
- Wallet address
- Administrative and operational processes. Information you provide to us in
connection with administrative and operational activities. This includes:
- Information you provide when registering your interest in Voice.
- Information you provide when signing up for any Voice newsletters.
- Updates you provide within the platform or through our support channels.
- Information you provide in any emails or other correspondence you send to us.
- Information you provide in submitting any question or comment or completing any survey, questionnaire or other form.
- USDC Transactions: If you choose to complete USDC transactions on the Voice platform, including withdrawing funds in USDC, you may be asked to submit the following information to Circle:
- Information collected on our platform:
- When you use or visit Voice, it will automatically collect some information about you and your visit, including Internet and network activity such as the Internet Protocol (IP) address (which may provide information about your location) used to connect your device to the Internet and some other information such as your type of device, browser type, and version, website navigation patterns, the pages that you visit as well as the timing, length, frequency of each visit.
- Certain data may be collected on our platform by us and by our third-party service providers using “cookies” which may be downloaded to your device and/or placed onto your browser. For more information about data collected on our platform using cookies, and about managing your cookie preferences as to the categories of data we may collect about you using cookies, please refer to our separate Cookie Notice.
- If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems may record details of those conversations, sometimes including their content, which may include visual and audio information about you.
- Information collected through publicly available sources: We may collect certain information from publicly available sources such as from third-party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with legal and regulatory obligations.
- Information we do not collect: We do not market to and do not knowingly collect any personal data from or about a minor under the age of 18. Voice is not intended for use by minors under the age of 18. Minors under the age of 18 must not use Voice for any purpose. If you believe we have any personal data from any minors under the age of 18 without such parental/guardian consent, please contact us at the email address specified below.
3. HOW WE USE YOUR INFORMATION AND BASIS OF PROCESSING
We only process certain types of your information as necessary to fulfil our Terms of Service and with your consent for specific purposes through enabling and disabling settings on the Voice platform. For users who live in the European Economic Area (EEA), it also identifies the legal basis under which we process your data:
|Information||Lawful Basis||Purpose of Processing|
|Registration and Log-in Data||Contract||to create your user account;|
to login to your account;
to notify you of changes to Voice;
to provide user support;
to enforce Voice terms, conditions and policies;
to communicate with you;
to develop new and improve existing services;
to administer the platform including troubleshooting;
to enable you to share content and interact with others;
to provide language and location customization;
to detect abuse, fraud and illegal activity on Voice.
|Financial Transactions Data||Contract||to process transactions, including payments and payouts, and facilitate exchange of NFTs;|
to retain financial records as is legally and operationally required;
|Know Your Customer (“KYC”) Process||Contract|
Given that this involves collection of biometric data, the lawful basis under article 6 of GDPR is Contract & under article 9 is explicit consent
|use of face image or ‘selfie’ to verify match to government-issued identification; |
to comply with legal and regulatory obligations;
|Shared Information||Contract||to manage the Voice platform in accordance with your instructions and requests (including posting, liking, sharing, commenting on content, whether yours or other users);|
to provide personalized help and instructions;
to provide language and location customization;
to develop new and improve existing services;
to administer the platform including troubleshooting;
ensure content is presented is the most appropriate format for your device.
|Security and investigations||Legitimate Interest: Security and protection of data||To operate, administer, secure and improve Voice, the Voice Chain, and other aspects of the way in which we conduct our operations to promote safety and security;|
to communicate with you, on Service-related issues;
to verify accounts and activity (This includes processing data for identity verification purposes and in order to confirm that the same user does not have more than one account or prevent the user from signing up to the platform again if they have removed due to misuse);
to prevent harmful conduct or illegal content;
to detect spam;
to investigate suspicious activity in breach of our Terms of Service and Content Guidelines;
to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;
to administer the Terms of Service, Content Guidelines and any other Policies specified in the Terms of Service, and any other policies and rules applicable to Voice.
|Customer Support||Legitimate interest: respond, resolve and investigate customers’ queries/complaints||to answer any user queries|
to resolve account issues.
|Sharing with law enforcement/legal requests||Legal Obligation||to comply with valid legal requests;|
to comply with our legal and regulatory obligations.
|Protection of interests of an individual||Vital Interests||protection of your life or physical integrity or that of others;|
to combat harmful conduct;
to promote safety and security.
|Marketing Information||Consent||to provide you with personalized advertising;|
to send emails with details about products/services that may be of interest to you.
|Data Analytics||Consent||to provision data analytics to third parties based on information available on the Voice Chain relating to your interactions with the platform and other information about your use of Voice.|
4. WHO WE SHARE INFORMATION WITH
In order to provide you with the services of our platform, and/or in connection with your use of features on the Voice platform, we share your personal data with our third party suppliers, subcontractors and other service providers, and with other third parties solely for purposes of legal and regulatory compliance, and as needed in connection with our corporate and organizational operations. We endeavor to only share the minimum amount of personal data needed for those third parties to perform their services, and to meet our legal and regulatory compliance obligations and corporate disclosure requirements. We will process any sensitive data, in accordance with all applicable regulations and security measures.
