Introduction
Based on blockchain technology, Hord automatically redistributes the lion’s share of revenue to active users in proportion to their contribution. This requires recording and encrypting users’ activity to enable the smooth running of smart-contracts. Due to the immutable nature of information recorded on a blockchain, this information can never be deleted and its encrypted content is always publicly available.
The use of minimum personal data collected to enable hybrid Web2.0/Web3.0 functioning is delineated below.
We care about your privacy
Hord App, including its affiliates (Hord Website and Hord App, jointly referred to herewith as Hord Platform), is committed to respecting your privacy and to comply with applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we collect and use personal data where Hord Platform is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.
We will give you additional privacy information that is specific to a product or service in supplement to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first.
Our products or services may be embedded within, other companies’ websites and services that have privacy policies of their own. Where our products or services are embedded in third parties’ products and services, we require such third parties to provide the necessary transparency to you. This might include linking to this Policy or providing transparency in integrated and embedded notices which identify us as the service provider.
If you do not agree with this Policy, do not use our products and services or provide Hord Platform with your personal data.
Information we may collect from you
WE MAY COLLECT AND PROCESS THE FOLLOWING DATA ABOUT YOU AS A USER AS DEFINED IN THE TERMS OF SERVICE:
Information you provide us with
Upon sign-up
We collect your name and email, or any information authorized by you from third parties federated identity login used by you (i.e.: Signing in with Google, Facebook, Twitter, Civic, …)
Product and service activations
To use some Hord Platform products and services, you may be required to provide additional information such as:
Wallet Information
In order to provide the services, we will need to either provide you with a wallet address (also referred to as a “public address”) or store the public address(es) you provide. As you use the Services, we might collect information about your wallet including the types and amounts of currencies and details about transactions.
KYC/AML Information
Certain services require you to provide identification information prior to accessing those services. KYC/AML information are either stored by the external service provider selected by the Contractor, or by Hord Platform KYC/AML service, in which case the Contractor will have access to the information and documentation provided. This may include your government-issued identification documents (e.g., passport, driver’s license), Social Security number, and other similar documents and information.
For the purpose of verification of client identity, Hord will collect the copies of these documents that could also contain personal information (e.g., birthdate. Address, government-issued identifiers, etc.) Any external service provider will be bound to respect the terms of this Privacy policy and data protection guarantees as provided therein.
Additional information
- Page Name and associated information
- Hosted content and associated information, such as tags, categories, etc.
- URLs and associated information, such as tags, categories, etc.
Use of products and services
When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language, and other such information. See also our Cookie policy below.
Our applications may contact our servers periodically, for example, to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. See Supplements to this Policy for more details.
Your transactions with us
The holdings and transactions associated with a wallet address and the activity related to a portfolio are immutably recorded and publicly available on the blockchain. Therefore, information about your holdings and transactions and about your portfolio related activity will be accessible to third parties due to the nature of the blockchain.
Other content you have provided us with, your requests, agreements between you and Hord Platform, the products and services provided to you, payment and delivery details, your contacts and communications, and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.
Information provided by partners
We might obtain information from industry partners and a variety of other sources, including publicly available sources such as business registries. In such cases, we require these sources to comply with applicable laws with regard to collecting and transferring this data to us, including ensuring that there is a legal basis for the transfer or anonymizing the data in accordance with applicable laws prior to the disclosure of the data to us.
Why do we process Personal Data?
Hord Platform may process your personal data for the following purposes. One or more purposes may apply simultaneously.
Providing products and services
We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and Hord Platform, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
Accounts
Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as username and email address. You may also be able to voluntarily provide more information about yourself while creating a profile.
Developing and managing products and services
We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular Hord Platform product and/or service with other personal data we may have about you, unless such personal data was collected for a purpose, where the original purpose is incompatible with this purpose.
Communicating with you
We may use your personal data to communicate with you, for example, to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
You can opt out of selected or all emails from the settings section.
