Last Modified: 07/29/2019

 

Your privacy is important to us.

 

It is BlueChip LLC’s (“BlueChip,” the “Company,” “we,” “our,” or “us”) policy to respect your privacy regarding any personal data we may collect while operating our services on our website, available at www.bluechip.dev (the “Website”). Accordingly, we have developed this privacy policy as it may be amended from time to time (hereinafter, referred to as the “Privacy Policy”) in order for you to understand how we collect and process (i.e., use, store, share, disclose, and otherwise make use of) your personal data. This Privacy Policy will also cover your rights in relation to your personal data. The Privacy Policy should be read in conjunction with the Terms of Service Agreement, which can be found here: https://www.bluechip.dev/terms-of-service.

 

This Privacy Policy does not cover any personal data that we may receive about you through other means, including any other website operated by BlueChip or any third-party.

 

By continuing to use our Website, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your personal data and the methods of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to one or more provisions of this Privacy Policy, please immediately cease your use of this Website.

 

This Agreement specifically incorporates by reference, the entirety of our Terms of Service.

Definitions

For the purposes of this Privacy Policy:

  1.  “Personal Data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information.
  2. “Services” means any services that are made available by the Company for use or sale on the Website.
  3. “User”, “You”, and “Your” means the user of the Website that agrees to this Privacy Policy and continues using the Website. You may also be referred to with pronouns such as “your” and “yours,” when second-person pronouns are required.
  4. “Parties” means the parties to this Privacy Policy (i.e., you and the Company). Hereinafter, the parties will individually be referred to as “Party” and collectively as “Parties.”



How We Collect Information

Through your use of our Website, you will be subject to different types of Personal Data collected and different manners of collection. We will collect and process your Personal Data in a lawful, fair, and transparent manner and, where appropriate, with your knowledge or prior explicit consent. Personal Data will be relevant to the purposes for which they are to be used, and to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

 

Types of Personal Data Collected

We comply with data minimization principles. We collect and process only the minimal amount of Personal Data that is necessary for performing the operations requested by you. We do not attempt to collect any Personal Data from you that are not strictly necessary for performing the requested operations. The following types of Personal Data will be collected by the Company through the Website:

  1. REGISTRATION: You, as a User of the Website and its Services, may be asked to register an account to use the Website or access any of the Services thereon. During the process of your registration, you will be asked to provide authorization via Google (if you opt for registration through Google) or Facebook (if you opt for registration through Facebook). You will also be asked to provide authorization for your Robinhood account. We use this Personal Data to provide the Services to you and ensure the security of BlueChip and its Website.
  2. BILLING: If you elect to use any of our paid Services, you will be asked to provide billing information, such as, but not limited to, your credit card number and billing address. This Personal Data will be used specifically for providing you with the Services you have purchased. The payment and billing information may be stored for the time period as required by applicable law for lawful purposes (e.g., accountancy records).
  3. CRYPTO AND FINANCIAL INFORMATION: To use our Services, you will be asked to provide information necessary for Application Programming Interface (“API”) access through Robinhood’s platform.
  4. ORDER AND INVOICE DATA: In order to assure payment for BlueChip’s Services, invoice and order data may be maintained. Such data will only be retained for the period of time necessary to secure payment.
  5. USE: Through your use of BlueChip’s Website, you may be asked questions about how to improve the Website or you may, at some point, communicate with representatives of BlueChip. We will receive your e-mail address, as well as the contents of your communications, answers to questions, and any other form of contact between you and BlueChip. We will use Personal Data contained in such communications only for the purposes of providing you with the requested information and for improving the Website and its Services.
  6. AUTOMATIC COLLECTION: We may collect information from you through automatic tracking systems on your device or through the BlueChip API, or other web and mobile analysis software. We may also receive certain usage data, such as your IP address and referral source. We use this information for our legitimate business interests, including analyzing usage of BlueChip’s Website. 
  7. COMBINED OR AGGREGATED INFORMATION: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update the Website for your and other consumers’ use.

 

Non-Personal Data

We may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from our Website, including referral links we may post on our Website in order to analyze what kind of users visit our Website, how they find it, how long they stay, from which other websites they come to our Website, what pages they look at, and to which other websites they go from our Website.

