Effective Date: August 13, 2019

Privacy Policy

The Stellar Development Foundation (“SDF,” “we,” “our,” or “us”) provides this Privacy Policy to explain how we collect, share, and use personal information about you and information arising from our interactions with you to support the operation, development, and growth of the “Services” defined in our Terms of Service, including, without limitation, our website https://www.stellar.org, all applications therein, and other websites or applications that we offer that link to this Privacy Policy (the foregoing websites and applications collectively, the “Sites”).

This Privacy Policy applies to information we collect when you visit and use our Sites or otherwise use our Services.

This Privacy Policy does not apply to the open-source Stellar software or the Stellar Network, a distributed open-source global network accessed through the Stellar software. You should be aware that any information posted to the Stellar Network will be made permanently available to the public.

How We Collect Your Information

We collect information you provide to us when you browse our Sites, create an online account, post messages to our forums, sign up for email alerts and newsletters, provide feedback through forms or surveys, participate in any interactive features, or otherwise use our Services. The types of information we may collect include your name, username, email address, profile picture, password, or public key, and any other information you choose to provide. We also collect the information you submit through your communications with us such as communications to learn more about our Services, contribute to our Services, report a security bug, receive lumens, or apply for a job with SDF.

We also collect technical information including, but not limited to, browser type, IP address, domain name, pages visited and other activities on the Sites, device type, and the time and date of your visits. We collect location information if permitted by your browser settings. Our Services use cookies, web beacons, web server logs, and other similar technologies to collect such information in order to: (1) understand how you use and interact with our Services; (2) measure the usability of our Services and the effectiveness of our communications; and (3) otherwise manage and enhance our Services and help ensure they are working properly. More information about our use of cookies may be found in the Cookie Section of this Privacy Policy below.

How We Use Your Information

We use your personal information for the following purposes:

  • To deliver the content of our Sites and Services, including, without limitation, to improve the content of our Sites, notify visitors to our Sites about updates, and recognize visitors to the Sites;
  • To respond to your comments, questions, and requests and to provide support services;
  • As required by SDF to enable our business, including for research and analytics purposes;
  • To protect the security and performance of our interests, including our assets and systems;
  • To comply with applicable laws and regulations;
  • To monitor and analyze trends, usage, and activities in order to operate and improve our Services;
  • To manage your online account(s) and send you technical notices, updates, security alerts, and support and administrative messages; and
  • As otherwise disclosed at the time personal information is collected. We do not use automatic decision-making (i.e., making decisions solely by automated means without any human involvement) or profiling (i.e., automated processing of personal information to evaluate certain aspects of an individual).

Where we intend to use or otherwise process your personal information for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal information for the new purpose.

How We Share Your Information

We may share your personal information with the following third parties:

  • Third party vendors who process data on behalf of SDF, such as analytics providers who track and analyze the performance of our Sites and related analytics;
  • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
  • Pursuant to a subpoena, court order, governmental inquiry, law enforcement investigation, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties; or
  • With your consent or as otherwise disclosed at the time of data collection or sharing. The Sites may also include, or provide access to, features and forums where you can post public comments and communicate with other users. We are not responsible for the other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself.

We may also share information that has been de-identified or aggregated without restriction.

Data Analytics

We work with third parties that collect information about your use of the Sites. For example, SDF uses Google Analytics and other third-party services to improve the performance of the Sites and for analytics purposes. For more information about how Google Analytics collects and uses information when you use our website, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

International Visitors

This section applies to those that access our Services from outside of the United States. Please be aware that the personal information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal information in the United States.

SDF generally processes personal information submitted to the Services for the implicit or express purposes specified on the relevant Service. In certain circumstances, SDF may process personal information in order to fulfill a contract or where required to do so by law. If necessary, SDF may also process personal information when it is in SDF’s legitimate interests to do so (e.g., for fraud or hacking detection) and when these interests are not overridden by your data protection rights.

If you reside in the European Economic Area (“EEA”), the United Kingdom, or Switzerland you have a right:

  • To request access to the personal information we hold about you;
  • To request that we rectify or erase your personal information;
  • To request that we restrict or block the processing of your personal information;
  • Under certain circumstances, to receive personal information about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal information directly to another (i.e., a right to data portability); and
  • Where we previously obtained your consent, to withdraw consent to processing your personal information. To exercise these rights, contact us using the “Contact Us” section below. Please be aware that SDF may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.

Retention

We will retain your personal information on file for as long as necessary for our legitimate business purposes. When we no longer need it for the purpose we collected it, we take steps to destroy it unless we are required by law or regulation to keep it longer.

How We Protect Your Information

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We monitor our systems for possible vulnerabilities and attacks, however, we cannot guarantee 100% security of any information that we maintain.

Your Choices

To update your contact information or change your communication preferences, including to stop email communications from us, please contact us through the methods provided in the “Contact Us” section below. In accordance with applicable laws, you may also unsubscribe from certain types of email communications from us by using the link provided in the email.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising Effective Date at the top of this policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our Sites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Cookies

Our Sites use cookies to collect information. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies on our Sites:

  • Strictly necessary cookies. These cookies are required for the operation of our Sites. They include, for example, cookies that enable a relevant Site to recognize a previous visitor.
  • Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies and similar technologies used on our Sites and the purposes for which they are used in the table below:

Technology

Name

Purpose

More information

Amplitude

amplitude_id

Used to distinguish users.

Google Analytics

_ga

Used to distinguish users.

_gid

Used to distinguish users.

_gat

Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.</property-id>

AMP_TOKEN

Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.

_gac_<property-id></property-id>

Contains campaign related information for the user

__utma

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists.

__utmt

Used to throttle request rate.

__utmb

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists.

__utmc

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

__utmz

Stores the traffic source or campaign that explains how the user reached the site. The cookie is created when the javascript library executes.

__utmv

Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable.

Cookies

Contact Us

If you have questions, comments, or concerns about this Privacy Policy, you may contact us:

By Mail:

Stellar Development Foundation
PO Box 192750
PMB 24194
San Francisco, CA 94119


By Email:

legal@stellar.org