Algorand Foundation Privacy Policy
The purpose of this document ("Privacy Policy") is to inform you of how the Foundation (as defined below) collects, uses, discloses, and otherwise processes personal data in accordance with applicable data protection laws, including (as applicable to you) the EU General Data Protection Regulation (“GDPR”), the UK GDPR and Data Protection Act 2018, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) and other US state privacy laws, and Singapore's Personal Data Protection Act 2012 (collectively, the “Data Protection Laws”). Please take a moment to read this Privacy Policy so that you understand the purposes for which we process your Personal Data.
By interacting with us, submitting information to us or signing up for any promotions or services offered by us (“Services”), you agree and acknowledge that Algorand Foundation US, Inc. (a Delaware corporation), its related corporations and affiliates, (collectively referred to herein as the “Foundation”, "us", "we" or "our"), as well as our respective and/or agents ("Representatives") will collect, use, disclose and share amongst themselves your Personal Data, and disclose such Personal Data to the Foundation’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy, subject to the rights and protections set out in this Privacy Policy and the applicable Data Protection Laws. Certain products offered by our affiliates — including the Pera Wallet application, operated by Pera Wallet, Lda. — are governed by their own privacy policies, which apply to those products instead of this Privacy Policy.
This Privacy Policy supplements but does not supersede any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which the Foundation may have at law to collect, use, disclose and/or process your Personal Data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your Personal Data.
The Foundation reserves, in its sole discretion, the right to revise this Policy at any time and if we change our Privacy Policy, we will post the changes on this page and may place notices on other pages of https://algorand.co/ (the “Site”), so that you may be aware of how we collect, use, disclose and/or process Personal Data. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our Site. Please check the Site regularly for updated information on the handling of your Personal Data.
- YOUR PERSONAL DATA
1.1 In this Privacy Policy, "Personal Data" means all data that falls within the definition of personal information, personal data, personally identifiable information or similar language under any applicable Data Protection Law. For clarity, Personal Data includes online identifiers (such as cookies, session identifiers, device identifiers, IP addresses, and similar technologies) that, alone or in combination with other information, can be used to single out, identify, or re-identify a natural person, even where no name, email, or other directly identifying information is attached.
1.2 Examples of such Personal Data which we collect and/or which you may provide us include (depending on the nature of your interaction with us):
(a) personal details (such as name, gender, date of birth/age, nationality, passport or national ID number, social security number, tax identification number);
(b) contact details (such as address, email address, telephone number, social media account details);
(c) financial details (such as bank information, credit card information, utility bill, credit report, other financial details with respect to “Accredited Investor” verification);
(d) corporate details (such as name, place of registration, registration number, transparency register number, details with respect to articles of association and other similar documents/certificates, details with respect to shareholders and/or beneficial owners (including their personal and contact details)
(e) technical information of the device(s) you us to access our Site and Services, including device identifier(s), advertising identifier(s) (such as IDFA or AAID), operating system, browser type and version, language and time zone settings, IP address, and similar technical information;
(f) log in information (such as email address, password);
(g) your cryptocurrency wallet address(es) used to interact with us, the Algorand Blockchain Network, or our Services, which we treat as Personal Data because it can be linked, directly or indirectly through on-chain transaction history or other information we or our affiliates hold, to you as an identifiable individual; and
(h) information collected automatically about your visit and use of our Site and Services, including cookies, pixel tags, web beacons, local storage values, session identifiers and similar online identifiers; network information such as your IP address and referring URL or domain; and usage information such as pages and content viewed, links clicked, search queries, and dates and times of access.
1.3 To the maximum extent permitted under applicable Data Protection Law, we may anonymise your Personal Data so that it no longer identifies you and you cannot reasonably be re-identified by any party, in which case we shall be entitled to retain, use, disclose, and/or process such anonymised data without restriction, including for business product related reviews. Pseudonymised data (data that can still be linked to you with additional
information) remains Personal Data and is subject to this Privacy Policy and applicable Data Protection Laws.
