Privacy Policy
1. SCOPE
This Privacy Policy applies to personal information processed by
Growth Lab’s website and interface located at
https://nftmakerapp.io/ (the “
Site”), corresponding mobile applications (“
App”) (together, the “
Near Labs Platform”) offered by Growth Lab, which
effectuates the creation and deployment (aka “minting”) of
non-fungible tokens (“NFTs”) and supports transfer of
such NFTs between users on the Near blockchain on which such NFTs are
recorded (“Near Blockchain”) To make this Privacy
Policy easier to read, the Near Labs Platform and our services are
collectively called the “Services.” For clarity, the
Services do not include the Near smart contract, the Near Blockchain
or protocol or any other blockchain-based network with which the Site
and Service may interact.
This Privacy Policy does not apply to any of the data processed via
the Near websites available at https://near.org and
https://near.foundation and corresponding mobile applications
which are governed by the NEAR Privacy Policy available here.
2. CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time in our sole
discretion. If there are any material changes to this Privacy Policy,
we will notify you as required by applicable law. You understand and
agree that you will be deemed to have accepted the updated Privacy
Policy if you continue to use our Services after the new Privacy
Policy takes effect.
3. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you
interact with us, our Services and the requirements of applicable law.
We collect information that you provide to us, information we obtain
automatically when you use our Services, and information from other
sources such as third-party services and organizations, as described
below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide
to us.
-
Account Creation. We may collect information when
you create a Near Labs Platform account, such as name, username,
email address, password, and a photograph if you choose to upload
one as your profile picture.
-
Wallet. Your account will serve as your digital
wallet, which will hold your NFTs. Please note that we will not
host or take possession of your private key.
-
Near Blockchain and Transfer-related Information.
In order to engage in NFT transfers on the Services, you will need
to provide us with access to or information about your digital
wallet and transfers on the Near Labs Platform. As you use the
Services, we may collect personal information and details
associated with the transfers you are involved with, such as the
NFTs you elect to mint, the NFTs you are transferring to or
receiving from other users, the names and/or email addresses of
other Near Labs Platform users from whom you receive or to whom
you send NFTs, ; information about your preferences and your
experience with sending NFTs and your crypto wallet public
address; We may collect your payment information if transfer fees
or Gas fees are imposed by the Near Blockchain.
-
Picture. We will collect the picture file that
you upload to the Near Labs Platform in order to mint your NFTs.
-
Your Communications with Us. We may collect
personal information, such as email address, phone number, or
mailing address when you request information about our Services,
register for our newsletter or marketing, request customer or
technical support, apply for a job or otherwise communicate with
us.
-
Interactive Features. We and others who use our
Services may collect personal information that you submit or make
available through our interactive features (e.g., commenting
functionalities, forums, blogs, and social media pages). Any
personal information you provide on the public sections of these
features will be considered “public,” unless otherwise required by
applicable law, and is not subject to the privacy protections
referenced herein.
-
Surveys. We may contact you to participate in
surveys. If you decide to participate, you may be asked to provide
certain information which may include personal information.
-
Sweepstakes or Contests. We may collect personal
information you provide for any sweepstakes or contests that we
offer. In some jurisdictions, we are required to publicly share
information of sweepstakes and contest winners.
-
Conferences, Trade Shows, and Other Events. We
may collect personal information from individuals when we attend
or host conferences, trade shows, and other events.
-
Business Development and Strategic Partnerships.
We may collect personal information from individuals and third
parties to assess and pursue potential business opportunities.
-
Job Applications. We may post job openings and
opportunities on our Services. If you reply to one of these
postings by submitting your application, CV and/or cover letter to
us, we will collect and use this information to assess your
qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our
Services:
-
Automatic Data Collection. We may collect certain
information automatically when you use our Services, such as
server logs, your Internet protocol (IP) address, user settings,
MAC address, cookie identifiers, mobile carrier, mobile
advertising and other unique identifiers, browser or device
information, location information (including approximate location
derived from IP address), Internet service provider, and metadata
about the content you provide. We may also automatically collect
information regarding your use of our Services, such as pages that
you visit before, during and after using our Services, information
about the links you click, the types of content you interact with,
the frequency and duration of your activities, and other
information about how you use our Services.
