Privacy Policy
Last Updated: January 27, 2025
This Privacy Policy (“Privacy Policy” or “Policy”) describes how Agora Labs Ltd. (together with its affiliates, parents, or subsidiaries, “Legion,” “we,” “us,” or “our”) collects, uses, shares, stores, and safeguards your personal information when you access or use the website (including all subdomains), crypto-asset launchpad, on-chain reputation engine, (digital or in-person) events, marketing campaigns, promotions, sales, and any related service (collectively, the “Services”).
By engaging with any of the Services you agree that your Personal Data (defined below) will be handled as described in this Policy (including any applicable changes).
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY THEN PLEASE DO NOT USE ANY OF THE SERVICES.
Scope of this Policy
This Policy, as well as the Terms of Use, and Cookie Policy, applies to everyone that accesses and uses the Services. Where Legion engages with an unaffiliated third-party to perform services on behalf of Legion in relation to the Services, Legion will ensure the third-party has suitable internal controls to meet this Policy.
Definitions
Term | Definition |
---|---|
“Data Processing” | Data Processing means performing any operation or set of operations on data, including: Obtaining, recording, or keeping data; Collecting, organizing, storing, altering, or adapting data; Retrieving, consulting, or using data; Disclosing the information or data by transmitting, disseminating, or otherwise making it available; or Aligning, combining, blocking, erasing, or destroying data. |
“Personal Data” or “Data” | Any information about an identifiable individual, as defined in the European Union General Data Protection Regulation (GDPR). Examples of Personal Data include, but are not limited to: Name, date of birth, and social security or other identity card number; Contact information such as mailing address, email address, and phone numbers; Social media profile username, and picture IP addresses; Cookies and any usage analytics; Wallet ID and associated metadata; or Transaction and usage data. |
“User” | An individual, business, or project who accesses and/or uses the Services. |
Purpose
It is Legion’s policy to comply with all privacy and data protection-related regulatory requirements applicable to Legion in connection with the Services. This Policy is intended to help Users understand:
- Data We May Collect About You
- Justifications for Engaging in Data Processing
- Who We May Share Your Data With
- How We Secure Data We Collect
- How to Access and Control Your Data
- What Choices Do I Have Regarding Use of My Personal Data for Marketing Purposes?
- How We May Transfer Data We Collect Internationally
- Your Rights if You Are a California Resident
- Rights Under General Data Protection Regulation
- Changes to this Policy
- Contact Us
The Data We May Collect About You — Where, When, & Why
We collect information about Users either directly through their access or use of the Services, or through a third-parties, as well as information gathered during your tenure with Legion.
Personal Data Collected Directly From You. You may browse certain areas of the website without registering with us or providing us Personal Data. We may collect emails or social media usernames via the Services to notify you about the existing Services, upcoming features and new releases or updates, as well as marketing and promotional campaigns. You may provide us with the following types of information- identity verification (such as email, phone number, social media handles, IP address, Wallet ID), feedback & correspondence (such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Services, receive customer support or otherwise correspond with us), usage of the Services, technical information (wallet address, API-key and network information regarding transactions, associated metadata), and marketing preferences.
Third-Party Links. Our Services may contain links to third-party websites and third-party vendors. Any access to and use of such linked websites, social media platforms, software code repositories, Dapps, and payment service providers (PSPs), is not governed by this Policy, but instead is governed by the privacy policies of those third-parties. We are not responsible for the information practices of such third-parties. The inclusion of a link on our websites, or in the Services, does not imply that we or our affiliates endorse the practices of the linked website, social media platform, Dapp, or PSPs.
Please note, if you are providing Personal Data to third-parties in connection with using our Services, you are responsible for ensuring that you have all required permissions and consents to provide such Personal Data for use in connection with the Services and that the use of such Personal Data to provide the Services does not violate any applicable law, rule, regulation, or order.
Personal Data Collected Automatically. We may automatically collect the following information about your use of our Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our websites or use our Services; and the referring URL, or the webpage that led you to our websites.
Third-Party Analytics
We use automated devices and applications, such as Google Analytics and other tracking technologies, to evaluate usage of our Services. We use these tools to help us improve our Services, performance, and user experiences. We do not share your personal information with these third-parties.
Blockchain Information. Due to the transparent nature of blockchain technology, any transactions or interactions you conduct through public blockchains may be publicly accessible. We do not control and are not responsible for any information recorded on the blockchain.
Justifications for Engaging in Data Processing
Some of the justifications for engaging in Data Processing include, but are not limited to:
- Consent is provided by the User;
- The performance of a contract to which the data subject is a party (e.g. employment contracts);
- Compliance with a legal obligation; or
- For the legitimate interests of the data controller, unless such interests are overridden by the interests or rights of the data subject.
How We Use the Data Collected
We use your Personal Data, for various reasons, including but not limited to:
- To enhance security and mitigate fraudulent activity.
