Censo App
Privacy Policy

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Last Revised: Nov 6, 2023

This Privacy Policy explains the categories of personal information that Censo (“Censo” or “we”) collects through our mobile app (the “Censo App”), how we process that information, and for what purposes. This Privacy Policy also explains how we can use and disclose, and how we protect, such information, as well as your choices regarding your information. Throughout this Privacy Policy, "information" includes personal information about you. We follow this Privacy Policy in accordance with applicable law.

PLEASE READ THIS PRIVACY POLICY AND OUR TERMS OF USE (THE “TERMS”) https://censo.co/legal/terms CAREFULLY. IF YOU DO NOT AGREE WITH THE PROVISIONS OF THIS PRIVACY POLICY OR THE APP TERMS, DO NOT USE OR ACCESS THE CENSO APP. BY USING OR ACCESSING THE CENSO APP, OR BY CLICKING A BUTTON OR CHECKING A BOX MARKED “I AGREE” (OR SOMETHING SIMILAR), YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE PROVISIONS OF THIS PRIVACY POLICY AND THE TERMS (COLLECTIVELY THE “TERMS”).

Information We Collect

“Personal information” means information that directly or indirectly identifies a specific individual, such as name, address, email, or telephone number. “Anonymized information” means information that doesn’t, and can’t reasonably be used to identify, a specific individual. When anonymized information is directly or indirectly associated with personal information, we treat it as personal information.

We collect the following personal information about you:

• Facial Scan. When you set up the Censo App, we scan your face and store an encrypted version of your facial scan (your “Facial Scan”). We store, but cannot access your Facial Scan

We may also automatically collect other information from or about you, including:

• usage, viewing, technical, and device data when you use the Censo App, including your browser, platform, or device type, unique device identifier, operating system, mobile network information, IP address, software and hardware attributes, and your internet service provider’s domain name
• your geographic location, where we are permitted by law to process this information, including precise or approximate location information provided by a mobile or other device interacting with one of our Censo App or associated with your IP address or other online or device identifier
• information regarding your access to and use of the Censo App, such as content viewed or downloaded, landing pages, how often you use the Censo App, browsing activity, dates and times of access, pages viewed, forms you complete or partially complete, and your preferences
• anonymized information
• aggregated information

How We Collect Information

Other than your Facial Scan, we do not collect personal information from or about you when you use or access the Censo App but may automatically collect the other information listed in “Information We Collect” above.

How We Use Your Information

Subject to applicable law and the choices and controls on the use of your information that may be available to you, we may use the information that we collect from and about you or the devices associated with you, for any of the following purposes.

• Use of your Facial Scan. We will only use your Facial Scan to authenticate you, such as if you need access to your seed phrase or to allow you to securely change the Apple IP or Google account that you are using for primary authentication of your Censo App account (the “Authentication Purpose”)

We may use all other information that we collect from and about you or the devices associated with you, for any of the following purposes:

• Services Provision. To provide the Censo App to you, troubleshoot, and provide support. We may also share information with third parties when it is required to do any of the foregoing
• Communication. To communicate with you, including to respond to your inquiries, provide information, content, and notifications of changes to the Censo App, and to request feedback or completion of a survey or questionnaire
• Personalization. To personalize your experiences with us, including to remember your interests and preferences, customize the content we provide to you or the content, product, and service recommendations we make to you, facilitate your interactions with us, track and categorize your activity and interests on the Censo App, and enrich your experience on the Censo App
• Analytics. To provide, operate, develop, analyze and improve the Censo App, including through surveys and other user research and analytics tools
• Our Business Purposes. For our business purposes, such as to meet our contractual and legal obligations, operate and improve on our lawful business activities, and detect and prevent misuse of our products and services and activities that may violate our policies, pose safety issues, or be fraudulent or illegal
• Legal and Safety Purposes. For legal and safety purposes, including to defend or protect us, you, or others from harm or in legal proceedings, protect our rights, protect our security and the security of our systems and customers, respond to court orders, lawsuits, subpoenas, and government requests, address legal and regulatory compliance, comply with our license obligations, enforce the Terms, or notify you of product recalls or safety issues
• Anonymized Information. To collect, process, and create anonymized information, whether ourselves or through a service provider or other third party, and to use and allow any party to use for any purpose that anonymized information
• Aggregated Information. To collect, process, and create aggregated information, whether ourselves or through a service provider or other third party, and to use and allow any party to use for any purpose that aggregated information
• Other Reasons With Your Consent. For any other purpose for which you provide your consent to us or request that we process your information

Sharing Your Information with Other Parties

We will not share your information with third parties other than in limited circumstances and subject to applicable law, including:

• Our Service Providers. When companies perform services on our behalf, such as fulfilling transactions, monitoring compliance with and enforcing our Terms, auditing interactions and transactions with users, detecting and preventing fraud, addressing security issues, fixing errors, helping us with advertising and marketing, maintaining accounts, providing customer service, helping with our internal research and development, verifying product and service quality or safety, and performing any of the other actions or activities allowed under this Privacy Policy. These companies may not use your personal information for purposes other than those we request or as required by law
• Change of Control. As part of a corporate transaction, such as a merger or sale of assets, divestiture, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, or dissolution. In such event, your information can be used subsequently by the other party or parties involved in that business transaction
• Analytics. For analytics, including to understand how you use the Censo App, determine how you access the Censo App, and improve the Censo App
• Compliance With Law. To comply with legal processes or applicable law, to enforce or apply the Terms, to ensure the safety and security of us, our users, and third parties, to protect our rights and property and those of our users and third parties, and in other cases where we have a good faith belief that disclosure is required by law
• Anonymized and Aggregated Information. We can disclose anonymized information and aggregated information to any party for any purpose
• Other Reasons With Your Consent. For any other purpose for which you provide your consent to us or request that we process your information

You can choose not to disclose certain information. Please see “Your Choices Regarding Your Personal Information”, "Cookies and Other Online Tracking Technologies; Do Not Track," “Children's Privacy,” and “How to Contact Us” below.

