Privacy Policy

April 1, 2023

1. Overview

This privacy notice applies to Found Onchain Inc. (“Found”) and describes how we collect, use, and share information about you collected via this website (the “Site”). If you choose to register or provide information (the “Data”) to Found through or on the Site, you agree to the use of the Data in accordance with this privacy notice (the “Agreement”). Found is not a law firm and does not provide legal advice. If you are concerned your legal rights may be impacted, you should seek the advice of your own legal counsel.

2. Information Collection

Found provides tokenized real-world asset (“RWA”) solutions for sellers and buyers of bankruptcy claims. As part of our products and services, we create, configure, and pages on this Site and provide access to data storage. Site visitors may access information and, in certain circumstances, submit claims, claim information, account information, identification information, bankruptcy ballots, rights offering subscription forms, or similar bankruptcy plan participation documents or inquiries relating to the matters for which we are providing support services and solutions for our users.

We collect certain personal information, oftentimes from the user or site visitor, before allowing access to certain information provided through gated access to this Site. Among other things, we may collect the following data: name, personal identification information (including mailing address, telephone numbers, and official government documents), third party passwords, email addresses, and information related to client or agent representation in an organization. We also collect information about visitor usage of the Site including, without limitation, the amount of time a visitor spends on a user-dedicated page, the reports the user/visitor accesses, and other activities in which the visitor engages in while on the Site. This information may be collected using log files and/or cookies, web beacons, local shared objects (or Flash cookies), and similar tracking tools.

3. Use of Personal Information

Personal information submitted through the Site is used only for limited purposes to provide RWA solutions. For example, when you register to gain access to a data room, the information you submit may be used to manage our relationship with you, such as to provide you with information we feel would be of interest to you. In addition, we may collect and analyze data on your use of our Site for the purpose of improving RWA solutions. We may also send you emails and communications regarding our products and services.

If you are in the EU, we will only send you marketing communications and updates about our products, services, and events with your prior consent. You can withdraw your consent at any time by requesting to be removed at support@found.xyz.

Information contained in documents accessible via links on case websites is made available by order of the bankruptcy court and cannot be removed, modified, or otherwise altered, without further order of the bankruptcy court.

4. Storage of Data

Found will retain Data for a reasonable period, considering legitimate business needs to capture and retain such information. Data will also be retained for a period necessary to comply with local, state, federal, or country specific regulations and requirements, and in accordant with Found’s document retention policy.

5. User Rights

You may have certain rights available under certain laws, including to the extent applicable to the EU’s General Data Protection Regulation (“GDPR”), relating to your personal information. In carrying out the tokenization of bankruptcy claims services, we are acting as a processor on behalf of our users, the data controllers. At the direction of, and in accordance with, the instructions of our users—to the extent that such data is not stored in an immutable way on blockchain ledger technology—we may allow users to access their personal information in our possession to correct, amend, or delete inaccurate information. If you wish to exercise any rights under these laws, including the GDPR, or obtain additional information regarding the processing of data about you that we conduct on behalf of users, please refer to the privacy notice of the data controller or contact the data controller directly.

To the extent applicable under GDPR, where Found is a data controller, you have the following rights concerning your data processed by Found: (i) you have the right to request access to personal information that Found holds about you; and (ii) you have the right to ask us to rectify information Found holds about you if it is inaccurate or not complete.

You may request that Found erase your personal data by contacting support@found.xyz. Found may not be able to erase your personal data based on the requirements of applicable laws, rules, and orders. If Found grants this request, we will keep basic data to identify you and retain it solely for preventing further unwanted processing.

6. Portability

Where processing is based on consent or performance of a contract, you have the right to data portability. Found must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to personal data that you have provided to Found as data controller. Please contact support@found.xyz to request access, rectification, erasure, to restrict processing, to object to processing, or to request data portability. The erasure or restriction of processing of your information may impact your legal rights.

7. Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data that produce legal effects that significantly affect the individuals involved such as through automated legal agreements completed with user-provided data at their direction. Found makes automated decisions using personal data provided in creating Smart Claims solely as a service provided to our users at their direction. You are given the opportunity to review all automated decisions prior to signing any transaction and consent to any automated decisions at the time of purchase.

8. Providing, Sharing, and Disclosure of Information

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our Site(s). In addition, your legal rights may be impacted.

Found will share your information with your consent or in accordance with this Agreement. We will not otherwise share, sell, or distribute any of the information you provide to us except as described in this Agreement.

Our arrangements with users may require us to provide all visitor information in our possession relevant to a transaction, including personal information, directly to the user with which the visitor is associated. Personal information may be provided to third-party vendors, consultants, and other service providers who are performing certain services on behalf of Found or its users. These parties are authorized to use your personal information only as necessary, and in accordance with applicable law, to provide the applicable services to Found Parties.

Personal information will also be disclosed to law enforcements, judicial bodies, regulatory or other government agencies, or third parties where necessary, in our judgment, to comply with legal or regulations.

Personal information may also be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and we may transfer personal information to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. You will be notified by email and/or prominent notice on the Site of any such event. Found may also share personal information with its affiliates.

We may share with third parties aggregated, non-personally identifiable information concerning Site usage including, but not limited to, trading data, as we deem appropriate as part of our ongoing business activities.

Except as set forth above in this section, we will not make any of your personal information available to third parties.

9. Information Security

Found has put in place physical, technological, and operational security procedures designed to protect personal information provided by users and visitors of the Site from unauthorized access. However, no method of transmission over the internet, or electronic storage method, is 100% secure. You can also take additional measures to protect yourself and your information, such as keeping your anti-virus software updated, using cold storage crypto wallet, keeping crypto wallet software updated, not clicking links on unsecure websites, not sharing your seed phrase, and keeping log-in credentials and passwords secure. Please contact us immediately as support@found.xyz if you suspect or experience any security-related issues.

10. Links to Third Party Websites

This Site may contain hyperlinks to other websites. This Agreement does not apply to those websites. The use of any such other website may be subject to a privacy statement, terms of use, disclaimer, or similar legal condition which may significantly differ from those set forth in this privacy notice or elsewhere on the Site. We strongly encourage you to review the privacy notice of any website you visit before providing any personal information. We are not responsible for the privacy practices or the content of any such other websites.

1. Changes to the Privacy Notice

Found reserves the right to modify or amend this Agreement at any time and for any reason. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this privacy notice was last modified or amended by checking the date at the top of the Agreement.

If you have any questions or concerns regarding your privacy while using the Site, please direct them to support@found.xyz.