Fimi Market Inc. (“Fimi,” “we”, “us”, or “our”) is committed to protecting your privacy and data. This Privacy Policy describes our practices regarding the Personal Data we collect, use, and share in connection with the Fimi website/marketplace, mobile application, and other software provided on or in connection with our Platforms, as described in our Terms and Conditions Policy (collectively, the “Platform”). “NFT” in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain which uses smart contracts to link to or otherwise be associated with certain content or data.

  1. Fimi Market, Inc.

    The primary agency for the collection, processing and use of your personal information through the Platform is: Fimi 251 Little Falls Drive, Wilmington, DE 19808, USA. Email: [email protected]

  2. Registration.

    To use the Platform, you may be asked to register by providing registration information. In addition, you may be required to register through the App. If you register for any reason, some or all of the following information may be collected:

    1. and last name;

    2. Account username;

    3. Company (if applicable);

    4. Email;

    5. Telephone;

    6. Cryptocurrency Wallet address;

    7. Or other registration-related information.

    The registration data is used to verify your identity and location, and to help us connect you to your historical data and account. By registering and using the Platform you consent to receive follow-up questions and other communication, either from us or from relevant third parties. If you create an account, we may use your name or your email address as your login name. Alternatively, we may use an anonymized login system for your login activity. The creation of an account is required because the Platform may not be able to work without historical data. The legal basis of the processing is your consent.

  3. Data Collection.

    “Personal Data” means data that allows someone to identify you individually, including, but not limited to, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.

    1. Information You Provide Us.

      1. When you use our Platform, update your account profile, or contact us, we may collect Personal Data from you, such as email address, first and last name, user name, and other information you provide. We also collect your blockchain address, which may become associated with Personal Data when you use our Platform.

      2. Our Platform lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your profile, browser, or mobile device.

      3. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.

      4. We may also collect Personal Data at other points in our Platform where you voluntarily provide it or where we state that Personal Data is being collected.

    2. Automatic Data Collection.

      As you interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

      1. Information Collected by Our Servers.

        To, and in order to, provide our Platform we (or a third party Platform provider) collect information from you, including, but not limited to, your browser type, operating Platform, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.

      2. Cookies.

        We use cookies to collect information. These are small files that your browser automatically creates and displays on your device (laptop, tablet, smartphone, etc.) when you access the Platforms. Cookies do not harm your device, do not contain viruses, Trojans, or other malicious software. Cookie information is stored, and may result in a connection with a specific terminal or browser being used. This does not, however, mean that we are immediately aware of your identity. The use of cookies serves to increase the usability of the Platform. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Platform, make improvements to our product quality, and provide users with a more personalized experience. Also, if you access the Website or the Platform from a social networking service, we may share information with such social networking service in accordance with this Privacy Policy and to the extent permitted by your agreement with such social networking service and its privacy settings.

      3. Local Storage and/or Pixel Tags.

        We may use device or HTML5 Local Storage, caching or other forms of Local Storage to store your preferences, help us remember certain information about how you interact with the Platform or display content on the through the Platform based upon what you have viewed on various other websites. We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs) in connection with the Platform to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel, that is ordinarily not visible to you and may be associated with Cookies on your hard drive or Local Storage. Pixel Tags allow us to analyze how users find our Platform, make the Platform more useful to you, and tailor your experience with us to meet your particular interests and needs. By accepting this Privacy Policy, and by accessing or using the Website or the Platform, you are consenting to permit the use of Cookies, Local Storage and Pixel Tags by us and the third- party companies with which we work.

      4. How We Respond to Do Not Track Signals.

        Because there is not yet a accepted standard for how to respond to Do Not Track Signals, our Platforms do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.

      5. Analytics Platforms.

        Other companies may set their own cookies or similar tools when you visit our Platform. This includes third-party analytics Platforms (“Analytics Platforms”) that we engage to help analyze how users use the Platform. The information generated by the Cookies or other technologies about your use of our Platform (the “Analytics Information”) is transmitted to the Analytics Platforms. The Analytics Platforms use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Platforms to improve our Platform. The Analytics Platforms may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Platforms’ ability to use and share Analytics Information is restricted by such Analytics Platforms’ terms of use and privacy policy. By using our Platform, you consent to the processing of data about you by Analytics Platforms in the manner and for the purposes set out above.

    3. Information Collected from Third-Party Companies.

      We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or Platforms for use in conjunction with our Platform or whose products and/or Platforms may be linked from our Platform. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers. We may add this to the data we have already collected from or about you through our Platform.

    4. Public Blockchain Information.

      We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.

