THE BLOCK
PRIVACY POLICY

 

 

Last Updated on April 3, 2023.

This Privacy Policy (“Policy”) describes how Block Bond Holdings, Inc. and its affiliates and subsidiaries (“The Block,” “we,” “us,” or “our”) collects, uses, and discloses information that we collect about visitors to our websites including www.theblock.co, www.theblock.pro, and other websites and platforms that link to this Policy (collectively, the “Site”), and the services available through our Site (collectively, the “Services”). This Policy also describes the rights you may have under applicable laws regarding your personal information.  

 

By visiting the Site or using any of our Services, you agree that your information is subject to and will be collected, used and disclosed in accordance with this Policy.

 

Categories of Information We Collect About You

Personal information is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. We collect the following categories of personal information about you directly from you, automatically through your use of our Site, and from third parties.

• Identifiers: Such as your name, address, email address, IP address, telephone number, or similar identifier.
• Demographics: Such as your gender, mailing address, and age.
• Commercial information: Such as records of products, subscriptions or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Professional and employment-related information: Such as employer, job title, experience or expertise, education, professional contact information, or other information such as your resume or CV provided in connection with job postings.
• Internet and other electronic network activity: Internet or other electronic network activity information, including browser type and operating system; browsing history, clickstream data, search history, and information regarding your interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of our Site; the length of time you visit our Site; and the referring URL, or the website that led you to our Site.
• Sensitive personal information: Such as payment card information and account login credentials and passwords (which may be considered sensitive in some jurisdictions).
• Inferences: Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

 

Information You Provide to Us

We collect information that you voluntarily and directly provide to us when you use our Site, including when you subscribe to a newsletter, provide us with information through a form on our Site, register for a webinar, in-person event, or other event, complete a survey, enter a contest, apply for a job through our Careers page, or sign up or pay for our Services.

 

We may collect information from you if you contact us through our Site, social media platforms or otherwise, including your name, email address, the contents of a message or attachments that you may send to us, and other information that you choose to provide. If you subscribe to our newsletter, we will collect certain information from you, such as your email address.  

 

We may also collect information about people you know through a referral program that allows you to easily forward information about our Site or Services to friends or family. If you choose to refer a friend or family member to our Site, you represent that you have their permission to do so. This functionality is only meant for U.S. residents. By using it, you acknowledge and agree that such friend or family member is based in the U.S. We will ask for that person’s email address and may also send them a message on your behalf. We may process this information to facilitate your referral invitation or other legitimate business purposes including to improve our referral program. 

 

Information We Collect Automatically

To improve our Site and Services, we and our third-party cookie providers automatically collect information when you use our Site using cookies, pixel tags, or similar technologies. This may include information such as your IP address and the types of personal information described above as “Internet and other electronic network activity.” Please see our section on cookies below for additional information regarding our use of cookies and similar technologies.  

 

Information We Collect from Third Parties

We collect information from third party business partners that provide services on our behalf and from non-affiliated third parties, such as research firms and public sources. Depending on the source, this information could include information such as demographic information and brand and media consumption information.

 

Our Use of Cookies and Other Tracking Mechanisms

To help make our Sites and Services more responsive to your needs, we and our business partners and service providers use cookies and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other information we collect about you (and our business partners and service providers may do so on our behalf).

 

• Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Site, you may not be able to utilize the features of the Site to their fullest potential. Depending on your location, you may also be able to change your cookie preferences by going to our cookie preference center.
• Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags) to, among other things, track activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our service providers also use clear GIFs in HTML email to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
  
  

Third Party Advertising Networks

We allow our third-party partners, third party ad serving networks, and unaffiliated advertisers (collectively, “Advertisers”) to use cookies, web beacons, and other tracking technologies to provide ads about goods and services that may be of interest to you. Advertisers may place a separate cookie on your computer, or browser, or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, server being used, area code and zip code associated with your server, and whether you respond to certain ads. Advertisers may collect information about your online activities over time, across different computers, devices, and browsers, and across different websites and other online services. Advertisers may use this information to provide interest-based advertising or other targeted content 

 

In general, the information collected and generated by third parties is processed and stored by the third parties and will be subject to their respective privacy policies (which we do not control and for which we are not responsible). We do not control these third-party Advertiser’s tracking technologies or the information they may collect. Many of these Advertisers are members of industry opt-out programs that offer you additional choices regarding the collection and use of your information as described in the Your Choices and Rights section below.

 

How We Use Your Information and The Basis on Which We Use It

We use the categories of personal information described above for the following business purposes:

 

• To provide our Site and Services to you, to communicate with you about your use of our Site and Services, and to respond to your inquiries.
• For identification and authentication purposes. For example, when you enter your login ID and password to enter our Services.
• For marketing and promotional purposes. For example, we may use your information to provide you with news, special offers, and general information about goods, services, and events that we think may be of interest to you (including through our newsletters, marketing, or promotional materials). We may also use the information that we learn about you to assist us in advertising our services on third-party websites and in other forums.
• To tailor the content and information that we may send or display to you, for personalized help and instructions, and to otherwise personalize your experiences while using the Site or Services.
• With respect to employment-related information, to evaluate your candidacy for a job posting and to make hiring decisions.
• To better understand how users access and use our Site, to improve our Site, create new products and services, and respond to user desires and preferences, and for related research and analytical purposes.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Where we believe necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy and our Terms of Service or the integrity of the Site and Services.
• We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.

