Last updated: April 17, 2023
Welcome to Exponential. Exponential DeFi Inc. doing business as Exponential (“Exponential,” “we”, “us”, or “our”) owns and operates the website located at exponential.fi (the “Website” and collectively with any connected software, mobile application or other products the “Site”).
Collecting and Using Your Personal Data
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
Tracking Technologies and Cookies
- Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available here.
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
Tracking and Performance Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
Use of Your Personal Data
We do not rent or sell your Personal Data (such as name, address, telephone number) to third parties for their marketing purposes.
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
- To engage in internal research: to understand the effectiveness of our Service, improve our Service, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in aggregate form such that individual users cannot be identified.
- To help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Service.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
- To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage your requests: To attend and manage your requests to Us.
- For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
- For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share your personal information in the following situations:
- With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to contact you.
- For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
- With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
- With your consent: We may disclose your personal information for any other purpose with your consent.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email We send or by contacting us.
We may use Email Marketing Service Providers to manage and send emails to you.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise Your rights.
- Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of Your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing Your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, We may not be able to provide you with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
California Privacy Rights
Exponential has collected the following categories of California Personal Information within the last 12 months from the sources listed below:
- Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties, and public databases.
- Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, credit card number, debit card number, or other payment information. This category of information is collected from you directly.
- Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. This category of information is collected from you when you choose to provide it to us directly or indirectly through our service providers and business partners as part of our surveys and market research.
- Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you and your devices.
- Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a California Party's interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
- Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
- Inferences, such as a profile about a California Party's preferences, characteristics, and behavior, drawn from information Exponential collects and insights Exponential receives from third parties such as our marketing and advertising partners and data analytics providers.
- Sensitive personal information, such as account login information allowing access to an account, precise geolocation data, race, and ethnicity, in each case as further described above in the relevant categories. Please note Exponential does not collect sensitive personal information for the purpose of inferring characteristics about you.
For each of the above categories, Exponential uses the California Personal Information for a variety of business purposes such as:
- Helping to ensure security and integrity to the extent the use of a Consumer's personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors in our systems;
- Short-term, transient use including contextual non-personalized advertising shown as part of a California Party's current interaction with us;
- Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- Conducting internal research to develop and demonstrate technology;
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which Exponential may own, control, or provide; and
- Other business purposes described in the “Collecting and Using Your Personal Data” Section.
- Exponential may also use the information Exponential collects for our own or our service providers' other operational purposes, purposes for which Exponential provides you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
Within the last 12 months, Exponential has disclosed California Personal Information for our business purposes. To learn more about the categories of third parties with whom Exponential shares such information, please see the “Collecting and Using Your Personal Data” Section.
If you are a California Party, you have certain rights related to your California Personal Information, including:
- The right to know what California Personal Information Exponential has collected about you, including the categories of personal information, the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom Exponential discloses California Personal Information, and the specific pieces of California Personal Information Exponential has collected about you.
- The right to correct inaccurate California Personal Information that Exponential has collected about you.
- The right to delete California Personal Information that Exponential has collected from you, subject to certain exceptions. For example, Exponential may not be able to delete your information if such information is subject to the Fair Credit Reporting Act.
- The right to opt out of the sale or the sharing of California Personal Information.
- Exponential does not sell California Personal Information, but if you wish to opt out of the sharing of California Personal Information in the future, please contact us via one of the methods outlined under the “Contact Us” section below.
- The right to limit the use or disclosure of your sensitive personal information. Exponential does not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information.
- The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.
As required under applicable law, Exponential will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. Exponential may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. Exponential may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, Exponential will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Exponential will require the agent to provide proof of that written permission. To the extent permitted by law, Exponential may require you to verify your own identity in response to a request, even if you choose to use an agent.
If you are an authorized agent submitting a request on behalf of a California Party, please make a request as outlined below under “Contact Us”.
If you are a resident of a state in which state-level privacy law is enacted (e.g., Colorado, Connecticut, Utah or Virginia), additional rights described in this Section may apply to you as applicable law comes into effect. You may have the following rights, in each case to the extent set out in applicable law:
- The right to confirm whether Exponential processes personal information about you and requests access to such personal information (including, if applicable, in a portable and readily usable format).
- The right to correct inaccuracies in certain personal information Exponential may hold about you; and
- The right to request that Exponential delete personal information collected from or about you.
- You may request to exercise these rights by contacting Exponential via the methods noted under “Contact Us” below. If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how you may exercise them.
Exponential does not sell personal information, but if you wish to opt out of the sharing of personal information in the future, please contact us via one of the methods outlined under the “Contact Us” section below.
As required under applicable law, Exponential will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. Exponential may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. Exponential may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights described above, Exponential will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under applicable law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Exponential will require the agent to provide proof of that written permission. To the extent permitted by law, Exponential may require you to verify your own identity in response to a request, even if you choose to use an agent. If you are an authorized agent submitting a request on behalf of a consumer, please make a request as outlined below under “Contact Us”.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
The opt out will place a cookie on Your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on Your mobile device.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.