Marketing, advertising, and making recommendations
We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content in our services. This may include displaying Hord Platform and third-party content.
What is our legal basis for processing your Personal Data?
Our legal basis for processing your personal data is dependent on the purpose for processing under the following legal bases:
Performance of a contract with you
We process your personal data to perform our obligations under the Terms & Conditions applicable to the product or service you are using, provided by us or our customers. Our Service Terms are available at Terms and Conditions
Your consent
We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent.
Legal obligations
We process your personal data as needed to comply with laws and regulations.
Legitimate interests
We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event, will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided in relevant Supplements applicable to the product or service.
How long do we retain Personal Data?
We endeavor to only collect personal data that are necessary for the purposes for which they are collected and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, for your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized or pseudonymized. Additional information may be provided in the Supplement applicable to the product or service you are using. You may contact the Hord Platform Privacy Office at hello@Hord.app to obtain additional information about retention of your personal data.
Do we share Personal Data?
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated in this Policy.
Your consent and social sharing services
We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.
Hord Platform companies and authorized third parties
We may share your personal data with other Hord Platform companies or authorized third parties who process personal data for Hord Platform for the purposes described in this Policy. This may include providing services including customer service, managing and analyzing consumer data, credit checks, conducting research, and managing marketing and other such campaigns.
We may conduct joint marketing and other communications with our partners, for example by including a specific portfolio created by third parties in communication with you. These third parties are not permitted to use your personal data for any purpose.
Mandatory disclosures
We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend Hord Platform’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.
Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
How do we address the privacy of children?
Hord Platform products and services are limited to users over the age of 18. Hord Platform does not knowingly collect information of children.
How do we address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.
We encourage you to access your personal data through your account from time to time to ensure that it is up to date.
What steps are taken to safeguard Personal Data?
Privacy and security are key considerations in the creation and delivery of our products and services. We take appropriate steps to address online security, physical security, risk of data loss, and other such risks, including advanced encryption of personal data, taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.
Where we have given you or where you have chosen a password that enables you to access your account, you are responsible for keeping this password confidential.
Your passwords are stored on our servers in encrypted form using a one-way hashing algorithm.
Please be reminded that you must protect any passwords or other credentials associated with your account for the Services and take full responsibility for any use of the account under your password.
How do we use Cookies and Web Beacons?
Hord Platform uses cookies, web beacons and other similar technologies to operate and improve our websites and offerings. We also use cookies for personalization and optimizing the use of services and products. Our domains may include third-party elements that set cookies on behalf of a third party, for example relating to third-party social networks. Please visit our Cookie policy below to find out more about how Hord Platform uses cookies and how you can disable cookies by browser settings or otherwise.
What are your rights?
You have a right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary, or outdated personal data updated.
You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format.
You have the right to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful.
You have the right to delete your Hord account and all personal data it contains. It is incumbent to you to ensure continued access to your wallet by saving your mnemonics to access your wallet from another source. Due to the nature of blockchain, disabling your account will delete all your personal information stored on Hord servers according to Hord's Terms & Conditions, but will not delete any information stored on any blockchain and public ledgers.
Any rights and obligations in the smart contracts assigned to your account or your cryptographic address and registered on the Blockchain are irrevocable and cannot be deleted.
You have the right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out of marketing and other communications from Hord Platform, critical alerts may still be sent to you. If you are located in a European Union member state or within the European Economic Area, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.
You may exercise your rights by contacting us at hello@Hord.app or by managing your account and choices through available profile management tools on your device and our services. In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the services to you. Applicable data protection law may provide certain restrictions on the extent to which these rights may be exercised. If a restriction applies, we will respond to your request with an explanation of what action will be taken, to the extent required under applicable data protection law.
Hord Cookie Policy
Where does it come from?
The cookies on the Site may be from any of the following categories:
1. Strictly Necessary cookies - These are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, sections of the Site may not operate effectively.
2. Functionality cookies - these are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat user of the Site and help us remember your preferences (for example, your choice of language or region).