 

Legal Bases for Use and Processing of Your Information

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing your personal data are as follows:

 

• Performance of a contract. We process your information where necessary for the performance of our contractual obligations to you, for example, to provide the Site and Services and authenticate your identity when logging into the various login sections of the Site.
• Compliance with legal obligations. We process your information where necessary to comply with the legal obligations to which we are subject.
• Legitimate Interests. We process your information where necessary to serve our legitimate business interests, for example, to ensure that we can effectively manage and communicate regarding our business efficiently, to perform investigations or compliance audits, to tailor the content and information we may send or display to you, to improve the Site and our Services, to exercise or defend our rights, and for business administration purposes. When we use your information to meet our legitimate interests, we take steps to ensure that your rights are not infringed. You can contact us using the details in the Contact Us section below for more information about the steps we take to ensure these rights are not infringed.
• To the extent we obtain your consent to process your information, you may have the right to withdraw your consent under applicable local law. To exercise this right, please contact us using the details in the “Contact Us” section of this Policy.

 

How We Disclose the Information We Collect

We may disclose each of the categories of information described above for our business purposes as follows:

 

• We may disclose the information we collect about you to our subsidiaries and affiliated entities. However, if we do so their use and disclosure of your information will be subject to this Policy.
• Service Providers and Business Partners. We may disclose the information we collect about you to service providers, contractors, agents, and third parties who perform functions and business operations on our behalf, for the purposes set out above. For example, we engage service providers and third parties to sponsor or co-host events, optimize services, process payments, send newsletters, marketing messages and advertising, support email and messaging services, help us manage our relationship with you, and analyze information. We also partner with third party platforms, including social media platforms, to market our Services to you. These third parties may collect or receive information about you or your use of our Services and may use your information to provide you with information about their own products and services. These business partners and service providers will be given limited access to the information you have provided as is reasonably necessary to deliver the Services, and we will use commercially reasonable efforts to require that such third parties comply with this Privacy Policy. These third-party business partners may also gather user data about you in the course of providing our Services to you, and this Privacy Policy may not describe the privacy practices of such third parties. You may opt out of receiving information about such third parties' products and services by doing so directly on such third-party websites.
• Business Transfers. If (i) we are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain of your information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We may disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information where we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We may disclose aggregate, anonymized, or de-identified information about you for any purpose permitted under applicable local law.
• We may also disclose your information with your consent. For example, while on our Site, you may have the opportunity to sign up or opt-in to receive marketing offers from our event sponsors or partners and will have the opportunity to consent to sharing your personal data which will be subject to the privacy policy and business practices of that third party.

 

Additional Information for California Residents

This section provides California residents with additional information regarding our collection, use, and disclosure of their personal information.

 

The chart below describes the categories of personal information described above in our section on “Categories of Information We Collect About You” that we may “sell” or “share” as those terms are broadly defined by California law and the categories of third parties to whom we may “sell” or “share” your personal information. We may sell or share your personal information for our business purposes as described above in our section on “How We Use Your Information and The Basis on Which We Use It.”

 

Category of Personal Information	Categories of third parties with whom we may “sell” or “share” this information
Identifiers	Marketing & Sales Service Providers, Data Storage and Analytics Providers, Payment Processors, Workforce Management Providers
Demographics	Marketing & Sales Service Providers, Data Storage and Analytics Service Providers, Workforce Management Providers
Commercial information	Marketing & Sales Service Providers, Data Storage and Analytics Service Providers
Professional and employment-related information	Marketing & Sales Service Providers, Workforce Management Providers
Internet and other electronic network activity	Marketing & Sales Service Providers, Data Storage and Analytics Service Providers
Sensitive personal information	Payment Processors, Workforce Management Providers
Inferences	Marketing & Sales Service Providers, Data Storage and Analytics Service Providers, Workforce Management Providers

 

When we disclose that we may have sold personal information, it means that we may have received some kind of benefit to our company in return for sharing Personal Information, it does not necessarily mean we received any money in exchange. We will update this disclosure as appropriate.

 

Your Choices and Rights

If you subscribe with us, you may review, update or change the registration data we have collected about you at any time by editing your personal data in your account settings.

 

Additionally, you may have certain rights regarding our processing of your personal information under applicable local law. Depending on the jurisdiction in which you live, these may include rights to:

 

• request information about our processing of your information;
• request access to your personal information;
• rectify, correct, or update the information we hold about you;
• request deletion of your information;
• opt out of “sales” of personal information or “sharing” of personal information for cross-context behavioral advertising purposes (as these terms are defined under applicable law);
• opt out of certain profiling activities;
• restrict or limit our use of your information;
• object to our use of your information;
• where you have provided consent, withdraw such consent to our processing of your personal information at any time;
• not be unlawfully discriminated against for exercising your rights;
• lodge a complaint with your local data protection authority.