-
Cookies, Pixel Tags/Web Beacons, and Other Technologies.
We, as well as third parties that provide content, advertising, or
other functionality on our Services, may use cookies, pixel tags,
local storage, and other technologies (“
Technologies”) to automatically collect
information through your use of our Services.
-
Cookies. Cookies are small text files placed
in device browsers that store preferences and facilitate and
enhance your experience.
-
Pixel Tags/Web Beacons. A pixel tag (also
known as a web beacon) is a piece of code embedded in our
Services that collects information about engagement on our
Services. The use of a pixel tag allows us to record, for
example, that a user has visited a particular web page or
clicked on a particular advertisement. We may also include web
beacons in e-mails to understand whether messages have been
opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general
categories:
-
Operationally Necessary. This includes
Technologies that allow you access to our Services, applications,
and tools that are required to identify irregular website
behavior, prevent fraudulent activity, improve security, or allow
you to make use of our functionality;
-
Performance-Related. We may use Technologies to
assess the performance of our Services, including as part of our
analytic practices to help us understand how individuals use our
Services (see Analytics below);
-
Functionality-Related. We may use Technologies
that allow us to offer you enhanced functionality when accessing
or using our Services. This may include identifying you when you
sign into our Services or keeping track of your specified
preferences, interests, or past items viewed;
-
Advertising- or Targeting-Related. We may use
first party or third-party Technologies to deliver content,
including ads relevant to your interests, on our Services or on
third-party websites.
See “Your Privacy Choices and Rights” below to understand your
choices regarding these Technologies.
-
Analytics. We may use our Technologies and other
third-party tools to process analytics information on our
Services. Some of our analytics partners include:
-
Google Analytics. We use analytics services
provided by Google Inc. This allows us to process usage data to
better understand how our website and web-related Services are
used. This enables us to continually improve our website, making
it relevant to your interests and needs. This may involve personal
data, such as cookie and other device identifiers. The data
collected by Google Analytics is usually transferred to a Google
server in the USA and processed there. In addition, Google uses
your data for its own purposes, e.g., for profiling or linking it
to other data. For more information, please visit
Google Analytics’ Privacy Policy.
To learn more about how to opt-out of Google Analytics’ use of
your information, please click
here.
-
Mixpanel. For more information about Mixpanel,
please visit
Mixpanel’s Privacy Policy.
-
HotJar. For more information, please visit
HotJar’s Data Policy.
-
Segment. For more information, please visit
Segment’s Privacy Policy.
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Amplitude. For more information, please visit
Amplitude’s Privacy Policy.
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HubSpot Analytics (HubSpot, Inc.). For more
information, please visit
HubSpot’s Privacy Policy.
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Social Media Platforms. Our Services may contain
social media buttons, such as Discord, WeChat, Twitter, YouTube,
which might include widgets such as the “share this” button or
other interactive mini programs). These features may collect your
IP address and which page you are visiting on our Services and may
set a cookie to enable the feature to function properly. Your
interactions with these platforms are governed by the privacy
policy of the company providing it.
C. Information Collected from Other Sources
Third-Party Sources.We may obtain information about
you from other sources, including through third-party services and
organizations. For example, if you access our Services through a
third-party application, such as an app store, a third-party login
service, or a social networking site, we may collect information
about you from that third-party application that you have made
available via your privacy settings.
4. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including
to provide our Services, for administrative purposes, and to market
our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide
you with our Services, such as:
- Managing your information and accounts;
-
Providing access to certain areas, functionalities, and features
of our Services;
- Answering requests for customer or technical support;
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Communicating with you about your account, activities on our
Services, and policy changes;
-
Processing your wallet information to facilitate transfers via the
Services;
-
Processing applications if you apply for a job, we post on our
Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such
as:
-
Pursuing our legitimate interests such as direct marketing,
research and development (including marketing research), network
and information security, and fraud prevention;
-
Detecting security incidents, protecting against malicious,
deceptive, fraudulent or illegal activity, and prosecuting those
responsible for that activity;
- Measuring interest and engagement in our Services;
- Improving, upgrading or enhancing our Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with our Services;
-
Auditing relating to interactions, transfers and other compliance
activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C.
Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with
content and advertisements. We may provide you with these materials
as permitted by applicable law.
Some of the ways we may market to you include email campaigns,
custom audiences advertising, and “interest-based” or “personalized
advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you
would like to opt out of the use of your personal information for
marketing purposes, you may contact us at any time as set forth
below
D. Other Purposes
We also use your information for other purposes as requested by you
or as permitted by applicable law.
-
Consent. We may use personal information for
other purposes that are clearly disclosed to you at the time you
provide personal information or with your consent.
-
De-identified and Aggregated Information. We may
use personal information and other information about you to create
de-identified and/or aggregated information, such as de-identified
demographic information, de-identified location information,
information about the device from which you access our Services,
or other analyses we create.
-
Referral and Sharing Features.Our Services may
allow you to share your NFTs with your friends, contacts or
colleagues who are also users of the Near Labs Platform. Our
referral services may also allow you to forward or share certain
content with a friend or colleague, such as an email inviting your
friend to use our Services.
5. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of
business purposes, including to provide our Services, to protect us or
others, or in the event of a major business transaction such as a
merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your
information are described below.
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Notice Regarding Use of Near Blockchain. If you
elect to transfer any NFTs, any transfer transactions that you
engage in will be conducted solely through the Near Blockchain
network. Information about your transfers will be provided to the
Near Blockchain and may be accessible to third parties due to the
nature of the Near Blockchain.
-
Other Users of the Services and Parties You Transact With
Some of your personal information may be visible to other users of
the Services (e.g., profile picture, information featured on
generally accessible parts of your profile; username of other Near
Labs Platform members who sent you NFTs or received NFTs from
you). In addition, to complete transfers via the Services, we will
need to share some of your personal information with the party
that you are transacting with.
-
Third Party Websites and Applications. You may
choose to share personal information or interact with third-party
websites and/or third-party applications, including, but not
limited to, third-party electronic wallet extensions. Once your
personal information has been shared with a third-party website or
a third-party application, it will also be subject to such third
party’s privacy policy. We encourage you to closely read each
third-party website or third-party application privacy policy
before sharing your personal information or otherwise interacting
with them. Please note that we do not control, and we are not
responsible for the third-party website’s or the third-party
application’s processing of your personal information.
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Service Providers. We may share your personal
information with our third-party service providers who use that
information to help us provide our Services. This includes service
providers that provide us with IT support, hosting, customer
service, and related services.
-
Affiliates. We may share your personal
information with members of our corporate family.
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Advertising Partners. We may share your personal
information with third-party advertising partners. These
third-party advertising partners may set Technologies and other
tracking tools on our Services to collect information regarding
your activities and your device (e.g., your IP address, cookie
identifiers, page(s) visited, location, time of day). These
advertising partners may use this information (and similar
information collected from other services) for purposes of
delivering personalized advertisements to you when you visit
digital properties within their networks. This practice is
commonly referred to as “interest-based advertising” or
“personalized advertising.”
-
APIs/SDKs. We may use third-party application
program interfaces (“APIs”) and software
development kits (“SDKs”) as part of the
functionality of our Services. For more information about our use
of APIs and SDKs, please contact us as set forth in “Contact Us”
below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store
associated with you to external parties if we, in good faith,
believe doing so is required or appropriate to: comply with law
enforcement or national security requests and legal process, such as
a court order or subpoena; protect your, our, or others’ rights,
property, or safety; enforce our policies or contracts; collect
amounts owed to us; or assist with an investigation or prosecution
of suspected or actual illegal activity.
C.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due
diligence, reorganization, bankruptcy, receivership, purchase or
sale of assets, or transition of service to another provider, your
information may be sold or transferred as part of such a
transaction, as permitted by law and/or contract.
6. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may
have about your personal information are determined by applicable law
and are described below.