3. Analytical - these record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.
Cookies and how we use them
This policy details how Hord uses cookies, cookie-like files, and other technologies that may enable tracking of user activities on its websites, e.g. Local Shared Objects, also known as “Flash cookies”, web beacons, etc. We refer to these generically as “cookies”.
What are cookies and how do they work?
Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Next time you visit the site, your browser will read the cookie and relay the information back to the website or element that originally set the cookie. First-party cookies are set by the website you are visiting directly. They allow website owners to collect analytics data, remember language settings, and perform other useful functions that help provide a good user experience. Third-party cookies are cookies used within our services that are set by other organizations. To learn more about these technologies and how they work, please see e.g. allaboutcookies.org.
On their own, cookies do not personally identify you. Unless you choose to identify yourself to Hord, such as by creating an account or providing your name or email address on a web form, Hord will not attempt to link this data to you personally.
Why does Hord use cookies?
At Hord domains, we use cookies to offer you a smoother experience, and for the purposes shown below.
These cookies are essential for running our websites and are key to providing you a seamless experience.
You can navigate uninterrupted e.g. by remembering language and country choices you’ve made and by preserving authentication to secure parts of the domain. These cookies also remember products of interest when you are redirected to a payment site for a possible purchase.
Providing a better website experience
These cookies enable us to improve our websites and business processes by looking at how our websites are used.
For example, if you have shown particular interest in a certain topic, we might redirect you by default to the Explore section related to that topic when you access the Explore page, or, it enables us to privilege content in your preferred languages.
Delivering more of the content you like
These cookies help make the content you view and receive as personalized as possible, for example by showing you relevant recommendations.
We examine what type of reference was used to reach our sites, e.g. an email campaign or a link from a referral site, so we can estimate the effectiveness of our promotions and advertising campaigns.
Our domains may also include elements that set cookies on behalf of a third party, e.g. a “Like”-button from Facebook or a “Tweet”-button from Twitter. We may also use pixel tracking to provide a reference ID from your visit back to the site from where you were referred. By consenting to the use of these cookies, you also consent to process by these third parties for the purposes listed in this Policy.
What is our legal basis for processing your Personal Data?
Cookies and pixel tracking are set in our sites and offerings based on your consent.
How can I manage cookies?
There are several methods available to permit you to manage cookies. You can review the options available to manage cookies in your browser. The browser can be used to manage cookies relating to basic functions, providing a better website experience, delivering more of the content you like, and promoting relevant offers. Different browsers use different settings that allow you to choose whether browser cookies are set and to delete them. These controls vary by browser, and manufacturers may change both the settings they make available and how they work at any time. As of 5 October 2020, you may find additional information about the controls offered by popular browsers at the links below. Certain parts of the Hord Products may not work properly if you have disabled browser cookie use. Please be aware these controls are distinct from the controls that Hord offers you.
How long do we keep the information?
It depends based on the type of cookies. Session cookies expire when you close the browser. Persistent cookies, including Local Shared Objects (“Flash cookies”), have typical expiration dates ranging from two months up to a couple of years. Where you have chosen to be identified, data collected from cookies may be retained as part of your interest profile. Any retained data will be subject to the Hord Privacy Policy.
Who is the controller of your Personal Data?
Hord, a BVI Company is the controller of your personal data.
In addition, the Hord Platform affiliate providing the product or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a product or service or by using contact information provided in the applicable Hord Platform websites.
In matters pertaining to Hord Platform’s privacy practices you may contact our Data Protection Officer, Eitan Lavi, at:
Hord
BVI
Email: privacy@Hord.app
What else should you know?
Hord may from time to time change this Policy. However, if this Policy is changed in a material, adverse way, Hord will post a notice advising of such change at the beginning of this Policy and on this site's home page. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.
If you have additional questions, please contact us or our Data Protection Officer, Eitan Lavi, by writing to:
Hord App
BVI
Email: hello@Hord.app
Changes to this Privacy Policy
Hord Platform may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice.
Thank You.