 

These rights may be limited or denied in some circumstances. For example, we may retain your personal information where required, such as for fraud prevention, or permitted by applicable law. Additionally, we may postpone completion of your request for legitimate business purposes, such as when your personal information is necessary to fulfill our obligations to you (e.g., if you are an active subscriber we may wait until your subscription expires before fulfilling your request). If you request deletion of data by us, we will use all commercially reasonable efforts to do so. If we delete any information, it will be deleted from our active database, but it may remain in our secure backup systems for a limited time in encrypted form and pursuant to our data retention policy.

 

• In the event you would like to exercise your rights under applicable local law or if you are an authorized agent submitting a request on behalf of an individual under applicable local law, please click on the “Do Not Sell or Share My Personal Information” link on our Site or send an email to [email protected].

 

We may need to verify your identity before completing your rights request. We may request information that you have provided to us or about your interactions with us. We may use the information you provide to us to verify your identity by comparing the information provided to the information in our records. If you are an authorized agent submitting a request, we may notify the consumer and ask the consumer to independently verify their identity before fulfilling your request.

 

Advertising Industry Opt-Out Tools

You can also choose to opt out of the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes by participating organizations through industry opt out tools. Some of the above referenced organizations adhere to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can opt-out from participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

 

Opt-out cookies only work on the internet browser and device they are downloaded onto. Please note that when you "opt-out" of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the Site or Services.  It means the online ads you see from DAA program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of the Services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

 

Do-Not-Track

This is a privacy preference that users can set in certain web browsers. While we are committed to providing you with meaningful choices about the information collected on our Site by third parties, currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as described above in the “Your Choices and Rights” section. You may also opt out of targeted advertising by following the instructions in the Advertising Industry Opt-Out Tools section above.

 

California Consumer Rights

If you are a California resident, you may have the following rights:

 

• Right to know: Right to request information about the personal information that we collect, use, disclose, share and sell.
• Right to deletion: Right to request that we delete your personal information we have collected. If you ask us to delete certain information, you may no longer be able to access or use the Services.
• Right to correct: Right to request that we correct inaccurate personal information that we maintain about you.
• Right to opt-out of sale or sharing: Right to opt-out of our sale (if any) or sharing of your personal information. You may opt-out of sale or sharing of your personal information by clicking on the “Do Not Sell or Share My Personal Information” link on our Site.
• Right to limit use of sensitive personal information: Right to limit our use and disclosure of your sensitive personal information to purposes specified under applicable law. You may limit the use of your sensitive personal information by clicking on the “Do Not Sell or Share My Personal Information” link on our Site.
• Right to be free from discrimination: You may freely exercise your rights without fear of being discriminated or retaliated against. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

 

In the event you would like to exercise your right to know, delete, or correct, or if you are an authorized agent submitting a request on behalf of a California consumer, please submit a request as described above in “Your Choices and Rights.”

 

Children’s Privacy

Our Site and Services are not designed for children under the age of 13. We do not knowingly collect information, as that term is defined in the Children’s Online Privacy Protection Act, from anyone under the age of 13. If we discover that a child under the age of 13 has provided us with personal information, we will take steps to delete such information from our systems. We also do not knowingly “sell” or “share” the personal information of children under the age of 16 and if we become aware, will take reasonable steps to delete it as soon as possible.   

 

Promotional Emails

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests, as may be required by applicable local law. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us, unless otherwise prohibited by applicable local law.   

 

Third Party Links

Our Site or Services may contain links to third-party websites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. Any access to and use of such linked websites is not governed by this Policy but is instead governed by the privacy policies of those third-party websites. You agree that we are not responsible for the information practices of such third-party websites, including the information or content contained on such websites, and do not have control over any third parties that you may authorize to access your account information.

 

Third Party Payment Processing

For online payments, we use the payment services of third parties, such as NetSuite, Stripe and Coinbase Commerce. We do not process, record, or maintain your bank, credit or debit card information. That information is provided directly to the third-party processor whose use of your personal information is subject to their privacy policy.

 

Security and Retention  

We care about the security of your information and have implemented commercially reasonable precautions to protect the information we collect from your use of the Site and Services from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your email communications from us. Your information will be securely held by us only so long as it is needed for our legitimate business purposes, including for any legal requirements, or until it is reasonably technically possible to delete or anonymize such information.

 

International Transfers of Information

Your information may be processed or maintained in servers and databases located outside of the jurisdiction in which you reside and where the privacy laws may not be as protective as your jurisdiction of residence. If you are located outside the United States and choose to provide information to us, please note that we may transfer to and maintain and process the data in the United States. We will take all steps reasonably necessary to ensure that your information is treated securely in accordance with this Policy.

 

Contact Us

The Block is the controller of your information. If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please email us at [email protected].

 

Changes to this Policy

This policy is current as of the Last Updated 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 our Site by updating the “Last Updated” date at the top of this page. If we make any changes to this Policy that materially affect our practices regarding the information we have previously collected or collect about you, we will also endeavor to provide you with notice in advance of such change by highlighting the change on our Site or sending you an email.