Respecting and protecting investor privacy has always been vital to our business. This Privacy Policy describes how Daphne Technologies LLC (together with its subsidiaries and affiliates “Daphne”, “us”, “we” or “our”) gathers and uses personal information about you when you communicate with us, when you visit Daphne's websites that link to this Privacy Policy (including www.daphnetech.io and any sites that are automatically redirected to them, collectively, the “Sites”); how we protect and share this information; and the rights you may have in relation to this information. If you have any questions or concerns about this Privacy Policy, or if you object to our uses of your personal information, please contact our Privacy Office at privacy@getdaphne.com.
When you visit and browse the Sites, you may provide us with information, and we will collect certain information automatically.
We use cookies and web beacons for a variety of purposes relating to our operation of, and your use of, the Sites. For instance, when you return to our Sites after logging in, cookies provide information to the Sites so that the Sites will remember you and your preferences. We use web beacons and other technologies to analyze the traffic patterns on the Sites, such as the frequency with which our users visit various parts of the Sites.
We use different types of cookies to deliver different services and features. These types include:1
Cookies are stored on your device based on the cookie type.
You may be able to have your browser warn you when a cookie is sent, and you may be able to turn off all cookies or otherwise modify how and when they are used. You can do this through your web browser settings. Each browser is different, but you can generally visit the Help menu in your browser to learn how to modify your cookie settings. If you turn cookies off, you may not have access to certain features that may improve your browsing, like the features mentioned above, and some of our services on the Site may not function properly.
Other technical methods, including our use of web beacons, may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the Sites to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.
If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.
We use information we collect about you primarily to provide services to you in accordance with any contract with you or your employer, communicate with you, and manage and improve our services for you and the other users of our services, as permitted by applicable laws.
We use your personal information to:
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.
In Connection with Third Party Offers. We may share information about you with third parties when you engage in certain activities on the Sites that are sponsored by third parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third parties in association with the offerings and at your request. We disclose this information to third parties for the purposes and on the basis described above, for example, to process your transactions and to respond to your requests for information or communications from third parties.
With Contracted Service Providers. Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you. Except as otherwise disclosed in this Privacy Policy or as otherwise communicated to you, Daphne takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accordance with this Privacy Policy. We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.
Analytics Providers. We engage analytics providers to help us understand how users engage with the Sites. These providers may use cookies and similar technologies to collect information about your use of the Sites, as well as information about your use of other websites over time. The services we use include, but may not be limited to, Google Analytics and Adobe, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.
Additional Sharing Practices. From time to time we may share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers, and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.
Finally, we may disclose information when we believe in good faith that such disclosures:
The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business. Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We do not sell your personal information and have not done so in the last 12 months from the effective date of this policy.
The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Periodically, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
The Sites may contain links to websites operated by third parties, and your personal information may be collected by those third parties when you use their websites. Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk. Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
You may update your contact information and/or modify your communication preferences by sending us an email at privacy@getdaphne.com. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.
The Sites are intended for use by individuals over 18, and minors under the age of 13 may not use the Sites.
We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite this policy, a child under the age of 13 has submitted personal information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals. Third parties or service providers, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites. We cannot control their responses to do-not-track signals or other such mechanisms, and their use of data relating to you and their responsiveness to do-not-track signals is governed by their respective privacy policies.
If you no longer wish to receive marketing materials from us, you can contact us at privacy@daphne.io or use other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to:
We will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services.
If you would like to discuss or exercise the rights you may have, contact us at privacy@daphne.io. We will review your request and respond within the time provided by applicable law.
The rights described herein are not absolute and we reserve all our rights available to us at law in this regard. If you make a request related to your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request.
For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
If you are a California resident, you have the right to request certain information from us regarding how we share certain categories of information with third parties that identifies you for the third-parties' direct marketing purposes. If you wish to exercise this right, please email us at privacy@daphne.io. For additional information about your rights and how to exercise those rights, refer to “Your Choices and Rights” above.
We process information collected via the Sites in the United States, the United Kingdom, and the European Union.
The information may be available to the U.S. government or its agencies under lawful orders made in the United States. In addition, we may transfer your information outside the United States, the United Kingdom, or the European Union to our affiliates, business partners, and service providers located in other countries.
In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under UK or EU applicable law. However, where applicable, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at privacy@daphne.io.
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended. When deciding how long to keep your personal information after our relationship with you has ended, we consider how long we need to retain the information to fulfill the purposes described in this Policy and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
The California Consumer Protection Act (CCPA) requires us to provide additional information about the personal information we collect with reference to specific categories of information. For additional information about our sources of personal information, how we use personal information, and how we disclose personal information, refer to Sections A, B, and C above.
Within the last twelve months, we have collected the following categories of personal information from California residents:
We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms. This policy is effective from January 10, 2023.
If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us at privacy@getdaphne.com.