1.4 In the course of your interaction on the Algorand Blockchain Network, we may also create Personal Data about you, such as records of your interactions with us and details of your transaction history. You acknowledge that information recorded on the Algorand Blockchain Network is publicly accessible and, by the nature of distributed ledger technology, cannot be modified or deleted from the blockchain. Our obligations of deletion, correction, and restriction of processing under this Privacy Policy apply only to Personal Data we hold off-chain.
1.5 In order to comply with international sanctions and applicable regulations for securities and to fight money-laundering or the financing of terrorism, we may need to check any Personal Data provided by you against publicly available databases.
1.6 For the avoidance of doubt, in the event that Data Protection Laws permits the Foundation to collect, use, disclose and/or process your Personal Data without your consent, such permission granted by the law shall continue to apply. - COLLECTION OF PERSONAL DATA
2.1 Generally, your Personal Data may be collected by us in the following ways:
(a) when you contact us via e-mail, telephone or by any other means;
(b) in the ordinary course of our relationship with you;
(c) when we provide you with access to the Algorand Blockchain Network;
(d) where you have manifestly chosen to make such Personal Data public, including via social media profiles;
(e) when we receive your Personal Data from third parties who legally provide it to us, such as background/ credit reference checking agencies or law enforcement agencies;
(f) when you visit any of our websites (including, the Site) or use any features or resources available on or through our websites (including but not limited to applying for the relevant ecosystem grant program and community champion award through links available on the Site). When you visit our website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a website and other technical communications information), some of
which may constitute Personal Data;
(g) when you submit your resume/CV to us for a job application;
(h) when you acquire ALGO Tokens directly from us; and/or
(i) when you submit your Personal Data to us for any other reason.
2.2 When you browse our Site, we automatically collect certain Personal Data through cookies and similar technologies. See §6 below. Where required by applicable Data Protection Laws (including EU ePrivacy / UK PECR), we will only set non-essential cookies after obtaining your prior, informed consent.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information on your dependent, spouse, children and/or parents), by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the further collection, use, disclosure and/or processing by us of their Personal Data, for the purposes contemplated hereunder, and that such consents have not been withdrawn.
2.4 You shall ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and/or services which you have requested. - PURPOSES FOR THE COLLECTION, USE, DISCLOSURE AND/OR PROCESSING OF
PERSONAL DATA
3.1 In general, we collect, use, disclose and/or process your Personal Data for the following purposes:
(a) to provide, maintain and improve our Services, including without limitation ensuring open access to and technical development on the Algorand Blockchain Network, minting and launching the ALGO Tokens, providing long-term governance, community and ecosystem, and being a treasurer of the funds raised;
(b) to help us review, develop, improve, manage the delivery of and to the extent this requires the use of Personal Data, enhance our products and services, including analysing customer behaviour and future customer needs, conducting market research, list processing and data analytics (including by requesting feedback from you or your participation in surveys);
(c) for authentication and verification purposes;
(d) to enable, improve or update information on the use of the Algorand Blockchain Network;
(e) to grant you access to and participate in the governance of Algorand Blockchain
Network;
(f) to enable you to apply to and be considered by the Foundation for operating nodes on Algorand Blockchain Network;
(g) to enable you to apply to and be considered by the Foundation for the relevant grant for building projects on or relating to Algorand Blockchain Network;
(h) to enable you the use of ALGO Tokens;
(i) for the issuance, distribution, use and circulation of or exchange for ALGO Tokens, where you have submitted Personal Data to us for the purposes acquiring of the ALGO Tokens;
(j) specifically, in relation to the processing of your Personal Data:
(i) as may be necessary in connection with any contractual relationship that you may enter into with us;
(ii) as may be required by applicable law;
(iii) as is necessary to protect the vital interests of any individual; and
(iv) where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
(k) to respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
(l) detect, prevent, and address technical issues;
(m) enhance security, monitor and verify identity or service access, combat spam or other malware or security risks;
(n) send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;
(o) detect, prevent and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss;
(p) to handle disputes and conduct and facilitate investigations and proceedings;
(q) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
(r) to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;
(s) to comply with, protect and enforce our contractual and legal rights and obligations;
(t) to commence, respond to, or act in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution);
(u) to match any Personal Data held which relates to you for any of the purposes listed herein;
(v) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sales);
(w) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
(x) where required or permitted by law for any purpose; and/or
(y) for purposes which are reasonably related to the aforesaid.
