Soho Technologies Privacy Policy

Effective as of April 26, 2023.        

This “Privacy Policy” describes the privacy practices of Soho Technologies, Inc. and our subsidiaries and affiliates (collectively, “Soho”, “we”, “us”, or “our”) in connection with the website, the Soho mobile application, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.   Soho may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Service or otherwise includes:

Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from NFT marketplaces.  Our Services are designed to monitor transactions taking place on various NFT platforms we support.  We may therefore collect information related to publicly available NFT transactions taking place on the blockchain.

Cookies and Other Information Collected by Automated Means  

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited,  your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Referrals

Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service.  We use your personal information to:

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.  We may send you Soho-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below. 

To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. We will publicly display within the Services your username, groups/channels you join on the Services, and social media handle(s) you provide in your profile.  We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.  

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices 

In this section, we describe the rights and choices available to all users.

Opt out of marketing 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 at support@soho.xyz.  

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. 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 Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

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” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Other sites, mobile applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security practices

The security of your personal information is important to us.  We employ a number of organizational, technical 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.

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.  

Children

As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as anyone under 13 years old.If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy 

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. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to support@soho.xyz. You may also write to us via postal mail at:

Soho Technologies, Inc.

Attn: Legal – Privacy

379 West Broadway, Floor 2

New York, NY 10012

        

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at 379 West Broadway, 2nd Floor, New York, NY 10013. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Appendix A

Platform Terms

Last Updated 5/7/19

Facebook Platform Policies (Last updated 4/25/19)

Terms that Relate Specifically to Developer’s Privacy Policy and/or Must Be Included in Developer’s Privacy Policy:

1.          Provide a publicly available and easily accessible privacy policy that explains what data you are collecting and how you will use that that data (§2.4.a)

2.        Your privacy policy must not modify, supersede, or be inconsistent with Facebook policies.  For example, user data obtained from us cannot be transferred to a data broker or sold, even if you disclose this in your privacy policy. (§2.4.b)

3.        Include your privacy policy URL in the App Dashboard. (§2.4.c)

4.        Link to your privacy policy in any app store that allows you to do so. (§2.4.d)

5.        Comply with your privacy policy. (§2.4.e)

6.        You may use Account Information in accordance with your privacy policy and other Facebook policies. (§2.5)

7.        If you stop using Platform, promptly delete all user data you have received from us (absent explicit consent from people). You can keep Account Information if you have presented your privacy policy within your app. (§3.13)

8.        If people log in with email addresses or phone numbers, your use of that data is subject to your privacy policy and any applicable law or regulation. (§18.1)

The Facebook Platform Policy is available at https://developers.facebook.com/policy/.

Google APIs Terms of Service (Last updated 1/16/19):

 

Terms that Relate Specifically to Developer’s Privacy Policy and/or Must be Included in Developer’s Privacy Policy:

1.        You will comply with all applicable privacy laws and regulations including those applying to PII. (§3.d)

2.        You will provide and adhere to a privacy policy for your API Client that clearly and accurately describes to users of your API Client what user information you collect and how you use and share such information (including for advertising) with Google and third parties. (§3.d)

The Google APIs Terms of Service is available at https://developers.google.com/terms/.  See also Google Privacy Guidance at https://developers.google.com/actions/policies/privacy-policy-guide and the Google API Services: User Data Policy, which governs the use of Google API Services when a developer requests access to Google user data, available at https://developers.google.com/terms/api-services-user-data-policy.  

Twitter Developer Policy (Last updated 11/3/17)

Terms that Relate Specifically to Developer’s Privacy Policy and/or Must Be Included in Developer’s Privacy Policy:

1.        Display your privacy policy to users before download, installation or sign up of your application. (§I.C.7)

2.        Your privacy policy must be consistent with all applicable laws, and must be no less protective of end users than Twitter’s privacy policy located at https://twitter.com/privacy including any relevant incorporated policies such as the supplemental terms located at https://support.twitter.com/articles/20172501. (§I.C.7)

3.        You must comply with your privacy policy, which must clearly disclose the information you collect from users, how you use and share that information (including with Twitter), and how users can contact you with inquires and requests regarding their information.  (§I.C.7)

4.          If for any reason your are unable to comply with your privacy policy or any privacy requirement of the Developer Agreement or Policy, you must promptly inform Twitter and take reasonable and appropriate steps to remedy any non-compliance, or cease your access to the Twitter API and use of all Twitter Content. (§I.C.7)

5.        If your Service uses Cookies, disclose in your privacy policy: (a) whether third parties collect user information on your Service and across other websites or online services; (b) information about user options for cookie management and whether you honor the Do Not Track setting in supporting web browsers. (§I.C.8)

6.        If your Service adds location information to users’ Tweets or Periscope Broadcasts: (a) disclose when you add location information, whether as a geotag or annotations data, and whether you add a place or specific coordinates. (§I.C.9)

The Twitter Developer Policy is available at: https://developer.twitter.com/en/developer-terms/policy.html.  See also the Twitter Developer Agreement, available at: https://developer.twitter.com/en/developer-terms/agreement.

LinkedIn API Terms of Use (Last Updated 3/25/19)

Terms that Relate Specifically to Developer’s Privacy Policy and/or Must Be Included in Developer’s Privacy Policy:

1.        Your application must include your own user agreement and privacy policy. (§5.1)

2.        Your user agreement and privacy policy must be prominently identified or located where members download or access your Application. (§5.1)

3.        Your privacy practices must meet applicable legal standards and accurately disclose the collection, use, storage and sharing of data. (§5.1)

4.        If your Application is an enterprise application, you must enter into customer agreements with your enterprise customers that describe how you will be accessing LinkedIn accounts and Content on the customer’s behalf. (§5.1)

5.        You must promptly notify LinkedIn of any breaches of your user agreement or privacy policy that impact or may impact LinkedIn Members. (§5.1)

6.        Your privacy policy must be at least as stringent and user-friendly as LinkedIn’s. (§5.1)

7.        Before obtaining information from LinkedIn Members, you must obtain their legally valid consent which, at a minimum, shall include: (a) how their data will be used, (b) when it will be collected (e.g. will the Application pull a Member’s Profile Data more than once); and (c) how a user can withdraw their consent.  The consent must be freely given (in accordance with applicable law) and given by a statement or a clear affirmative action.  When a particular Member’s Member token and OAuth Access Token expires, you must obtain that Member’s consent again in order to continue to collect and store their data. (§5.2)

The LinkedIn API Terms of Use is available at: https://developer.linkedin.com/legal/api-terms-of-use#.  See also LinkedIn Specifications for Obtaining Consent to Store Profile Data, available at https://legal.linkedin.com/storing-member-data and Plugin Terms of Use, available at: https://developer.linkedin.com/legal/plugin-terms-of-use.

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