Thank you for using Token Markets, a product of Tokenly, Inc.

This Privacy Policy (the “Policy”) lets store owners and customers (collectively “you”) know how Tokenly, Inc. ("we" or "us" or “Company”) collects, processes, retains and shares information provided to us for use on the Tokenly Markets ecommerce website located at https://TokenMarkets.com/ (the "Platform"). The Platform allows store owners to sell tangible and digital products and services to customers (the “Services”). The Company is committed to respecting the privacy rights of store owners, customers and other visitors. This Policy covers your choices regarding the sharing of your information on the Platform and while using the Services offered by the Company.

Personal Information

In operating the Platform, the Company may require you to register for an account to utilize the Services. Store owners must create an account to sell products and services on the Platform. Customers, however, are allowed to complete a purchase on the Platform using a guest checkout feature, understanding that some Personal Information will still be collected at the point of sale, as described in the Uses of Information section of this Policy. When opening an account, the Company will collect personal information from you, such as your full name, email address, phone number, preferred payment information (such as your bitcoin wallet address, account information for PayPal or other third party payment processor, or credit card information), billing address, shipping address, and other information that may be used to personally identify you (collectively “Personal Information”). We will only collect data from third party payment processors like PayPal with your authorization and consent, solely for the purpose of completing a purchase and sale transaction on the Platform. As described below, Personal Information does not include any anonymized aggregated data that is collected for analysis and reporting purposes.

The specific Personal Information collected on the Platform depends on whether you are a store owner selling products and services or a customer buying products and services. We will use your Personal Information to provide the Services to you according to this Policy and the Store Owner Terms of Use or the Customer Terms of Use, as applicable. We will not share your Personal Information except as provided for in this Policy.

In some situations, either the Company or the store owner may need to request additional information from you in order for you to complete a purchase or sale transaction. We may also collect additional information from you when you contact us for customer service issues or when responding to Company surveys.

Purposes of collecting Personal Information

We use the Personal Information you provide for the specific purposes of:

• Tracking, processing, confirming and completing online orders and payments between store owners and customers;
• Delivering downloadable content to customers, as applicable when such content is provided to us from store owners;
• Providing customer service and troubleshooting issues;
• Monitoring for any prohibited or illegal activities on the Platform in violation of our terms of use;
• Creating connections between your Platform account and any accounts that you may wish to link from third-party platforms, such as PayPal;
• Delivering transaction notices to you;
• Offering new products and services;
• Improving the effectiveness of the Platform, the Services, and our marketing efforts;
• Conducting research and analysis; and
• Sending marketing communications.

You may choose to not provide us with Personal Information or any requested additional information, understanding that your ability to use the Platform and the Services may be impacted if you do not provide the minimum information necessary to complete a transaction on the Platform.

Customers and store owners may also share catalog listings from the Platform to other social media platforms. If you choose to share a catalog listing outside of the Platform, you may be required to login to such other social media platforms via a pop-up window outside of the Company’s Platform. We will not have access to your account information for other such social media sites nor will we collect any data on where you shared the posted content. Once you make such a post, your rights to your content will be governed by such third-party’s terms of use. With your consent, we may also obtain Personal Information and non-Personal Information from third party providers.

If you provide us Personal Information about others, or if others give us your Personal Information, we may store that data and will only use that Personal Information for the specific purpose of delivering goods, services or digital content. An example is when a customer provides a friend's shipping address for a purchased item to be shipped directly to such friend.

Usage and Other Information

When you use our Services, we collect usage data and other information regarding your communications, transaction history and interactions with the Platform and other users using cookies (see the “Cookies” section below) or other similar technology. With your consent, we may also access and collect information from your mobile device related to your location.

The Platform is supported by a network of computers, cloud-based servers and other infrastructure and information technology, including but not limited to, third-party service providers. Your Personal Information is processed within and outside of the United States. By using the Platform and Services you consent to your Personal Information possibly being transferred and processed outside of the United States, even to countries that have different data protection rules and requirements than your country of residence, subject to the transfer restrictions set forth in the General Data Protection Regulation (“GDPR”) specifically limiting transfers to countries identified on the Official Journal of the European Union website as having adequate levels of data protection policies.

Log Data

We collect information that your device sends whenever you visit the Platform (“Log Data”). This Log Data may include information such as your device's Internet Protocol (“IP”) address, details about how you used the Platform, the time and date of your visit, your location, the time spent on the Platform and other statistics. You may choose to not have us collect this information, understanding that it may impact your ability to use the Platform and the Services. The Log Data is retained by the Company for a period of six (6) months from the date it is collected.

Cookies

From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Platform and your use of the Services. We only store Personal Information in cookies to identify you as a user and to enhance and customize the Services provided to you on the Platform. Cookies also allow us to learn which areas of our Platform are useful and which areas need improvement, and cookies provide us with marketing data for analysis. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this functionality, your experience on the Platform may be diminished and some features may not work as intended.

Do Not Track (DNT) is an optional browser setting that allows you to limit your sharing preferences with respect to third parties. We do not respond to DNT signals.

Your Elections

We may communicate with you through multiple channels about your purchase and sale transactions and to keep you up-to-date on promotions, offers, customer experience content and new products or services. We may also use the information you provide to send you marketing communications.

Once you provide your Personal Information, we may contact you through e-mail or text messages, if you choose to provide your mobile telephone number. We may continue to communicate with you through the channels you have selected until you request to stop receiving these communications by opting out. Before sending you mobile marketing messages, we will require your express consent by requesting that you opt-in during your account setup process or upon a customer using the guest checkout feature.