-
Email Communications. If you receive an unwanted
email from us, you can use the unsubscribe link found at the bottom
of the email to opt out of receiving future emails. Note that you
will continue to receive transfer-related emails regarding Services
you have requested. We may also send you certain non-promotional
communications regarding us and our Services, and you will not be
able to opt out of those communications (e.g., communications
regarding our Services or updates to our Terms of Service or this
Privacy Policy).
-
Text Messages. You may opt out of receiving text
messages from us by following the instructions in the text message
you have received from us or by otherwise contacting us.
-
Mobile Devices. We may send you push notifications
through our mobile application. You may opt out from receiving these
push notifications by changing the settings on your mobile device.
With your consent, we may also collect precise location-based
information via our mobile application. You may opt out of this
collection by changing the settings on your mobile device.
-
“Do Not Track.” Do Not Track (“DNT
”) is a privacy preference that users can set in certain web
browsers. Please note that we do not respond to or honor DNT signals
or similar mechanisms transmitted by web browsers.
-
Cookies and Interest-Based Advertising. You may
stop or restrict the placement of Technologies on your device or
remove them by adjusting your preferences as your browser or device
permits. However, if you adjust your preferences, our Services may
not work properly. Please note that cookie-based opt-outs are not
effective on mobile applications. However, you may opt-out of
personalized advertisements on some mobile applications by following
the instructions for
Android,
iOS and
others
.
The online advertising industry also provides websites from which
you may opt out of receiving targeted ads from data partners and
other advertising partners that participate in self-regulatory
programs. You can access these and learn more about targeted
advertising and consumer choice and privacy by visiting the
Network Advertising Initiative
,
the Digital Advertising Alliance
,
the European Digital Advertising Alliance
, and
the Digital Advertising Alliance of Canada
.
Please note you must separately opt out in each browser and
on each device.
Your Privacy Rights.In accordance with applicable
law, you may have the right to:
-
Access Personal Information about you, including:
(i) confirming whether we are processing your personal information;
(ii) obtaining access to or a copy of your personal information; or
(iii) receiving an electronic copy of personal information that you
have provided to us, or asking us to send that information to
another company (aka the right of data portability);
-
Request Correction of your personal information
where it is inaccurate or incomplete. In some cases, we may provide
self-service tools that enable you to update your personal
information;
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Request Deletion of your personal information;
-
Request Restriction of or Object to our processing
of your personal information; and
-
Withdraw Your Consent to our processing of your
personal information.
If you would like to exercise any of these rights, please contact us
as set forth in “Contact Us” below. We will process such requests in
accordance with applicable laws
7. SECURITY OF YOUR INFORMATION
We take steps designed to ensure that your information is treated
securely and in accordance with this Privacy Policy. Unfortunately, no
system is 100% secure, and we cannot ensure or warrant the security of
any information you provide to us. To the fullest extent permitted by
applicable law, we do not accept liability for unauthorized
disclosure.
By using our Services or providing personal information to us, you
agree that we may communicate with you electronically regarding
security, privacy, and administrative issues relating to your use of
our Services. If we learn of a security system’s breach, we may
attempt to notify you electronically by posting a notice on our
Services, by mail or by sending an email to you.
8. INTERNATIONAL DATA TRANSFERS
We store the personal information we collect as described in this
Privacy Policy for as long as you use our Services or as necessary to
fulfill the purpose(s) for which it was collected, provide our
Services, resolve disputes, establish legal defenses, conduct audits,
pursue legitimate business purposes, enforce our agreements, and
comply with applicable laws.
9. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this
Privacy Policy for as long as you use our Services or as necessary to
fulfill the purpose(s) for which it was collected, provide our
Services, resolve disputes, establish legal defenses, conduct audits,
pursue legitimate business purposes, enforce our agreements, and
comply with applicable laws.
10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our
processing of personal information that is subject to the California
Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California
residents with the right to know what categories of personal
information Growth Lab has collected about them and whether Growth Lab
disclosed that personal information for a business purpose (e.g., to a
service provider) in the preceding twelve months. California residents
can find this information below:
Identifiers
A real name, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address,
account name, or other similar identifiers.
- Service providers
- Third-party websites or applications
- Blockchain networks
- Other users or third parties you interact with
- Advertising partners
Personal information categories listed in Cal. Civ. Code §
1798.80(e)
A name, signature, Social Security number, address,
telephone number, passport number, driver's license or state
identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card
number, debit card number, or any other financial information.
