Privacy Policy
Last updated: November 1, 2024
Illa Labs. ("Illa Labs", "we", "us"), a corporation in the United States, operates the Illa Labs website at https://illa.network (the “Website”) and the associated tools, features, materials, and services offered from time to time on the Website (collectively, the “Services”). This Privacy Policy is part of the Illa Labs Terms of Service and relates to all of Illa Labs’ collection, use, and disclosure of your personal information, unless we have provided you with a separate privacy policy for a particular product, service, or activity. All terms, conditions, and terminology are consistent with the Terms of Service, which are incorporated into this document by reference.
Please review this privacy policy carefully. By submitting your personal information to us, by using our Website, or by otherwise accessing or using the Services, you consent to our collecting, using, and disclosing your personal information as set out in this privacy policy. The Services do *not* include third party websites or platforms which may be linked or interconnected to the Services. Such outside platforms are governed by their own privacy policy. These third party platforms may include, but are not limited to third parties that display Illa Labs data, such as aggregators, data portals, and portfolio apps, as well as other integrators building on top of Illa Labs’ API.
The Blockchain
Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
This means that by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens) it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this requires you to execute such transactions using your wallet’s private key.
In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you.
If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains, as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.
Individuals under the Age of 18
As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit, or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.
In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and you are aware that your child has provided personal data to the Services, please contact us so that we may remove such data. Note that we cannot delete information stored on public cryptographic blockchains.
Collection of Personal Information
We collect Personal Information from you in the following ways:
Through your use of the Services, whether directly uploaded and created by you, or automatically collected by us as you use the Services.
Through your engagement with our Website, including information submitted by you within a website form or obtained from us through cookies or similar technologies.
From other third-party sources, such as our partners and service providers.
We collect the following types of information from you:
Information and content you provide. We collect the content, communications, and other information you provide when you use our Services, including information you provide when you create an account, initiate the use of the Services, create or share content, and message or communicate with others.
Financial information. In order to transfer funds, you may need to provide us and our third-party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency, or any other payment methods. You may agree to your personal and financial information being transferred, stored, and processed by such third parties in accordance with their respective privacy policies.
Your usage. We collect information about how you use our Services, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency, and duration of your activities.
Information about transactions made on our Services. If you use our Services for transactions of any kind, we collect information about them.
Things others do and information they provide about you. We also receive and analyze content, communications, and information that other people provide when they use our Services.
Cookies
We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. Cookies may store a variety of information, including the number of times that you access a website, your login information, your device information, IP address, and the number of times that you view a particular page or other item on the Website or Services. The use of cookies is a common practice adopted by most major websites to better serve their users. If you have an account with the Services, we may link this usage data with other information that we collect from you as outlined above. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.
Device Information
As described below, we collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.
Information we obtain from these devices may include:
Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, the names of apps, files and types of files stored in your wallet, and the names of plugins.
Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
Identifiers: unique identifiers, device IDs, and other identifiers.
Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera, or photos.
Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed, and, in some cases, information about other devices that are nearby or on your network.
Cookie data: data from cookies stored on your device, including cookie IDs and settings.
Information necessary to enable push notifications: if you enable push notifications in our services, we will collect information from your device as may be necessary to enable such notifications.
Information from partners
The Services use Google Analytics and other Google services to gather information about the computers and devices that connect to them. Although Google Analytics plants a cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.
See the “Third-Party Data Collection” section for additional information on third-party collection of data.
When using the Services
When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.
On the Blockchain the following data may be stored:
addresses of externally owned accounts
transactions made; and
token balances.
Given the technological design of the blockchain, this data will become public and it will not likely be possible to delete or change the data at any given time.
In our web servers, we will store the following data:
addresses of externally owned accounts
transactions made
log data
the Internet protocol address (“IP address”); and
transaction ids/hashes.
Use of Personal Information
We use the information we have (subject to choices you make) as described below and to provide and support the Services. Here's how:
Provide, personalize and improve our Services.
We use the information we have to deliver our Services, including to personalize features and content.
Information across devices: We connect information about your activities on different devices to provide a more tailored and consistent experience.
