Effective: January 14, 2025
Last Updated: January 14, 2025
This Privacy Policy describes how DAWN LLC. (“Freysa”, “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, web extensions and social media pages as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). Freysa may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
While we implement and maintain measures (such as through on-device processing in certain circumstances) designed to minimize the nature in which we collect and otherwise process personal information, to offer our Service we need certain personal information to derive the hashed values and mathematical proofs critical to our Service. In addition, we may collect personal information unrelated to our core products and services such as when individuals contact us to discuss the Service.
Information you provide to us or that we generate about you. Personal information you may provide to us through the Service or otherwise or that we may generate about you may include:
Contact data, such as your first and last name, email address, mailing address, and phone number.
Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Derived data, such as hashed values and mathematical proofs related to the personal information we collect.
Third-party sources. We may combine personal information we receive from or generate about you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
Blockchain Data. We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity, and to analyze transaction trends for research and development purposes.
Identity Verification Services. We may obtain information from third-party services using your data to verify your identity if required by law (such as applicable know-your-customer requirements).
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
For more information concerning our automatic collection of data, please see the Tracking Technologies section below.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
Provide the Service and operate our business;
Enable security features of the Service such as by sending you security codes via email or other communication methods and remembering devices from which you have previously logged into the Service;
Establish and maintain your user profile on the Service;
Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
Communicate with you about events or contests in which you participate; and
Provide support for the Service, and respond to your requests, questions and feedback.
Service personalization, which may include using your personal information to:
Understand your needs and interests;
Personalize your experience with the Service and our Service-related communications; and
Remember your selections and preferences as you navigate webpages.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, create new products and services, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics and Amplitude for this purpose. You can learn more about Google Analytics and Amplitude related to use of our site and products here: https://tools.google.com/dlpage/gaoptout?hl=en and https://amplitude.com/docs/get-started/cookies-and-consent-management
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Compliance and protection. We may use your personal information to:
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
Enforce the terms and conditions that govern the Service; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, create new products and services, and promote our business.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Functionality. To enhance the performance and functionality of our services.
Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
In this section, we describe the rights and choices available to all users.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and using certain account service features.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://www.aboutcookies.org/. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.