Privacy Notice

Last Updated March 8, 2024

This Privacy Notice is designed to help you understand how Family Labs Ltd. (“Company,” “we,” “us,” or “our”) collects, uses, and shares your personal information, and to help you understand and exercise your privacy rights.

1. Scope and updates to this privacy notice.

This Privacy Notice applies when we process your personal information and is subject to change from time to time.

This Privacy Notice applies to personal information processed by us, including on our websites, our Family Wallet mobile application, and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications and other offerings are collectively called the “Services.”

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. Personal information we collect.

This Privacy Notice applies to information you provide directly to us, information collected automatically from you, and information collected from other third-party sources.

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.

  1. Personal Information You Provide to Us Directly

    We may collect personal information that you provide to us.

    • Family Wallet Mobile Application. Our Services may also you to create a digital wallet (the “Family Wallet”). The Family Wallet may enable you to interact with decentralized blockchains (each, a “Blockchain”) associated with digital assets that the Services may, in our sole discretion, elect to support ( the “Supported Digital Assets”). You may choose to interact with third party services and supported protocols in connection with the sale, purchase, trade and distribution of your Supported Digital Assets. Through such interactions, you may be able to: (A) store Supported Digital Asset account(s) in the Family Wallet to facilitate transactions; and (B) monitor, maintain, and transact with the associated Supported Digital Assets. We and our service providers will receive your wallet address when you connect your wallet to our Services or send a transaction via Blockchain.

    • Your Communications with Us. We may collect personal information, such as name, email address, when you request information about the Company or our Services, register for our newsletter, request support, 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 information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

  2. Personal Information Collected Automatically

    We may collect personal information automatically when you use our Services.

    • Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as 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), and Internet service provider. 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, items that you search for via the 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.

    • Cookie Policy (and Other Technologies). We, as well as third parties that provide content or other functionality on our Services, may use cookies, pixel tags, 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;

      See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

    • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.

  3. Personal Information Collected from Other Sources

    Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. 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. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. How we use your personal information.

We may use your personal information to (1) provide the Services; (2) for administrative purposes such as improving the Services; (3) for marketing purposes; (4) with your consent; and (5) for other permissible purposes as requested by you or as allowed under applicable law.

We use your personal 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.

  1. Provide Our Services

    We use your personal information to fulfill 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;
    • Sending you push notifications;
    • Answering requests for customer or technical support;
    • Communicating with you about your account, activities on our Services, and policy changes;
    • Processing applications if you apply for a job we post on our Services; and

  2. Administrative Purposes

    We use your personal 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;
    • Developing new products and services;
    • Ensuring internal quality control and safety;
    • To facilitate the connection of third-party services or applications;
    • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
    • Debugging to identify and repair errors with our Services;
    • Auditing relating to interactions, transactions, and other compliance activities;
    • Sharing personal information with third parties as needed to provide the Services;
    • Enforcing our agreements and policies; and
    • Carrying out activities that are required to comply with our legal obligations.

  3. With Your 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.

  4. Other Purposes

    We also use your personal information for other purposes as requested by you or as permitted by applicable law.

    • De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Services, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

    • Information Made Available on the Blockchain Network. Notwithstanding anything to the contrary in this Privacy Notice, information you make available on the blockchain network via the Family Wallet mobile application, such as your user information and related electronic wallet address may be shared with third parties, made publicly visible and/or appear as part of or any other applicable Blockchain network, including when you conduct any sales, purchases, or other related activities through the Services. In these situations, the personal information you share may not be able to be modified or deleted due to the immutable nature of the Blockchain. The foregoing disclosure may be made for purposes related to facilitating those activities or transactions on the Blockchain, including without limitation making payments to the Company.

4. How we disclose your personal information.

We may share your personal information with third parties (1) to provide the Services; (2) to protect us or others; and (3) in connection with corporate transactions, such as a merger.

We disclose your personal 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.

  1. Disclosures to Provide our Services

    The categories of third parties with whom we may share your personal information are described below.

    • Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

    • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

    • Affiliates. We may share your personal information with our corporate affiliates.

    • 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.

  2. 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.

  3. 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.

5. Your privacy choices and rights.

You may be able to manage your preferences and communications from us and other option features offered via our Services. In addition, some privacy laws grant individuals certain rights regarding their personal information.

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 transaction-related emails regarding products or 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 or this Privacy Notice).

  • “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.

  • Cookie Choices. 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.

    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 to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
  • Request Correction of your personal information where it is inaccurate or incomplete;
  • 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. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

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.

6. International transfers of personal information.

We may transfer personal information internationally.

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. Children's information.

Our Services are not directed at children.

You must be 18 years or older to use the Services. The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

8. Retention.

We may retain your personal information for so long as necessary to fulfill the purposes for which it was collected.

We take measures to delete your personal information or keep it in a form that does not permit identifying you when this personal information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this personal information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of Service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

9. Supplemental notice for Nevada residents.

We do not “sell” your personal information as that term is used under Nevada law.

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. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.

10. Supplemental notice for European users.

If you are a resident in the European Economic Area or the United Kingdom, you are entitled to additional information and may have additional rights with respect to your personal information.

This section applies to users located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”). Our Legal Bases for Processing Personal Information. If you are located in the EEA or the U.K., we only process your personal information when we have a valid “legal basis.” The legal bases we may rely on to process your information include:

  • Consent. You have consented to the use of your personal information, for example to use cookies.
  • Contractual Necessity. We need your information to provide you with the Site, for example to respond to your inquiries.
  • Compliance with a Legal Obligation. We have a legal obligation to use your personal information, for example to comply with tax and accounting obligations.
  • Legitimate Interests. We or a third party have a legitimate interest in using your personal information. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Site. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of the EEA, Switzerland, or the U.K., you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

11. Other provisions.

We are not responsible for third-party links and services.

Third-Party 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, including the services provided by financial institutions and cryptocurrency exchanges, 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.

12. Contact us.

If you have any questions, you may contact us.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at [email protected]