Product research and development: We use the information we have to develop, test and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.
Provide measurement, analytics, and other business services.
The Services use Google Analytics to gather information about their use. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. The Services use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information.
Promote safety, integrity and security.
We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.
Communicate with you.
We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms in accordance with applicable law. We also use your information to respond to you when you contact us.
Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services don’t recognize it for tracking purposes.
Third-Party Data Collection
Third parties may collect or receive certain information about you and/or your use of the Services to provide content, ads (including personalized ads), or functionality, or to measure and analyze ad performance, in or through the Services. These third parties include:
You may choose whether to receive certain personalized (also known as targeted) advertising from participating ad networks, audience segment providers, ad serving vendors, other service providers or entities by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance or if you are a user in the European Economic Area, Your Online Choices. We adhere to the Self-Regulatory Principles for Online Behavioral Advertising.
We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
Retention
The Services may keep the information we gather about you for an unlimited length of time.
To request that information collected about you be deleted, please contact us at the email provided in this policy. A valid request must include sufficient information to identify your personal data. Note that we cannot delete information stored on public cryptographic blockchains.
How we Use Your Personal Information
We only share information about you with others as follows:
We contract with other companies to perform functions on our behalf, such as service providers that assist in the administration of the Services and our marketing efforts, identity verification services, data analytics companies that help us target our offerings, marketing partners, and payment providers. We also share your information with third party service providers who provide products and services that we use to operate our business, such as financial institutions, accountants, auditors, lawyers, payment processors, information technology consultants, and advisors. We may need to share your information with these companies. These partners may access this information so long as you have an account on the Services.
We may also transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.
We will also share your information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harm our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your data, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in our Privacy Policy.
We routinely share information with companies closely related to us – our “affiliates” – for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights under this Privacy Policy and we will be responsible for our affiliates’ conduct related thereto.
We may share information about you with US, state or international regulators, SEC, or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas.
The Services may contain links to third party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with us. Third party websites are not under our control, and we are not responsible for any third party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to these websites does not imply an endorsement by us, or of the provider of such content or services, or of any third party website. Please be aware that when you enter a third party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.
International Transfer and Storage of Information
Personal information may be processed in any country across the world or in which we engage third party service providers to provide the Services. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
Our practices regarding your personal information will at all times continue to be governed by this privacy policy and we will continue to comply with all applicable legal requirements.
Opt–Out
If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Services.
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your Rights
Subject to certain exemptions, to the extent permitted by applicable law, you have the following rights in relation to the personal information we hold about you:
Your right of access. At your written request we will inform you whether we hold personal information relating to you and if we do, you have the right to receive a general account of our processing of such personal information. If your request is made in writing, subject to applicable laws and the provisions of this Privacy Policy, we will also provide you with access to your personal information that is in our possession. A reasonable fee may be levied if you request the transcription, reproduction or transmission of such information and you will have to provide information or documentation to verify your identity. We will inform you of the approximate cost before proceeding to respond to your request. Your rights to access your personal information are not absolute. Access can be denied for several different reasons under applicable legislation. If we deny your request for access to your personal information, we shall explain why.
Your right to rectification. If we hold personal information about you and you believe that it is not accurate, complete and up-to-date, you can request to have it rectified (or rectify it yourself via your account information page, if available). If we discover that information is not accurate, complete and up-to-date, we will take reasonable steps to rectify it. We will also send any information that has been amended, where appropriate, to any third parties that have access to the information.
Your right to withdraw consent. If we rely on your implicit or explicit consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Contact
If you have comments or questions about the privacy policies of the Services, please contact our Data Protection Officer at legal@illalabs.ai.
Changes
This privacy policy is current as of the “updated” date which appears at the top of this page. We may modify this privacy policy from time to time. When changes are made to this privacy policy they will become immediately effective when published in a revised privacy policy posted on our website, unless otherwise noted. We may also communicate the changes through our Services or by other means. By submitting your personal information to us, by registering for or using any of the Services we offer, by using our Website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy policy, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy policy.
Check this page for the latest.