Effective Date: March 13, 2023
WOLFER FINANCE, LLC (“our”, “us” or “we”) is committed to protecting your privacy.
This privacy policy (“Privacy Policy”) describes the types of personal information that we collect from you through or in connection with (i) any of our products, services, or applications, including, without limitation, (ii) any of our websites, webapps, or mobile applications, including, without limitation, the Wolfer Finance website located at https://wolfer.finance/ (the “Site”) and any subdomains thereof, and (iii) any content made available from or through the Wolfer Finance Discord and/or the Site ((i) through (iii) collectively, the “Services”). The Privacy Policy further describes how we use your personal information and the circumstances under which we may disclose it to others.
Please REVIEW this Privacy Policy carefully. BY USING THE SERVICES, YOU CONSENT TO THE PRIVACY PRACTICES SET FORTH HEREIN. IF YOU DO NOT AGREE WITH THESE PRIVACY PRACTICES, YOU MUST CEASE USING THE SERVICES IMMEDIATELY.
Data Collection – What Do We Collect and How do We Collect it?
As an Affiliate
To become an affiliate, you may provide us with certain personal information, including your email address, social media “handle,” and/or a password to access your Affiliate Dashboard. While we do not ask for your name, sometimes your name is evident from other information you provide us, for example if you provide us with your Twitter handle and it contains your name or a variation of your name. This personal information may, by itself, or in combination with other data, reveal your identity.
To Receive Our Newsletter or Marketing Emails
In order to receive our newsletter or sign up to receive marketing/promotional emails, you must provide us with at least an email address and first name. You may choose to provide us with additional personal information, such as your last name. This personal information may, by itself, or in combination with other data, reveal your identity.
To Use Our Site, Discord, and Other Services
When you use our site, Discord, and other Services, we automatically collect your Internet Protocol Address (“IP address”). IP addresses are considered personal information and may be used to identify you.
When you visit Our Website
We may collect usage data through the use of “cookies” and other data collection tools. For more information about these data collection tools, please see the section of this Privacy Policy titled “Cookies and Other Data Collection Tools.”
Purchasers of NFTs
For those of you who purchased a Wolfer Finance NFT, we request that you fill out our KYC Form at kyc.wolfer.finance. The KYC form asks you to provide the following personal information: your first name, last name, email address, address (which is optional) and country of residence. This information is required to comply with U.S. securities and Treasury laws and regulations. You can learn more about our KYC form at kyc.wolfer.finance
Independent Contractors/Employees
We may post job openings and opportunities on our Site. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
Miscellaneous Collection of Personal Information You Provide to Us
You may choose to communicate with us for certain purposes, such as for customer service, to resolve technical issues, or to provide a comment on our Services. We may collect personal information, such as your name and email address in this capacity.
What Do We Do with Your Personal Information?
Wolfer Finance’s Use of Your Personal Information
We may use your personal information for the following purposes:
- To operate and improve the Services;
- To deliver services that you have requested;
- To contact you about events, publications and services that we provide;
- To better understand how you interact with the Services;
- To tailor the content and information that we provide to you through the Services;
- For security purposes;
- To enforce and protect our rights and the rights of others;
- To comply with applicable laws;
- To consider you for certain opportunities; and
- For research and analytics purposes.
Disclosure of Personal Information to Third Parties
We may disclose your personal information to third parties as follows:
Service Providers. We may disclose your personal information with third parties who work on behalf of, or with, us such as vendors, processors, suppliers, agents, attorneys, and representatives (collectively, “Service Providers”). Service Providers assist us with a variety of functions including, but not limited to, sending marketing communications, assisting with advertising and related analytics, providing management services, conducting research or surveys, sending regular mail and e-mail, maintaining databases, or processing credit card payments.
Business Partners. We may disclose your personal information to third-party business partners, product suppliers, partners who we conduct joint-marketing activities with, partners who we offer a co-branded service with or provide advertising and related-analytics services to us.
Disclosures Under Special Circumstances. We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm, illegal activity, or financial loss; (iii) to detect, investigate and help prevent security, fraud or technical issues; and (iv) to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirement.
Corporate Transactions. We may transfer your personal information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations. For the purpose of this Privacy Policy, third parties who receive personal information in accordance with this section shall be referred to as “Corporate Transaction Recipients.”
At Your Direction: We may disclose or transfer your information to any third party that you direct or ask us to provide that information to.
Selling Your Personal Information
We may sell your IP address to third parties for a commercial purpose, including for financial profit, in combination with non-personal usage data, including the potential Wallet Information described above. We will not sell any other personal information, such as your name or email address.
Residents in certain states may opt out of the sale of this data, as explained below under the section entitled “Your Privacy Rights” in the section below.
How do We Protect Your Personal Information?
We use commercially reasonable security measures, including technical, physical and administrative practices and procedures, to protect your personal information against unauthorized access, loss, misuse and alteration. Nevertheless, no system is perfect. Therefore, we cannot guarantee the absolute security of your personal information, and we make no representations or warranties with respect to the sufficiency of those security measures, nor will we be responsible for any direct or indirect damages that you may incur as a result of a security breach or technical malfunction.
How Long do We Retain Your Personal Information?
