EFFECTIVE DATE: 19 March 2025
This Privacy Policy (this “Policy”) applies to the platform (including any applicable mobile applications and websites) (collectively the “Platform”) provided by Spell Labs LLC (the “Company,” “we,” “us” or “our”). It describes how the Company collects, uses, and discloses Personal Information that we obtain from Users of the Platform and any account services provided through the Platform, and how we use and disclose that information. For purposes of this Policy, “Personal Information” refers to information supplied by a User from which the identity of such User may be directly or indirectly determined.
We prioritize the security and privacy of your Personal Information. We are committed to ensuring that all Personal Information is processed in accordance with the highest standards of data protection and privacy regulations, and that technical and organizational measures are put in place. Our robust data management practices are designed to safeguard your information and maintain your trust.
It is important that you familiarize yourself with the provisions of this Policy together with Terms andConditions and any other privacy notices we may provide on specific occasions when we are collecting or processing Personal Information so that you are fully aware of how and why we are using your Personal Information.
By registering for and using the Platform, you agree that your Personal Information will be handled as described in this Policy and the Terms and Conditions applicable to the Platform (the “Agreement”); capitalized terms used herein shall have the same meaning as set forth in the Agreement.
We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our products and Platform when you participate in activities on the Platform, or otherwise when you contact us.
Personal Information Data. The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make, and the products and features you use. The personal information we collect may include the following:
While we minimize the collection of personal information, in order to satisfy your needs or requests for specific product functions, we may collect personal information including but not limited to your name and contact details such as telephone number or any additional Personal Information.
Communication Data. If you communicate with us, we collect your name, contact information and the contents of any messages you send, including without limitation, exchanges via our Telegram channel or other social media means.
User-Generated Data. When you use our Platform, we may collect personal information that is included in the input, file uploads or feedback that you provide to our Platform, as well as associated metadata, which encompasses information on how and where the content was created, formatted, or edited, and additional details like keywords. We collect data related to the blockchain addresses and transactions that you initiate or engage with through our Platform.
Other Data that are not specifically listed here, which we will process as described in this Privacy Policy or as otherwise disclosed at the time of collection.
We automatically collect certain information when you visit, use, or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Platform and other technical information. This information is primarily needed to maintain the security and operation of our Platform and for our internal analytics and reporting purposes.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Platform and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Platform (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Platform. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
We process your Personal Information using one of the following legal basis:
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information.
Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We use your information, including your Personal Information, for the following purposes:
To provide our Platform to you, to facilitate communications and transactions on the Platform, to communicate with you about your use of our Platform, to respond to your inquiries, to fulfill your orders, and for other customer service purposes;
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Platform;
To better understand how Users access and use the Platform, both on an aggregated and individualized basis, in order to improve our Platform and respond to user desires and preferences, and for other research and analytical purposes;
For marketing and promotional purposes. For example, we may use your information, such as your email address or contact number registered with us, to send you news and newsletters, special offers, and promotions, to conduct sweepstakes and contests, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Platform on third-party websites.
For safety and security. To protect the rights, property or safety of the Platform, our Users or others, as well as facilitate and ensure provision of services and products offered by the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
In addition, we, our affiliates, subsidiaries, or third-party service providers may transfer or disclose your Personal Information to:
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
With your consent.
We may also disclose your personal information:
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We will only keep your Personal Information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if such actions are not reasonably practicable (for example, because your personal information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
The Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.
Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Data. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other Personal Information we collect from you (and our third-party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process or to allow us to track your activities at our Platform. There are two types of cookies: session and persistent cookies.
Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Platform. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Platform.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Platform. We also may use other analytic means to evaluate our Platform. We use these tools to help us improve our Platform, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.
The following are the rights and choices available to all users:
Access: You may request to see the Personal Information we hold about you and understand how it’s being processed by logging in to your account settings and updating your user account or contacting us using the contact information provided.
Deletion: You have the right to ask us to erase your Personal Information from our records.
Rectification: If your Personal Information is inaccurate or incomplete, you can have it corrected or completed.
Restriction: You may limit the ways we use your Personal Information.
Withdrawal of Consent: You can retract any consent given for processing your Personal Information at any time.
Objection: You may challenge the processing of your Personal Information by us.
Termination Account: We will deactivate or delete your account and information from our active databases upon your request. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Complaints: You can file a complaint with your local data protection authority regarding our handling of your Personal Information.
For your specific rights under the applicable laws, please refer to “Lawful basis for processing Personal Information”.
Please note, we store your Personal Information on servers located in the country where our main offices is located. If such jurisdiction is outside your jurisdiction of residence, you consent to the transfer of your Personal Information to such jurisdiction for purposes of providing the Platform to you, even if such other jurisdiction has less protections for Personal Information than your jurisdiction of residence. We will ensure that security provisions are in place consistent with our obligations to maintain the security of your Personal Information under the laws of your jurisdiction of residence.
You should be aware that due to the inherent transparency of the blockchain networks, transactions that you approve when using the Platform may be publicly accessible. This includes, but is not limited to, your public key address, the public key address of the receiver, the amount of crypto sent or received, and any other data a User has chosen to include in a given transaction.
Transactions and addresses available on blockchain networks may reveal Personal Information about the User’s identity, and Personal Information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. We encourage you to review how privacy and transparency on blockchain networks works.
If you have questions about the privacy aspects of our Platform or would like to make a complaint, please contact us via our live chat services or at [email protected].
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Platform. If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Platform or providing a push notification through the Site (you should make sure your Site settings allow for such push notifications) or sending an email that you have provided in your Account, (for this reason you should make sure to update your account information promptly if it changes).