 

How Information Is Used

We respect data protection principles and process Personal Data only for specified, explicit, and legitimate purposes for which such Personal Data were provided. We primarily use your Personal Data to enable your use of BlueChip’s Website and supply the services requested by you. We may also use your Personal Data for the following purposes:

  1. Asking you about your experience with us;
  2. Communicating with you about your user account with us;
  3. Analyzing our aggregate user data;
  4. Securing payment for our Services;
  5. Enforcing our Terms of Service;
  6. Providing customer services to you;
  7. Advising you about updates to BlueChip, the Website, or related items; or
  8. Providing you with information about services that are similar to the Services used by you.

We will seek your prior express consent for using your Personal Data for any purposes that are not indicated in this Privacy Policy.

 

Your Consent

By using the Website, you are consenting to our processing of your Personal Data as set forth in this Privacy Policy. The term “processing” includes collecting, storing, deleting, using, and disclosing Personal Data.

Please note that we do not collect any sensitive data about you (e.g., your health information, opinions about your religious and political beliefs, or racial origins). Should we intend to process any sensitive data collected from you, we will seek your explicit consent in advance.

 

How Information Is Stored And Kept Secure; Protection of Personal Data

We protect your Personal Data by using reasonable security safeguards against loss or theft, unauthorized access, disclosure, copying, use, or modification. Your Personal Data is contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the Personal Data confidential. We implement a variety of security measures, such as encryption when users enter, submit, or access their Personal Data to maintain the safety of your Personal Data. BlueChip also encrypts the authorized Robinhood access token in storage and does not retain Robinhood account passwords. Please note, however, that no system involving the transmission of information via the Internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data seriously and we take reasonable steps to ensure the ongoing confidentiality, integrity, and availability of your Personal Data. Nevertheless, we are not liable for any loss, theft, unauthorized access, disclosure, copying, use, or modification of your Personal Data that occurs outside our reasonable control.

 

Breach Notification

Should a Personal Data breach occur, we will inform the relevant authorities without undue delay and immediately take reasonable measures to mitigate the breach. We will notify you about such a breach via e-mail as soon as possible but no later than within seven (7) business days.

 

Retention Period

Your Personal Data will be kept for as long as it is necessary to provide you with the requested services. When your Personal Data is no longer necessary to deliver the requested services, we will delete your Personal Data, unless we are obliged by law to retain such Personal Data for a specific period of time.

 

Cookies

BlueChip uses cookies. Cookies are small files stored on your browser which are used for authentication, authorization, and help collect information about your browsing behavior. These cookies do not access information which is stored on your computer.

There are two types of cookies, namely, persistent cookies (i.e., cookies that remain valid until their expiration date, unless deleted by the user before that date) and session cookies (i.e., cookies that are stored on a web browser and remain valid until the moment when the browser is closed). We use both persistent cookies and session cookies.

We use cookies to help us remember information about your account. For example, cookies are used to help us understand your preferences based on previous or current activity on BlueChip’s Website, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about Website traffic and interaction so that we can offer better experiences and tools in the future. Other reasons we use cookies include (but are not limited to):

  1. Authentication and authorization;
  2. Understanding and saving User’s preferences for future visits;
  3. Keeping track of advertisements; and
  4. Compiling aggregate data about traffic and interactions in order to offer better experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

Most Internet browsers accept cookies automatically, although you are able to change your browser settings to control cookies, including whether or not you accept them, and how to remove them. You may also be able to set your browser to advise you if you receive a cookie, or to block or delete cookies.

If you would like to set your browser to refuse cookies, check your browser’s help information or visit http://www.whatarecookies.com for further information.

We honor Do Not Track (“DNT”) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place. Users can also choose to visit our Website anonymously, but you may not be permitted to access any of the Services.

 

How Information May Be Shared or Disclosed

We may disclose your information if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such a disclosure or transfer is limited to the situations when the Personal Data is required for the purposes of (1) provision of the Services, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. Please note that some third-parties may be located outside of the jurisdiction in which you reside.

Such reasonable disclosure cases may include, but are not limited to:

  • Satisfying any local, state, or federal laws or regulations;
  • Responding to requests, such as discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
  • Bringing legal action against a User who has violated the law or violated our Terms of Service;
  • As may be necessary for the operation of BlueChip and our Website;
  • Generally cooperating with any lawful investigation about our Users; or
  • If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our Terms of Service or other applicable rules.

 

Third-Parties

We may utilize third-party service providers, from time to time or all the time, to help us with our Website and to help to serve you. Such third-party service providers may include:

  1. Data storage companies (e.g., Amazon Web Services and other cloud storage providers);
  2. User information logistics providers (e.g., Google Analytics or other analytics companies which help us track general user information and usage);
  3. Web hosting companies;
  4. Newsletter providers; and
  5. Other parties who assist us in operating BlueChip and conducting our business.

