Privacy Policy

Last Revised on January 16, 2023

This Privacy Policy for Strange Loop Labs AG (“Company”, “we”, “us”, or “our”) describes how we collect, use, and disclose information about users of the Company’s website (celestia.org) and any other applications, services, tools and features we operate (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services and for the purpose of applicable data protection laws, we are the data controller.

As we are committed to protect and respect your privacy, the following information will provide you an overview of what happens to your information that we collect, use, and share in connection with the Services and the purposes for which we use it. We are aware of the importance of how your data is handled and we assure you that we observe all applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the Liechtenstein Data Protection Act (DPA). If you have any questions or concerns regarding data protection in connection with your use of Services, you can reach us as the responsible party in accordance with the GDPR. Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access, or download any of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

2. YOUR LEGAL RIGHTS

If you are located in the EEA or the UK, you have certain rights in relation to your personal information:

We will not refuse any requests submitted by you to exercise your rights without a legal reason.

We will consider all requests to exercise your rights and provide our response without undue delay (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law).

Certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request.

We may request you provide us with information necessary to confirm your identity before responding to any request you make.

3. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect, use, store, and transfer certain categories of information about you from a variety of sources.

Some features of the Services may require you to directly enter certain personal information about yourself. You may elect not to provide this personal information but doing so may prevent you from using or accessing these features. Personal information that you directly submit through our Services may include:

• Basic contact details. Name and email. We collect basic contact details to communicate with you about the Services and send you newsletters with your consent.
• Account information. Username, password, security questions. We collect account information to maintain and secure your account with us in order to provide you with certain Services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Information about your use of the Services. We collect this information to facilitate your engagement with the Services, monitor and analyze trends in connection with the Services and conduct internal research and development as a matter of our legitimate interests.
• Any other information you choose to provide. This includes any other information that you choose to include in communications with us, for example, when sending us an email or completing web forms. We use this information to assess and/or facilitate your engagement with the Services, including to communicate with you about our Services, personalize your experience, monitor, and analyze trends in connection with the Services and conduct internal research and development.

Additionally, we may use any of the above information to investigate and address conduct that may violate any applicable terms of service, comply with legal obligations, cooperate with investigations by law enforcement or other authorities of suspected violations of law, or to pursue or defend against legal claims.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, and tracking technologies (“Tracking Technologies”). Usage Data may include:

• Unique device identifier
• Device type, such as your phone, computer, or tablet
• IP address
• Browser type
• Date and time stamps, such as the date and time you first accessed the Services
• Operating system
• Log data
• Geolocation

We use the information we collect automatically to provide the Services and better understand user interaction with the Services.

We may obtain information about you from third-party sources, and may combine information we receive from you with information we obtain from third-party sources.

Any information we receive from third-party sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 9 below for more information.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, improve and develop the Services and our product offerings, including as we describe in our Terms of Service (https://celestia.org/tos), to enforce any applicable terms of service, to protect or defend the Services, our rights, and the rights of our users or others, and for the purpose of combatting fraud, or to otherwise operate our business.

4. LEGAL BASIS FOR PROCESSING INFORMATION UNDER THE GDPR

We may process information and any other data collected by us under the following conditions:

• Performance of a contract: If necessary for the performance of an agreement with you or for any pre-contractual obligations thereof.
• Legal obligations: If necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: If necessary in order to protect your vital interests or those of another natural person.
• Legitimate interests: If necessary for legitimate interests pursued by the Company.
• Consent: If you have given your consent for us to process information and any other data collected by us for one or more specific purposes.

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 data is a statutory requirement or a contractual or pre-contractual requirement.

5. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• With vendors or other service providers, such as cloud storage providers, security vendors and data analytics vendors in our legitimate interests or to perform a contract with you.
• With our affiliates or otherwise within our corporate group in our legitimate interests or to perform a contract with you. This includes in particular our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In connection with an asset sale, merger, bankruptcy, or other business transaction in our legitimate interests or as required by law.
• To enforce any applicable terms of service.
• To ensure the safety and security of the Company and/or its users in our legitimate interests.
• With professional advisors, such as auditors, law firms, or accounting firms in our legitimate interests or as required by law.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

7. USER GENERATED CONTENT

The Services also include a forum (https://forum.celestia.org/), which users may elect to join and/or participate in. The purpose of these features is to engage in discussions with other users and use the forum as a shared community resource. Through your participation, you may submit information (e.g., messages, photos, webpages, and other information) (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including the Company.

Please note that we do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

8. SOCIAL FEATURES

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access the Company’s pages on certain third-party platforms, such as Discord and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both the Company and the third party may have access to information about you and your use of both the Services and the third-party service. The information that they collect about you can be found in the privacy statements of the respective third-party providers.

9. THIRD PARTY WEBSITES AND LINKS

We may provide links to websites or other online platforms operated by third parties. When you click on a link to any other website or location, you will leave our Service and go to another website, and another entity may collect data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Discord or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

10. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

11. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

12. DATA TRANSFERS

Personal information may be exported outside of the jurisdiction in which you reside. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your personal information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside. You should note that you are not obliged to give your personal information to us, but if you choose not to do so, we may not be able to provide our Services, or your access to our Services may be limited.

13. DATA TRANSFER TO NON-EU COUNTRIES

We use tools and services of companies domiciled outside the EU. If such tools are active and your personal data is being transferred outside the EU, we make sure that the transfer is made only to countries that have been declared as offering an adequate level of protection through a European Commission decision (an “Adequacy Decision”). In absence of an Adequacy Decision, appropriate safeguards are in place and asserted by each contractual party.

14. HOW LONG WE STORE YOUR PERSONAL INFORMATION

Unless a more specific storage period has been specified in this Privacy Policy, your information and data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible obligations for storing your personal data; in the latter case, the deletion will take place after these obligations cease to apply.

15. HOW TO CONTACT US

If you have any questions about this Privacy Policy, including any requests, please use the contact details set out below.

Full name of legal entity: Strange Loop Labs AG
Registration number: FL-0002.638.646-0
Email address: [email protected]
Postal address: Pradafant 11, 9490 Vaduz, Liechtenstein

When you contact us by email, the data you provide (your email address, name, and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context, if the inquiry is assigned to a contract, after the time limits for the term of the contract, otherwise after the storage is no longer necessary, or restrict the processing if there are legal obligations to retain data. The processing of such data is based on Art. 6(1)(b) of the GDPR if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures, and in all other cases based on our legitimate interest in the effective processing of requests addressed to us (Art. 6(1)(f)) or on your agreement (Art. 6(1)(a)).

You have the right to make a complaint at any time to the Liechtenstein’s Data Protection Office (Datenschutzstelle Liechtenstein: Städtle 38, Postfach 684, FL-9490 Vaduz, T +423 236 60 90, [email protected], https://www.datenschutzstelle.li/). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Office, so please contact us in the first instance.