We intend to retain your personal information only for as long as is reasonably necessary for the purposes listed above in the section entitled “What Do We Do with Your Personal Information.” This includes retaining your personal information for the purposes of satisfying any legal, accounting, or reporting obligations.
Third-Party Websites
We may include links on the Services to third-party websites and products that we do not operate or control (“Third-Party Websites”). We are not responsible for the collection, use or disclosure of personal information collected through the Third-Party Websites, and we expressly disclaim any and all liability related to such collection, use and disclosure. Therefore, before interacting with the Third-Party Websites, you should consult the privacy policies of those websites to learn more about their privacy practices.
Children’s Privacy
We do not knowingly collect, store, or sell personal information of minors under 18 years of age and no parts of the Services are directed towards or designed to attract anyone under that age. If we become aware that we have collected or stored personal information from an individual under age 18, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to [email protected].
Cookies and Other Data Collection Tools
What is a cookie?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that website or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other data.
Why do we use them?
Cookies help us improve the Services by providing us with data about which parts of the Services are most popular, enabling us to analyze technical and navigational data about the Services and helping us to detect and prevent fraud. We also use cookies and other data collection tools to help improve your experience with the Services.
How do I control cookies?
Web browsers allow some control of most cookies through the browser settings. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although you are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some parts of the pp. To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.
Do Not Track
The Services do not support Do Not Track (DNT). DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your online activities collected. For more information about DNT, please visit www.donottrack.us.
Additional Information for EU Visitors
With respect to “personal data” as defined by Regulation (EU) 2016/679 that you may provide to us through the Services, we serve as the “controller.”
We provide the Services from servers located in the United States. If you are accessing the Services from the European Union, we will only transfer your personal data to the United States through the use of appropriate safeguards. We process your personal data to pursue our legitimate business interest to operate the Services and as described in the section of this Privacy Policy titled “Using Your Personal Information.” To learn more about with whom we may share your personal data, please refer to the section of this Privacy Policy titled “Sharing Your Personal Information.”
We retain your personal data for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. Copies of information that you have updated, modified or deleted will remain in our systems if applicable law requires us to retain it.
You have the right to access your personal data, rectify inaccuracies in it, request the erasure of it, request that we restrict the processing of it, and opt out of the sale of it in certain circumstances. If you wish to access your personal data, please contact us at [email protected], and allow reasonable time for your personal data to be collected.
You also have the right to lodge a complaint with a supervisory authority.
Your Privacy Rights – Residents of California, Colorado, Connecticut, Utah, and Virginia
1) Your Privacy Rights
This section explains your privacy rights under applicable law. Please note that some of the rights may vary depending on your state of residence and when your state’s laws become effective.
- a) Right to Know.
You have the right to request access to and receive details about the personal information we maintain about you (when these laws become effective), including:
- The specific pieces of personal information that Wolfer Finance has about you;
- The categories of personal information Wolfer Finance has collected about you;
- The categories of sources from which your personal information is collected;
- The categories of personal information that Wolfer Finance has sold or disclosed for a business purpose about you;
- The categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
- b) Request to Delete.
You have a right to request that Wolfer Finance delete your personal information that we have collected from you, with certain exceptions.
- c) Request to Correct.
Residents of California, Colorado, Connecticut, and Virginia have the right to request that Wolfer Finance correct inaccurate personal information that it maintains about you.
1. d) Opt out of the Sale of Personal Information.
You have the right to opt out of the sale of your personal information to third parties.
1. e) No Discrimination.
You have a right not to be discriminated by Wolfer Finance for the exercise of your privacy rights.
2) How to Exercise Your Privacy Rights
- a) Submitting a Request to Know, Delete, or Correct.
You may submit a request to know, delete, or correct your personal information by contacting us via email at [email protected].
- b) Submitting a Request to Opt-Out of the Sale of Your Personal Information.
If you would like to opt out of the sale of your personal information, please click opt-out.wolfer.finance or send an email to [email protected].
- c) Verification Methods.
Once you submit a request, we will verify that you are the consumer to which the request pertains. We may request that you provide personal information to us to so that we can verify your identity, including your IP address. If you do not know your IP address, type the phrase, “What is my IP address?” into your web browser, such as Chrome or Microsoft Edge. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.
- d) Authorized Agent
Residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
- e) Appealing Requests
If you are a Colorado, Connecticut, or Virginia resident, you may appeal our decision to your request regarding your personal information. To do so, please send an email to [email protected]. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.
3) Alternate Format of Privacy Policy.
If you have a disability that prevents or limits your ability to access this Privacy Policy, please email us via email at [email protected]. We will work with you to provide it in an alternative format.
Contact
We welcome questions and comments about this Privacy Policy. Please send your questions and comments to us at [email protected].
Modifications to this Privacy Policy
We reserve the right, in our sole discretion, to modify this Privacy Policy at any time without notice to you. We will post all modifications to this Privacy Policy on the Site and they will become effective immediately upon being posted to the Site. Your continued use of the Services following the posting of modifications to this Privacy Policy constitutes your acceptance of those modifications. Therefore, you should check the Effective Date of this Privacy Policy each time that you visit the Site and review the table below to learn what has changed since the last time you visited. Notwithstanding the foregoing, to the extent required by law, we will notify you of any material changes to this Privacy Policy.
The table below identifies material modifications to this Privacy Policy since the Effective Date.