Third party service providers with whom your personal data is shared include providers who host our websites, provide information technology and systems, or otherwise hold or process your information on our behalf, under appropriate conditions of confidentiality and security. We vet all of our service providers prior to engaging them to ensure that they also process data in accordance with applicable regulations and security measures. Further details of how our service providers process data can be found in each provider’s privacy notice.
Below is a list of some specific third parties with whom we share your personal data. This list is not exhaustive, but will be reviewed and updated on an ongoing basis to include any service providers who have been more recently engaged by Voice. Third party service providers and others with whom we share data include:
- Regulatory, prosecuting and other governmental agencies, courts or authorities or litigation counterparties, in any country or territory; to comply with any applicable laws or regulations; protect our legitimate rights, privacy, property, vital interests, health and safety, as well as those of our customers, business partners, personnel, or the general public; seek professional advice, manage risk (including obtaining and managing insurance), pursue available remedies or limit damages; enforce our Terms of Service; or respond to an emergency; and
- A person or entity who intends to or is taking over our business and assets, or relevant parts of them, due to a prospective or concluded merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.
Voice may be required to provide the information collected in connection with the AML/KYC program to regulatory agencies, law enforcement, private parties, financial institutions, or other entities. Voice may also voluntarily comply with requests for information concerning information collected in connection with the AML/KYC program from regulatory agencies, law enforcement, private parties, financial institutions, or other entities, including, but not limited to voluntary information sharing pursuant to Subsection 314 of the USA Patriot Act and 31 CFR 1010.540.
These disclosures may involve transferring your personal data to any of our offices overseas for processing in accordance with this Privacy Notice and as permitted by the applicable laws. If you are dealing with us within the European Economic Area (EEA) or the United Kingdom (UK), you should be aware that this may include transfers to countries outside the EEA / UK. Such intra-organisational transfers are based on approved mechanisms.
Where we rely on our service providers located outside of your jurisdiction and acting as data processors, we ensure that they are subject to laws ensuring an adequate level of data protection as set out in an applicable adequacy decision of the relevant regulatory authority (which may include the EU-U.S. Privacy Shield) or will ensure that an adequate level of data protection will be available on the basis of standard contractual clauses that will allow you to directly enforce your rights as a third-party beneficiary.
We do not sell any of your information to anyone, and we never will without your consent. We also impose strict restrictions on how our partners can use and disclose the data we provide.
5. RETENTION AND DELETION OF YOUR INFORMATION
We retain your personal information for the period of time necessary to fulfill the purposes outlined in this Privacy Notice and our record retention policies, unless a longer retention period is required by law. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
5.1 General Data Retention. Any personal, non-public information will be stored with us for as long as you hold a Voice account and/or use Voice’s Services. Should you choose to delete your Voice account, your personal information will be deleted in a timely manner in accordance with all applicable data privacy laws. In the event that deletion is delayed due to practical and/or technical limitations of our systems, Voice will process the deletion of content as soon as it is technically feasible. Due to regulatory compliance obligations and/or technical limitations of our systems, deletion of content will be restricted and/or may not be possible in the following circumstances:
- due to associated data being stored on a blockchain, which is immutable and uneditable, or other immutable means of storage;
- where your content is included in an NFT which has been transferred or sold to another person;
- where your content has been used by others in accordance with this license and they have not deleted it;
- where we are required to retain records, including transactions processing records and data, due to legal and/or regulatory obligations and/or requirements; or
- where it may restrict our ability to: investigate or identify illegal activity or violations of our terms and policies (for example, to identify or investigate misuse of our products or systems); comply with a legal obligation, such as the preservation of evidence; comply with a request of a judicial or administrative authority, law enforcement, or a government agency; or to protect the safety and security of our products, systems, and users.
5.2 Transactions Processing Data Retention. For legal and operational reasons, certain data that you submit to Voice when you initiate financial transactions processed on the platform, such as identifying information, transactions related, due diligence information, and tax information must be retained for a period of a minimum of five years, of up to a maximum of seven years, even if you opt to delete data associated with your Voice account.