Personal Information does not include publicly available
information that is lawfully made available to the general public
from federal, state, or local government records. Note: Some
personal information included in this category may overlap with
other categories
- Service providers
-
Third-party websites or applications (e.g., wallet providers;
third-party identity verification services)
- Blockchain networks
- Other users or third parties you interact with
Commercial information
Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming
histories or tendencies.
- Service providers
- Blockchain networks
- Other users or third parties you interact with
Sensory data
Audio, electronic, visual, or similar information.
-
Service providers that support the social network platform.
- Data analytics providers
- Other users (your posts).
Internet or other electronic network activity
Browsing history, search history, information on a consumer's
interaction with an internet website, application, or
advertisement.
- Service providers
- Blockchain networks
- Other users or third parties you interact with
- Advertising partners
Inferences drawn from other personal information to create a
profile about a consumer
Profile reflecting a consumer's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
- Service providers
- Advertising partners
The categories of sources from which we collect personal information
and our business and commercial purposes for using personal
information are set forth in “Personal Information we Collect” and
“How We Use of Your Information” above, respectively.
“Sales” of Personal Information under the CCPA. For
purposes of the CCPA, Growth Lab does not “sell” personal
information, nor do we have actual knowledge of any “sale” of
personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the
right not to receive discriminatory treatment by us for the exercise
of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally
authorized to act on your behalf, may make a verifiable consumer
request related to your personal information. To designate an
authorized agent, please contact us as set forth in “Contact Us”
below.
Verification. When you make a request, we will ask
you to provide sufficient information that allows us to reasonably
verify you are the person about whom we collected personal information
or an authorized representative, which may include confirming the
email address associated with any personal information we have about
you. If you are a California resident and would like to exercise any
of your rights under the CCPA, please contact us as set forth in
“Contact Us” below. We will process such requests in accordance with
applicable laws.
Accessibility. This Privacy Policy uses
industry-standard technologies and was developed in line with the
World Wide Web Consortium’s Web Content Accessibility Guidelines,
version 2.1. If you wish to print this policy, please do so from your
web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the
Light” law permits users who are California residents to request and
obtain from us once a year, free of charge, a list of the third
parties to whom we have disclosed their personal information (if any)
for their direct marketing purposes in the prior calendar year, as
well as the type of personal information disclosed to those parties.
Right for minors to remove posted content.Where
required by law, California residents under the age of 18 may request
to have their posted content or information removed from the publicly
viewable portions of the Services by contacting us directly as set
forth in “Contact Us” below.
11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the
sale of certain personal information to third parties who intend to
license or sell that personal information. You can exercise this right
by contacting us as set forth in “Contact Us” below with the subject
line “Nevada Do Not Sell Request” and providing us with your name and
the email address associated with your account. Please note that we do
not currently sell your personal information as sales are defined in
Nevada Revised Statutes Chapter 603A.
12. CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as
required by local law), and we do not knowingly collect personal
information from children. If you learn that your child has provided
us with personal information without your consent, you may contact us
as set forth in “Contact Us” below. If we learn that we have collected
a child’s personal information in violation of applicable law, we will
promptly take steps to delete such information.
13. THIRD-PARTY’S WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and
other websites/applications may reference or link to our Services.
These third-party services are not controlled by us. We encourage our
users to read the privacy policies of each website and application
with which they interact. We do not endorse, screen or approve, and
are not responsible for, the privacy practices or content of such
other websites or applications. Providing personal information to
third-party websites or applications is at your own risk.
14. SUPERVISORY AUTHORITY
If you are located in the European Economic Area, Switzerland, or the
United Kingdom you have the right to lodge a complaint with a
supervisory authority if you believe our processing of your personal
information violates applicable law.
15. CONTACT US
If you have any questions about our privacy practices or this Privacy
Policy, or to exercise your rights as detailed in this Privacy Policy,
please contact us at:
Growth Lab, Inc.
Address: 1209 Orange Street, Wilmington Deleware
Email: info@primelab.io
Telephone: 9842303429