- To communicate with you about your use of the Services, respond to inquiries, and other customer service purposes.
- To tailor the content and information that we may send or display to you, offer location customization, and personalized help and instructions, and otherwise personalize your experience while using the Services.
- To ensure our Services are working as intended, to better understand how users access and use our Services, both on an aggregated and individual basis, to make improvements to our Services, develop new features, tools, products, and offerings, and for other related research and analytical purposes.
- To offer promotions; for example, we may use your information, such as your email address, to send you news and newsletters, special offers, conduct contests and sweepstakes, or to otherwise contact you about products or information we think may interest you.
- To provide you with feedback on incidents (including, but not limited to, questions, bugs or complaints) you raise directly with us.
- To enforce any applicable Terms of Use, license, services agreement, comply with the law, legal process or legal obligations, exercise or defend legal claims, detect, prevent or address fraud, security or technical issues, or otherwise protect our property, legal rights, or that of others.
- To provide you with updates on changes (including bug fixes, new features and revised content) where you have already engaged with us by raising an incident.
- For job candidates, we seek specific consent on the application to assess candidate suitability for an open role, and to verify information provided during the recruitment process.
- To perform accounting and other record-keeping functions.
- To provide Legion personnel payroll, other administration services, and keep a record of employment.
- To record any training, professional development, and performance metrics.
Who We May Share Your Data With
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your Personal Data will be maintained by such affiliates and subsidiaries in accordance with this Policy and applicable data protection laws, regulations, and statutes.
- Services Providers. We may disclose the Personal Data we collect from you to third-party vendors and service providers who help provide the Services, as well as contractors or agents who perform functions on our behalf.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or are in negotiations for any of these types of transactions, we may transfer the Personal Data we have collected from you to the other company.
How We Secure Data We Collect
We have implemented commercially reasonable precautions to protect the Personal Data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Security measures will be reviewed from time to time, having regard to the technology available, the cost, and the risk of unauthorized access.
How to Access and Control Your Data
You may request access, a copy, modification or deletion of Personal Data that you have submitted to us by contacting us at [email protected]. We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain Personal Data to comply with legal obligations, accounting requirements, or for other business purposes. There is no charge for requesting this Data. You are only entitled to access Data about yourself and will not be provided with Data relating to other people or third-parties. Please note, we may request additional information to verify the identity of the requesting party before responding to a request. If Legion does not own or control the information you request, we will inform you.
What Choices Do I Have Regarding Use of My Personal Data for Marketing Purposes?
You may instruct us not to use your Data to contact you regarding services, promotions, surveys and special events that might appeal to your interests by contacting us using the information below. You can also opt out by following the instructions located at the bottom of any commercial emails messages you may receive.
Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you, such as service-related announcements (e.g., if our Services are temporarily suspended for maintenance).
How We May Transfer Information We Collect Internationally
Legion operates internationally, so it may be necessary in the course of business to transfer a person’s Personal Data within the organization. The transfer of such Data is necessary for the management and administration of your Data within the group. When this is necessary, the organization will take steps to ensure that the Data has the same level of protection at all times. For more information, please contact us at [email protected].
Your Rights if You Are a California Resident
If you are a California resident, you have certain rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”). This section applies to you.
We are required to inform you of: (i) what categories of information we collect about you, including during the preceding 12 months, (ii) the purposes for which we use your personal data, including during the preceding 12 months, and (iii) the purposes for which we share your personal data, including during the preceding 12 months.
You have the right to: (i) request a copy of the personal information that we have about you; (ii) request that we delete your personal information; (iii) opt-out of the sale of your personal information; (iv) correct inaccuracies; and (v) restrict any sharing of your data with third-parties. These rights are subject to limitations as described in the CCPA and CPRA.
We will not discriminate against any consumer for exercising their CCPA and CPRA rights.
If you would like to exercise any of these rights, please contact us at [email protected].
Legion does not “sell” Personal Data, nor do we have actual knowledge of any “sale” of Personal Data of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in this Policy.
Rights Under General Data Protection Regulation (GDPR)
If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. Legion aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data that Legion holds about you and if you want it to be removed from our systems, please contact us at [email protected].
In certain circumstances, you have the following data protection rights:
- The right to access. You have the right to request information concerning the Personal Data we hold that relates to you.
- The right of rectification. You have the right to have your Data rectified if that Data is inaccurate or incomplete.
- The right to object. You have the right to object to your Personal Data being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
- The right of restriction. You have the right to request that Legion restrict the processing of your Data.
- The right to data portability. You have the right to be provided with a copy of the Personal Data collected and processed by Legion in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Legion relied on your consent to process your Personal Data.
Please note, Legion may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU or EEA.
Children’s Privacy
Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us via [email protected]. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
Changes to this Policy
We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above. Your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Contact Us
If you have questions about the privacy aspects of our website or Services or would like to make a complaint, please contact us at [email protected].