The third-party service providers indicated above may have access to your Personal Data as part of their partnerships with us only if they agree to assure an adequate level of protection of Personal Data that is consistent with this Privacy Policy.

We do not sell, trade, or transfer your Personal Data to third-parties not indicated in this Privacy Policy, unless we obtain your prior explicit consent.

Please note that we allow third-party behavioral tracking which may include non-personal data.

We are not responsible for actions of third-parties that are not mentioned in this Privacy Policy and with whom you share your Personal Data, and we have no authority to manage or control third-party solicitations.

 

Transmittals From Us

From time to time, we may send you informational communications related to BlueChip, such as announcements or other information. You may also receive information from us that is specifically about your use of BlueChip’s Website, Services, or about your account with us, including information about security breaches or other privacy-related matters.

By providing any personal information to us, or by using BlueChip’s Website or Services in any manner, you have created a commercial relationship with us. As such, you agree that any e-mail sent from us or third-party affiliates, even unsolicited e-mails, shall specifically not be considered SPAM, as that term is legally defined.

 

Third-Party Links

Through your use of our Website, you may find links out to other websites or mobile applications. This Privacy Policy does not and will not apply to any of those linked websites or applications. We are not responsible in any manner for the content or privacy and security practices and policies of any third-parties, including other websites, services, or applications that may be linked to or from our Website.

Before visiting and providing any information to any such third-party websites and applications, you should familiarize yourself with the applicable privacy practices and take reasonable steps necessary to protect your Personal Data.

 

Your Rights

You may choose to forego the provision of certain Personal Data to us, but you may then be prohibited from using BlueChip’s Website or any of the Services thereon. We collect the information we do to maintain the integrity of BlueChip, our Website, and our Services and to help to ensure the information security of the Parties. If you do not agree to any of the provisions within this Privacy Policy, you must cease your use of our Website entirely.

 

Accessing, Correcting, and Erasing Personal Data

We take reasonable steps to ensure that the Personal Data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your Personal Data as current as possible and update your Personal Data through the Website if necessary.

You may at any time review or change the Personal Data in your user account by logging into it through the Website and updating your data. You may terminate your user account by sending an e-mail request to BlueChip at support@bluechip.dev. Upon your request to terminate your user account, we will deactivate or delete your account and information from our active databases.

If you would like to access, modify, or delete your Personal Data that are processed through our Website, please send us an e-mail to support@bluechip.dev. We will answer your request within a reasonable timeframe.

 

Children

We do not market to any individual under the age of 18 years old. Individuals under 18 years of age may not create an account on BlueChip’s Website. However, we cannot distinguish the age of people accessing our Website or Services. If you are under the age of 18, you are not permitted to use BlueChip’s Website and must cease use immediately. If a person under 18 has provided us with Personal Data without obtaining parental or guardian consent in advance, the parent or guardian may contact us requesting us to destroy or de-identify the Personal Data. Our contact details are specified in the “Contact Us” section of this Privacy Policy.

 

Updates, Modifications, or Revisions

We are committed to conducting our business in accordance with the principles stated in this Privacy Policy in order to ensure that the confidentiality of your Personal Data is protected and maintained. However, we may change this Privacy Policy from time to time at our sole and exclusive discretion.

Unless we specifically obtain your consent, any changes to the Privacy Policy will apply to the Personal Data collected on or after the date of the last amendment that is indicated at the beginning of this Privacy Policy.

It is your responsibility to periodically check this Privacy Policy for any such modification, revision, or amendment. Any changes made are assumed to have been accepted by your continued use of our Website.

For significant changes in the Privacy Policy, or where required by the applicable law, we may seek your explicit consent to the changes stated in the Privacy Policy.

 

California Residents

California’s “Shine the Light” law (Civil Code § 1798.83) permits Users of our Website that are residents of California to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. If you are a California resident and would like to request such information, please submit a written request to support@bluechip.dev. The data collection and management of California residents is additionally regulated by the California Consumers Protection Act (CCPA). This act provides California residents with additional protections, such as the ability to request information regarding the data stored as well as the ability to have such information deleted. BlueChip will be in compliance with the CCPA once it comes into effect in 2020.

 

Complaints About Handling of Personal Data

You have the right to submit a complaint to us about the way in which your Personal Data has been handled by contacting  support@bluechip.dev.

After you submit such a complaint, we will send you an e-mail confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe.

 

Contact Us

For all matters relating to this Privacy Policy and our privacy practices, please e-mail us at support@bluechip.dev.