At any time, you may elect to (a) stop receiving marketing communications, or (b) update or delete your account and any Personal Information details.

Uses of Information

We use information about you to provide the Services of fulfilling your purchase and sale transactions and for other business purposes described in the Personal Information section of this Policy.

In order for a store owner to list products or services for sale on the Platform or for a customer to buy products or services, each such user will need to share some Personal Information with the Company and with other users. Your shipping address will also need to be shared with a store owner for shipping and delivery purposes when you purchase a physical product from a store owner. Payment information that is provided to the Company from store owners and customers, however, is not shared with any other users without your consent.

We do not sell, rent or trade your individual Personal Information to third parties without your consent. We may, however, share, sell or rent aggregated data with third parties for analysis and research purposes. This aggregated data would only consist of anonymized data.

Your Personal Information may be shared with current or future affiliates or subsidiaries of the Company.

In limited circumstances, we may need to share your Personal Information with third parties that perform services on our behalf, such as PayPal or other third-party payment processor, to complete a purchase and sale transaction on the Platform. In order for the Company connect your Platform account with your account from a third-party platform like PayPal, we will require your affirmative consent, understanding that your Personal Information may be shared with such third-party platforms.

From time to time, we may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may share Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves. We may also transfer Personal Information in the event of a corporate sale, merger, acquisition, dissolution or similar event.

Any personally identifiable information you submit to another user or in a comment or forum, as applicable, on the Platform, can be read, collected, or used by the public and other users, and could be used to send you unsolicited messages. We recommend that you do not provide your full name, e-mail address or any other Personal Information in this manner. While you may need to share your contact information with other users when discussing an item listed for sale, please note that if you choose to do so, it is at your own risk. You accept full responsibility for those posts and any consequences that may arise from posting or sharing such information.

Your Personal Information is retained as long as you are continuing to use the Platform and the Services. If you decide to close your account, the Company will continue to store and share your Personal Information as described in this Policy unless you provide a written request to support@tokenly.com to have your Personal Information deleted, understanding that the Company shall retain copies of all invoices generated on the Platform (regardless whether a purchase and sale was completed on such invoice) for the Company’s record keeping purposes.

Third Party Websites

At times we may partner with a third party to create a site that may look as if you are on a Company page. These sites may be co-branded or may have the look and feel of being on the Platform. However, the information collected on these pages may not be covered under our Policy. It is your responsibility to review the privacy policies of those websites to confirm that you understand and agree with their policies.

Information from Children Under 13

We are a general audience website and do not direct any of our content specifically at children under the age of 13 years old. We understand and are committed to respecting the sensitive nature of children’s privacy online and we do not knowingly collect information online from children under 13. If you are a parent or guardian and you learn that your children have created an account or otherwise provided Company with Personal Information, please contact us. If Company becomes aware that Company has collected Personal Information from a child under age 13 without verification of parental consent, Company will take steps to remove that information from Company servers.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, information with respect to the types of Personal Information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

To request a copy of the information disclosure provided by the Company pursuant to Section 1798.83 of the California Civil Code, please contact support@tokenly.

European Union’s General Data Protection Regulation

Residents of the European Union have the right under the GDPR to request from a business, with whom the European Union resident has an established business relationship, information with respect to the types of Personal Information the business collects and processes. Further, such residents of the European Union may also request a portable copy of such resident’s Personal Information collected by the business and may also request changes to any incorrect Personal Information collected. Such residents may also restrict a business’s processing activities and sharing of Personal Information with third-parties and may request that such resident’s Personal Information be deleted altogether.

To request such information from the Company pursuant to the GDPR, please contact support@tokenly.

Security of Your Personal Information

We use reasonable security measures, including but not limited to physical, electronic, and procedural safeguards, to protect the confidentiality of Personal Information under our control and appropriately limit access to Personal Information, including Secure Sockets Layer (“SSL”) protection technology (see "Safe Shopping Policy” below).

The Platform has security measures in place to prevent the loss, misuse, disclosure and alteration of the Personal Information that we obtain from you, but we make no assurances to you or to any third party about our ability to prevent any such loss or misuse arising out of any such loss, misuse, disclosure or alteration.

We also avoid storing your user passwords in plain text. Information that you provide us for credit card transactions is stored with external merchant processors. While we use the security measures described above along with others, we cannot ensure or warrant the security of any information you transmit to us by e-mail, and you do so at your own risk.

If we become aware of a security breach involving your Personal Information, we may need to notify you electronically of such breach, in addition to posting information about the breach on the Platform or Company website. By using the Platform and Services, you agree to receive such communications. Please contact us as support@tokenly if you would like to withdraw your consent to receiving such communications or to request a free written notice of a security breach from the Company, upon providing us with a mailing address, as applicable.

Safe Shopping Policy

We use a variety of information security measures to protect your online transactions with us. The Platform uses encryption technology, such as SSL, to protect your Personal Information during data transport. SSL protects information you submit via the Platform such as ordering information including your name, address and credit card number.

Privacy Policy Changes

As we continue to improve the Platform and Services, products and the features we provide, this Policy is subject to change. We will post significant changes to this Policy here and/or other formats for you to review. If we change our information practices or this Policy in such a way that your Personal Information may be used or shared in a manner not described in the Policy at the time you provided it, we will give you the opportunity to opt-out of having your Personal Information used or shared in that new manner.

How To Contact Us

If you have questions about our Privacy Policy, please contact us at:

Tokenly, Inc.

support@tokenly.com

Last updated: June 7, 2018