3.2 In addition, and without prejudice to the generality of the foregoing, if you submit an application to us as a candidate for employment or an internship, or are an existing employee of the Foundation, we collect, use, disclose and/or process your Personal Data for the following purposes:
(a) for management and/or evaluative purposes, including without limitation to process your employment application, to conduct pre-recruitment checks, and/or to provide or obtain employee references or other references where relevant for background screening and/or vetting;
(b) for personnel administration, including to administer benefits and payroll processing, to administer or execute employee remuneration schemes, and/or to his/her employment related work activities;
(c) to enter into an employment relationship with you or to appoint you to any office;
(d) to manage or terminate the employment relationship with you or appoint you, including without limitation role assessment, job compatibility assessment, career progression and/or management of staffing requirements; and/or
(e) for purposes which are reasonably related to the aforesaid.
3.3 Furthermore, and without prejudice to the generality of the foregoing, and where permitted under Data Protection Laws, we may also collect, use, disclose and/or process your Personal Data and/or share your Personal Data with our business partners for any of the following purposes:
(a) providing or marketing services, products and benefits to you, including promotions;
(b) to enable you to apply to and be considered and selected by the Foundation for the relevant marketing initiatives and campaigns for promotion relating to the Foundation and Algorand Blockchain Network (including but not limited to you, if selected by the Foundation, appearing on the relevant Foundation marketing, promotion or community webpage and may be contacted by other members in our communities or any visitor of our websites)
(c) for us or our business partners to inform you via e-mail about upcoming opportunities and promote our respective products and services;
(d) to administer a contest, promotion, survey or other site feature;
(e) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by the Foundation or other third parties; and
(f) conducting research, analysis and development activities (including data analytics, surveys, product and service development and/or profiling), understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
3.4 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose and/or process your Personal Data. If so, we will collect, use, disclose and/or process your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.5 We also reserve the right to monitor, check and process your Personal Data if necessary to investigate or obtain evidence concerning any complain, claim or dispute or any actual or suspected illegal or unlawful conduct or to aid in such investigation or evidence gathering by any law enforcement or regulatory authorities.
3.6 Where the GDPR or UK GDPR applies to your Personal Data, we rely on the following lawful bases under Article 6(1) (and, for special categories, Article 9):
(a) Consent (Art. 6(1)(a)) — for non-essential cookies, marketing communications, and other processing where we expressly request your consent;
(b) Performance of a contract (Art. 6(1)(b)) — to provide the Services you have requested, including access to and use of the Algorand Blockchain Network, ALGO Tokens, and related applications;
(c) Compliance with a legal obligation (Art. 6(1)(c)) — including AML/CFT, sanctions screening, tax reporting, and responses to lawful requests from authorities;
(d) Legitimate interests (Art. 6(1)(f)) — including operating, securing, and improving our Services; detecting and preventing fraud and abuse; defending and exercising legal claims; and internal administration. Our legitimate-interest assessments are available on request. - DISCLOSURE OF PERSONAL DATA
4.1 We may disclose your Personal Data for the purposes set out in this Privacy Policy, where permitted under applicable Data Protection Laws and on one or more of the lawful bases described in §3.6, to the following categories of recipients (some of whom may be located outside your country of residence, including in the United States):
(a) our service providers and contractors, including third-party vendors that provide data processing or management services;
(b) our business partners and members of our communities (and in particular, where you have consented to receiving information/ newsletters/ marketing/ promotion from us);
(c) our group affiliates;
(d) other holders or users of ALGO Tokens;
(e) any person or entity involved in the handling of ALGO Tokens or Services provided to you; and
(f) law enforcement authorities, regulatory authorities, statutory bodies or public agencies for the purposes of complying with their requirements, policies, directives or requests;
(g) banks, credit agencies and other financial and/or payment service providers;
(h) IT-service providers;
(i) members of Algorand Blockchain Network communities (actual or prospective);
(j) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale); and/or
(k) any other party to whom you authorise us to disclose your Personal Data to.