Your Choices Regarding Your Personal Information

You have choices about our collection and use of your information which you can exercise by . contacting us through the Censo App. For example, you can:

• Change Your Information. Make changes to your information, such as re-scanning your face. We may take reasonable steps to verify your identity before providing access to your information or making changes to it.
• Change Your Communication Preferences. Make changes regarding receiving notices from us by changing your preferences for the Censo App on your mobile device
• Withdraw Consent. Withdraw your consent to our use or disclosure of your information by contacting us through the Censo App. We will respond to requests to control your personal information as required by applicable law.

In some circumstances, your ability to access or control your information will be limited, as required or permitted by applicable law. Please be aware that if you do not provide your Facial Scan, we will not be able to provide the Censo App to you.

Cookies and Other Online Tracking Technologies; Do Not Track

We do not use Cookies or other online tracking technologies in connection with your use of the Censo App.

Children's Privacy

We do not knowingly collect personal information from individuals under age thirteen (13). If you are under age thirteen (13), please do not access, use, or submit any personal information through or in connection with the Censo App. If you have reason to believe that we may have accidentally received personal information from an individual under age thirteen (13), please immediately email us at info@censo.co.

How We Protect Your Information

We take physical, technological, and administrative measures to protect the information that you provide through or in connection with the Censo App from accidental or unlawful destruction, loss, or alteration, and from unauthorized access, use, or disclosure. Please be aware, however, that no security measures can guarantee absolute security. No Internet, text message, email, or application transmission or method of electronic storage is ever fully secure or error free. Text message, email, and other communications, including those sent through the Censo App, may not be secure. You should use caution whenever submitting information through or in connection with the Censo App and take special care in deciding which information you provide to us.

Storage

By using or visiting the Censo App, your personal information will be transferred to and processed in the United States and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different from the laws and protections in your country.

Retention

We will retain your Facial Scan for as long as reasonably necessary for the Authentication Purpose or until ninety (90) days after you terminate your subscription to the Censo App whichever occurs first. For more information, please see our Data Retention Policy https://censo.co/legal/data-retention.

To determine the appropriate retention period for the categories of your personal information, we consider the amount, nature, and type of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Residents of Europe

This section of our Privacy Policy provides certain required information to persons located in the European Union (“EU”), a European Economic Area (“EEA”) member state, or the United Kingdom (“UK”), and to persons with respect to whom the processing of their personal information may have actual or potential effects in Switzerland. Before we collect any personal information, you are entitled under the General Data Protection Regulation (“GDPR”), the United Kingdom General Data Protection Regulation (“UK-GDPR”) and the revised Swiss Federal Act on Data Protection (“revFADP”) to the information in this section of our Privacy Policy.

Legal Basis for Processing

We will only process your personal information when we have a lawful basis for doing so and only for the purposes set forth in this Privacy Policy. We may also seek your prior consent or rely on some other lawful basis to process your personal information.

Additional Rights

If you use our sites and are located in the EU, an EEA member state, or the UK, or the processing of your personal information may have actual or potential effects in Switzerland, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

• The right to access. You have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. We may charge a reasonable fee based on administrative cost.
• The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to erasure. You have the right to ask us to erase your personal information in certain circumstances, including your personal information must be erased to comply with a legal obligation under EU, an EEA member state, UK, or Swiss law.
• The right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we no longer need the personal information for the purposes of the processing but you require such personal information for the establishment, exercise, or defense of a legal claim.
• The right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you.
• The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you believe your rights under the UK-GDPR have been violated, the UK-GDPR gives you the right to file a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/data-protection-complaints/personal-information-complaint/. If you believe your rights under the revFADP have been violated, you have the right to enforce your claims in court or to file a complaint with the competent data protection authority.
• The right to withdraw consent. If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of information by contacting us at info@censo.co.
• The right to object to processing. You have the right to object to the processing of your personal information that is based on legitimate interests. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests or which override your rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us at info@censo.co.
• Automated decision-making. To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

To exercise these rights please contact us through the Censo App or at info@censo.co. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.

Cross-Border Transfers of Personal Information

Personal information that you provide while in the EU, an EEA member state, the UK, or Switzerland will be transferred to the United States. The GDPR, the UK-GDPR, and the revFADP permit such transfer when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective of your privacy as those in your location. When we transfer personal information from the EU, an EEA member state, the UK, or Switzerland, we will use various legal mechanisms, including contracts such as the standard contractual clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights.

Retention of Your Personal Information

We will retain your personal information as described in “Retention” above.

How To Contact Us

If you have any questions or comments about this Privacy Policy, please contact us as follows.

Email: info@censo.co
Phone: 646.688.4722

Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time. If we update or modify this Privacy Policy, you will be required to accept the updated or modified Privacy Policy in order to continue using the Censo App. If you do not agree to the updated or modified Privacy Policy, you may not continue to access or use the Censo App. This Privacy Policy was made effective on the date indicated above.

Conflicts

If any of the terms of this Privacy Policy conflict with any of the terms of the App Terms, the terms of this Privacy Policy shall control with respect to the subject matter of this Privacy Policy.