Should you make a request to redact or delete data associated with Voice, we will take all reasonable measures to delete your data submitted to Voice, while retaining only that which is necessary to comply with applicable legal requirements.
5.3 NFT Content Retention. NFT content should not contain personally identifying information, and therefore is not considered personal data. Once minted to the blockchain, NFTs and associated metadata are immutable and uneditable, even if the NFT content creator opts to delete their Voice account. Any NFTs minted on Voice cannot be deleted by Voice, even if you request to have all other personal data related to your account deleted.
Further information about our record retention policies is available on request. Please contact us through one of the communication methods set out below.
6. SECURITY AND CONTROL OF YOUR INFORMATION
6.1. Data storage. Data you submit to Voice that is public will be stored and processed differently, depending on whether it is stored on the blockchain (which is immutable and uneditable), or mutable and editable. Learn more in the Voice FAQ.
6.2 Data Security. The security of your information is important to us. We have implemented appropriate technical, physical and administrative security measures intended to protect your personal data from unauthorized access, disclosure, alteration or destruction. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.3 Limitations of Data Control. It is possible for third parties to take information which is publicly accessible on Voice and use it without our knowledge or authorization, and for other users to post information about you on Voice that will be publicly accessible. These behaviors are outside of our control and any such use is beyond the scope of this Privacy Notice. Depending on your place of residence, such third parties may be obligated to notify you if they have obtained your personal data in this way. If you believe another user has violated any Voice Policies, such as the Terms of Service or Content Guidelines, by posting information about you on Voice, you may choose to report this following the procedures set out in the Content Guidelines.
7. AUTOMATED DECISION-MAKING
We may use automated decision-making tools in connection with processing your personal data. Automated decision-making may occur during the following processes:
- Verification steps to complete the Know Your Customer (“KYC”) process;
- Verification steps required to successfully process financial transactions;
- Trust, safety, and security screening of user accounts and activity to protect the Voice platform and community from fraud, illegal activity, and other harms.
Should you wish to object to, or should you encounter any issues resulting from automated decision-making which appear to have occurred in error, you may reach out to Voice for support at [email protected].
8. RIGHTS OF INDIVIDUALS IN CERTAIN PLACES
If you are located in certain places, you may have some or all of the following rights pursuant to data protection or privacy laws that apply to you:
- A right of access to the personal data that we hold about you, and information related to how we process your data. Such related information include information on the categories of data, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, the recipients of your personal data, and the safeguards regarding data transfers to other jurisdictions, subject to the limitations set out in applicable laws and regulations. We will provide you with one copy of your personal data free of charge, but we may charge you a reasonable fee to cover our administrative expenses if you request further copies of the same information.
- A right to rectify any inaccurate personal data that we hold about you to be corrected or deleted.
- A right to ask us to delete your personal data (“right to be forgotten”). We will decline your request for deletion if processing your personal data is necessary: (i) to comply with our legal obligations such as fraud detection and monitoring; (ii) or being required to perform a task in the public interest; (iii) in pursuit of a legal action; (iv) for exercising the right of freedom of expression and information; and (v) for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing.
- A right to ask how your personal data has been shared, if at all, with third parties for the third parties’ direct marketing purposes, as well as to object to our use of your personal data for direct marketing purposes at any time.
- A right to object to our processing of some or all of your personal data – based on our legitimate interest (or that of a third party) – on the basis that it impacts on your fundamental rights and freedoms.
- A right to restrict our processing of some or all of your personal data if:
- you dispute the accuracy of your personal data;
- your personal data was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal data;
- we no longer need to process your personal data, but you require your personal data in connection with a legal claim; or
- you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
- A right to object to actions taken based on automated decision-making.
- A right to data portability, which means you may receive your personal data in a structured, commonly used and machine-readable format. However, you may only exercise this right if the processing of your data is based on your consent or carried out by automated means.
- A right to withdraw, at any time, any consent that you gave us to process your data. Your consent withdrawal will not affect the lawfulness of the processing done before the withdrawal.
If you wish to exercise any of these rights that apply to you, please contact us as set out below. When exercising any of these rights, you will have to prove your identity to our satisfaction so that we can be sure that they apply to you and to safeguard your information from unauthorized access by someone impersonating you.
We may continue to store your personal data to the extent processing is required or based on one of the following bases: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
In the event where you do not have the benefit of a particular right (whether stated above or not) or we do not have to comply with a particular obligation, we may nevertheless without obligation and in our sole discretion grant you the benefit of such right or choose to fulfil such obligation but are under no continuing obligation to do so.
You may also be able to object to our processing of your personal data with the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose, but we would invite you to attempt to resolve the issue with us first.