Where a particular disclosure relies on your consent, you may withdraw that consent as described in §3.6 and §8. Withdrawal does not affect the lawfulness of disclosures already made, or disclosures we make on another lawful basis (such as compliance with a legal obligation).
4.2 We may share information about you in aggregate or anonymised form, for example, information regarding business product-related reviews, with the above mentioned entities or parties (e.g. our business partners).
4.3 We operate internationally, and your Personal Data may be transferred to, stored in, or accessed from countries other than your country of residence — including the United States — whose data protection laws may differ from those in your jurisdiction. Where we transfer Personal Data across borders, we take steps to ensure that it continues to be protected in accordance with this Privacy Policy and as required by applicable Data Protection Laws. You may contact us using the details in §8 for more information about how we protect Personal Data when it is transferred internationally. - KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE
We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with products and services you have requested, or processing any requests and applications you may have made to us. - ALGORAND FOUNDATION’S COOKIE POLICY
6.1 Our websites (including our Site) and platforms use cookies and other technologies. Cookies are small text files stored in your computing or other electronic devices when you visit our website (including our Site) and platforms for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website (including our Site) or platform, your browser will read the cookie and relay the information back to the website (including our Site), platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
6.2 Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites (including our Site) or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes.
This technology can also be used for tracking traffic patterns on websites (including our Site) and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
6.3 We may employ cookies and other technologies as follows:
(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
(b) making our websites (including our Site) and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites (including our Site) and platforms;
(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(d) collating information on a user’s search and browsing history;
(e) when you interact with us on our websites (including our Site) and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website (including our Site) or platform, the browser used by a visitor, the operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (which may include for example, information about which pages they have
viewed, the time the pages were accessed and the time spent per web page);
(f) using such information to understand how people use our websites (including our Site) and platforms, and to help us improve their structure and contents;
(g) using cookies that are necessary in order to enable our websites (including our Site) and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites (including our Site) and platforms; and/or
(h) personalising the website (including our Site) and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
6.4 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites (including our Site) and platforms. These companies collect information about your interaction with our websites (including our Site) and platforms. We use such information to compile statistics about visitors who interact with the websites (including our Site), platforms and other Foundation’s online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
6.5 We use only strictly necessary cookies by default. Where required by applicable law (including the EU ePrivacy Directive and the UK Privacy and Electronic Communications Regulations), we will request your prior, informed, freely-given, and specific consent before setting any non-essential cookies or similar technologies — including analytics, functional, and advertising cookies — through a cookie consent banner or preference center. You may grant, refuse, or withdraw your consent at any time, and your refusal to consent to non-essential cookies will not affect your access to the basic functionality of our Site. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
6.6 Disabling strictly necessary cookies may impair core functionality of our Site. Browser controls are independent of, and do not substitute for, the consent obligations set out in §6.5.
6.7 Our cookie consent banner and preference center categorize cookies as follows:
(a) Strictly necessary — required for the Site to function (e.g., authentication, security). No consent required.
(b) Functional — enable enhanced features and personalization. Consent required.
(c) Analytics / performance — help us understand how visitors use the Site. Consent required. See §6.8 for details of the analytics tools we use and their data flows.