  4. Use of Your Personal Data.

    1. We process your Personal Data to run our business, provide the Platform, personalize your experience on the Platform, and improve the Platform. Specifically, we use your Personal Data to:

      1. facilitate the creation of and secure your account;

      2. identify you as a legitimate user in our Platform;

      3. provide you with our Platform, including, but not limited to, helping you view, explore, and create NFTs using our tools and, at your own discretion, connect directly with others to purchase, sell, or transfer NFTs on public blockchains;

      4. improve the administration of our Platform and quality of experience when you interact with our Platform, including, but not limited to, by analyzing how you and other users find and interact with the Platform;

      5. provide customer support and respond to your requests and inquiries;

      6. investigate and address conduct that may violate our Terms of Service;

      7. detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;

      8. display your username next to the NFTs currently or previously accessible in your third-party wallet, and next to NFTs on which you have interacted;

      9. send you a welcome email to verify ownership of the email address provided when your account was created;

      10. send you administrative notifications, such as security, support, and maintenance advisories;

      11. send you notifications related to actions on the Platform, including notifications of offers on your NFTs;

      12. send you promotional materials, and other notices related to our Platforms or third parties’ goods and services;

      13. comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and

      14. act in any other way we may describe when you provide the Personal Data.

    2. We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Platforms and enhance Platform navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

  5. Disclosure of Your Personal Data.

    We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

    1. Third Party Service Providers.

      We may share your Personal Data with third party Service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Platform is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Platform.

    2. Affiliates.

      We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

    3. Corporate Restructuring.

      We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

    4. Legal Rights.

      Regardless of any choices you make regarding your Personal Data (as described below), Fimi may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Fimi; (c) to protect or defend the rights or property of Fimi or users of the Platform; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

    5. Other Disclosures.

      We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

  6. Third-Party Websites.

    Our Platform may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Platform and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

  7. Third-Party Wallets.

    To use our Platform, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable Terms of Service and privacy policy of that third party.

  8. Your Choices Regarding Information.

    You have several choices regarding the use of information on our Platforms:

    1. Email Communications.

      We may periodically send you emails that directly promote the use of our Platform or third parties’ goods and services. When you receive promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the Notifications preferences in your dashboard. Despite these preferences, we may send you occasional transactional Platform-related informational communications.

    2. If you decide at any time that you no longer wish to accept Cookies from our Platform for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Platform or all functionality of the Platform.

  9. Data Access and Control.

    You can view, access, edit, or delete your Personal Data for certain aspects of the Platform via your Dashboard. You may also have certain additional rights:

    1. Email Communications.

      If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.

    2. If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not “sell” your “personal information.”

    3. If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us by using the “Submit a request” link https://fimi.market/contact or at the address provided below, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights. Please note, we may not honor part or all of a request you make to exercise your rights under CCPA – for example, certain information we collect is exempt from this California Privacy Notice, such as publicly-available information collected from a government agency. When this occurs and we do not honor your request, we will explain why in our response.

    4. Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.

  10. Registration Data in the European Union and the United Kingdom. In accordance with GDPR, we use the so-called Double Opt-in method. We will only send you e-mail if you confirm by clicking on a link in our notification e-mail that you are the owner of the given e-mail address. If you confirm your e-mail address, we will save your e-mail address and the time of registration until you unsubscribe. You can unsubscribe from e-mail at any time, except that we may still send you an email if you request a password reset. A corresponding unsubscribe link can be found in every e-mail. A message to the above or in the specified contact information (e.g. by e-mail or letter) is also sufficient. The legal basis of this processing is your consent in accordance with. Art. 6 para. 1 lit of the GDPR.

    In our email, we use commercially available technologies that measure the interactions with the e-mail (e.g. opening the e-mail, clicked links). We use this data in pseudonymous form for general statistical evaluations as well as for the optimization and further development of our content and customer communication. This is done with the help of small graphics that are embedded in the e-mail (so-called pixels). The data is collected exclusively pseudonymized and also not linked with your other personal information. Legal basis for this is our aforementioned legitimate interest. Through our e-mail, we want to share content relevant to our customers and better understand what readers are actually interested in. If you do not want us to include your information in our analysis of usage behavior, you can unsubscribe from e- mails or deactivate graphics in your e-mail program by default. The data for the interaction with our e-mails may be stored pseudonymously for 30 days and then completely anonymized.

  11. Data Retention.

    We may retain your Personal Data as long as you continue to use the Platform, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Platform if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it.

  12. Data Security.

    You should always keep your account access information confidential and close the browser window when you stop communicating with us, especially if you share your computer with others. In addition, we take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. However, as you should be aware, no security service is impenetrable and we cannot guarantee the security of our Platforms. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.

    1. You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is secure. If you discover an issue related to your wallet, please contact your wallet provider.

  13. Minors.

    We do not intentionally gather Personal Data from visitors who are under the age of thirteen (13). Our Terms of Service require all users to be at least eighteen (18) years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s Fimi account, but only with the involvement of the account holder. If a child under 13 submits Personal Data to Fimi and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us by using the “Submit a request” link or at the address indicated below.

  14. Users Outside of the United States. If you are a non-U.S. user of the Platform, by visiting the Platform and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.

  15. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on the Platform or www.Fmi.Market. The date the Privacy Policy was last revised, if applicable, is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Platform and this Privacy Policy to check for any changes.

  16. Questions; Contacting Fimi; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us by using the “Submit a request” link (provide hyperlink) or at the following address: [Provide address that is monitored].