9. MARKETING COMMUNICATIONS PREFERENCES
When you sign up for a Voice account, or sign up for a Voice interest list, you agree that we may send you occasional and/or periodic marketing information, such as emails, updates, newsletters, and other information about Voice, and opportunities, features and activities offered by Voice that may be of interest to you (collectively, “Marketing Communications”). We may provide Marketing Communications to you by emailing them to you at the email address you provide, by sending an SMS or text message to a mobile phone number that you provide, by posting them to the Voice website, or by other means. Marketing Communications will only be sent to you from Voice, and not any third party. We will not share your information with any third parties for use by them for marketing purposes.
You may opt out of receiving Marketing Communications at any time by unsubscribing, for example, using available “Unsubscribe” buttons available in emails; or by notifying us by email at [email protected]; or via any other communication channel that we have used to contact you and telling us that you wish to unsubscribe.
10. DO NOT TRACK
Certain web browsers and other devices you may use to access Voice may permit you to submit your preference that you do not wish to be “tracked” online. We do not currently commit to responding to these submissions, in part, because no common industry standard for “do not track” has been adopted by industry groups, technology companies, or regulators. We will make efforts to monitor developments around “do not track” browser technology and the implementation of a standard.
11. CONTACT US
We welcome questions, comments and requests regarding this Privacy Notice and our processing of personal data. Please use the following means to contact us:
- By mail to: 4001 Kennett Pike, Suite 302, Wilmington, Delaware 19807, USA
- By email to: [email protected]
- By phone at: +1 540 315 8111
If you are in the EEA, you may also contact our EU Representative, designated for the purposes of Article 27 of the GDPR:
- By email to: [email protected]. Please note that when submitting an email, you should quote <Voice US LLC> in the subject line of your email.
- By online webform at: www.datarep.com/data-request
- By mail to one of the following addresses listed below, depending on where in the EEA you reside. Please note that when submitting an enquiry, it is essential to mark your letter recipient as “DataRep,” or the letter may not reach our EU representative.
|Austria||DataRep, City Tower, Brückenkopfgasse 1/ 6. Stock, Graz, 8020, Austria|
|Belgium||DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium|
|Bulgaria||DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria|
|Croatia||DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia|
|Cyprus||DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus|
|Czech Republic||DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava- mesto, Moravska, Ostrava, Czech Republic|
|Denmark||DataRep, Lautruph⌀j 1-3, Ballerup, 2750, Denmark|
|Estonia||DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia|
|Finland||DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland|
|France||DataRep, 72 rue de Lessard, Rouen, 76100, France|
|Germany||DataRep, 3rd and 4th floor, Altmarkt 10 B/ D, Dresden, 01 0 67, Germany|
|Greece||DataRep, 24 Lagoumitzi str, Athens, 17671, Greece|
|Hungary||DataRep, President Centre, Kàlmàn lmre utca 1, Budapest, 1054, Hungary|
|Iceland||DataRep, Kalkofnsvegur 2, 101 Reykjavik, Iceland|
|Ireland||DataRep, The Cube, Monahan Road, Cork, T12 HlXY, Republic of Ireland|
|Italy||DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy|
|Latvia||DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia|
|Liechtenstein||DataRep, City Tower, Brückenkopfgasse 1/ 6. Stock, Graz, 80 20, Austria|
|Lithuania||DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania|
|Luxembourg||DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg|
|Malta||DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta|
|Netherlands||DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands|
|Norway||DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway|
|Poland||DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland|
|Portugal||DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portuqal|
|Romania||DataRep, 15 Piața Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania|
|Slovakia||DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia|
|Slovenia||DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia|
|Spain||DataRep, Calle de Manzanares 4, Madrid, 28005, Spain|
|Sweden||DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden|
|United Kingdom||DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom|
Alternatively, you may contact our appointed data protection officer whose contact details are as follows:
- By mail to: Advisori LLC, 1750 Tysons Boulevard, Suite 1500, McLean, Virginia 22102, USA, Attention: Christopher Folk
- By email to: [email protected]
Please also contact us using the method above if you have a disability and require this Privacy Notice in an alternate format.
12. CHANGES TO THIS PRIVACY NOTICE
Any changes we make to this Privacy Notice in the future will be made available on Voice and also available if you contact us as set out above. Please check back frequently to see any changes. To the extent permitted by law, by continuing to use Voice after changes have been posted, you are confirming that you have read and understood the latest version of this Notice.
If you do not agree with any of the statements set out in this Privacy Notice, you should stop using Voice in any way.