(d) Advertising / targeting — used to deliver advertisements and measure their effectiveness. Consent required. - THIRD-PARTY INFORMATION
Certain links contained on the Site may direct you to co-branded websites maintained by the Foundation or to companies which the Foundation has established business relationships. When you submit information to one of these co-branded sites or partner companies, you may be submitting it to both the Foundation and these business partners. This Privacy Policy does not apply to any information that you may provide to third parties, such as through other sites linked to the Site. The Foundation is not responsible for those sites and cannot control the content of what is offered on those sites, or links from those sites, or the privacy policy or data security, if any, of those sites, and we therefore strongly encourage you to read their respective privacy policies as they may differ from ours. - CONTACTING US – WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR
PERSONAL DATA
8.1 If you:
(a) have any questions or feedback relating to your Personal Data or about this Privacy Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy;
(c) would like to obtain access or correction of your Personal Data;
(d) would like to exercise any of the additional rights described in §§8.4–8.5 below; or
(e) wish to lodge a complaint, please contact us as follows:
By mail : Algorand Foundation US, Inc., 1216 Broadway, Floor 2, PMB 1012 New York, NY 10001 United States
By email: personal.data@algorand.foundation, people@algorand.foundation or legal@algorand.foundation
8.2 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to the Foundation on your behalf.
8.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, the Foundation may not be in a position to continue to provide its products and services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with the Foundation, and your being in breach of your contractual obligations or undertakings the Foundation’s legal rights and remedies in such event are expressly reserved.
8.4 Where the GDPR or UK GDPR applies to your Personal Data, you have the following.rights, subject to the conditions and exceptions in those laws:
(a) Right of access (Art. 15) — to obtain confirmation of whether we process your Personal Data and a copy of that data;
(b) Right to rectification (Art. 16) — to have inaccurate Personal Data corrected;
(c) Right to erasure / 'right to be forgotten' (Art. 17) — to have your Personal Data deleted in defined circumstances. As noted in §1.4, this applies to off-chain data only; on-chain records cannot be modified or deleted;
(d) Right to restriction of processing (Art. 18);
(e) Right to data portability (Art. 20) — to receive your Personal Data in a structured, commonly used, machine-readable format;
(f) Right to object (Art. 21) — including to processing based on legitimate interests and to direct marketing;
(g) Right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you (Art. 22). See §11.
(h) Right to withdraw consent at any time where processing is based on consent (Art.7(3));
(i) Right to lodge a complaint with a data protection supervisory authority. EU users may contact the supervisory authority in their EU Member State; UK users may contact the UK Information Commissioner's Office (ICO).
8.5 Where US state privacy laws apply (including the CCPA/CPRA in California and equivalent laws in other states), you have rights that may include:
(a) Right to know what Personal Information we have collected about you and how it has been used and disclosed;
(b) Right to delete Personal Information we have collected from you, subject to exceptions;
(c) Right to correct inaccurate Personal Information;
(d) Right to opt out of the “sale” or “sharing for cross-context behavioral advertising” of your Personal Information. The Foundation does not sell Personal Information for money. Where any of our analytics or advertising tools constitute “sharing” under the CCPA/CPRA, you may opt out via the “Do Not Sell or Share My Personal Information” link / cookie preference center;
(e) Right to limit the use and disclosure of sensitive Personal Information;
(f) Right to non-discrimination for exercising your privacy rights.
Authorized agents may submit requests on your behalf where permitted by applicable law. We may verify your identity before responding to a request. We will respond within the timeframes required by applicable law.
8.5 If you are in Singapore, your rights under the Singapore Personal Data Protection Act 2012 continue to apply, including the right to access and correction of your Personal Data and the right to withdraw consent. To exercise these rights, please contact us using the details above. - GOVERNING LAW
This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of laws principles. Notwithstanding the foregoing, nothing in this section deprives you of the protection of the mandatory provisions of the data protection law applicable in your place of residence, and the following apply where mandated by applicable law:
(a) if you are located in the European Economic Area, the GDPR governs the processing of your Personal Data and you may lodge a complaint with your national supervisory authority;
(b) if you are located in the United Kingdom, the UK GDPR and the Data Protection Act 2018 govern, and you may complain to the UK Information Commissioner's Office;
(c) if you are a resident of California or another US state with applicable privacy legislation, that state's privacy law governs the rights afforded to you under §8; and
(d) if you are located in Singapore, the Singapore Personal Data Protection Act 2012 governs the processing of your Personal Data.