HODL Totals

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Privacy Policy

This Privacy Policy governs the manner in which Daring Crypto Ventures LLC (“DCV”) collects, uses, maintains and discloses information collected from users (“Students” of the School, “Consumers” of the Open-Source Software we provide, “Subscribers” to our newsletters, and “Members” of our Discord server).

This Privacy Policy applies to the Daring Crypto Ventures School and all Courses offered by the School. This Privacy Policy applies to the HODL Totals add-on for Google Sheets™. This Privacy Policy applies to subscribers of our email newsletter. This Privacy Policy applies to our Discord server.

Regardless of which type of user you are, rest assured that your privacy is taken very seriously and is critically important to us. At DCV, we have a few fundamental principles:

We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
We store personal information for only as long as we have a reason to keep it.
We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
We help protect you from overreaching government demands for your personal information.
We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

We are here to help crypto go mainstream. Moreover, we are here to fuel cryptocurrency adoption by building a community of self-reliant crypto HODLers in full compliance with tax laws and regulations. Our mission is ambitious but grounded in the fact that anyone armed with the right information and training can truly unbank themselves and take control of their financial lives.

We believe in solutions grounded in the open internet, with code that is open source and available under the MIT License. Unlike the software used by many other crypto service companies, our source code is public so you can actually download and take a look at the code to see how it works.

This Privacy Policy applies to information that we collect about you when you use:

Our websites (including daringcryptoventures.com, hodltotals.com, dcv.teachable.com);
Our open source tools available on github and through the Google Workspace™ Marketplace (including the HODL Totals add-on);
Our mobile applications (including the HODL Totals mobile app for Android and iOS);
Our other products, services, and features that are available on or through our websites (for example, the Daring Crypto Ventures School courses on dcv.teachable.com, expertise shared via Discord Server chats, useful content shared in our email newsletters)

This Privacy Policy also applies to information we collect when you apply for a job at DCV or one of our subsidiaries. Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.” Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Creative Commons Sharealike License

This Privacy Policy is available under a Creative Commons Sharealike license. You can grab a copy of this Privacy Policy and other legal documents on GitHub. You’re more than welcome to copy it, adapt it, and repurpose it for your own use. Just make sure to revise the language so that your policy reflects your actual practices. If you do use it, we’d appreciate a credit and link to DCV somewhere on your site.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

Public profiles: If you have an account with us, we collect the information that you provide for your public profile. For example, if you are a dcv.teachable.com Student or a HODL Totals Discord server user, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
Student enrollment in the School or a Course within the School: We will need basic information from you in order to set up your School account. Students may visit the School anonymously. We will collect personal identification information from Students only if they voluntarily submit such information to us. Students can refuse to supply personal identification information but doing so may prevent them from engaging in certain School related activities.
Resources made available to you from the School or from a Course within the School: We may share resources with you, made available from within our School or our other communication channels, and while doing so may collect information about you in connection with your consumption of those resources. That information will help us provide you with more meaningful content, better services, impactful features and more complete resources.
Newsletter subscriptions: If you sign up for our email newsletter, we’ll collect information from you such as “what to call you” and an email address so that we can proactively share information about our Services with you.
Communications with us: You may also provide us with information when you respond to surveys, communicate with our Engineers about a support question, post a question in our public forums, or sign up for a newsletter. When you communicate with us via form, email, phone, chat, comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you login and complete a course on dcv.teachable.com.
Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that our students perform in the School — in other words, who did what and when. Our usage tracker also tracks information like your email address and site settings. We also collect information about what happens when you use our Services (e.g., page views, searches on our site, along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions.
Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you use our mobile app to manage your crypto lifestyle on the go, our Services may access your camera or stored photos to pull in wallet addresses stored as QR codes.
Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. We may use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.

Information We Collect from Other Sources

We may also get information about you from other sources. For example, if you create or log in to your Teachable account through another service, we’ll receive information from that service (e.g., your username, basic profile information) via the authorization procedures for that service. The information we receive depends on which services you use or authorize and what options are available. Third-party services may also give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.

How and Why We Use Information

Purposes for Using Information

We may collect and use information about you for the purposes listed below:

To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information. For example, to send periodic emails to Student email addresses that provide Students information and updates pertaining to their order. Or, for another example, using Student email addresses to respond to Student inquires, questions or other requests.
To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them more easily meet their obligations to comply with tax regulations or make our Services easier to use. Or, to use information in aggregate to understand how our Students as a group use the services and resources provided by our School.
To market our Services and to measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
To claim you are a customer. If you notify us that you are using our services through any means, we may (i) orally state that You are a customer, (ii) include Your name or trademarks, trade names, service marks or logos in a list of customers (whether in our online or offline promotional materials) and (iii) generally describe the products or services it provides to You in its promotional materials, presentations and proposals to other current and prospective customers. You may revoke our right to use your trademarks, trade names, service marks or logos under this paragraph with written notice to DCV and a reasonable period to stop the use.
To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of DCV and others, which may result in us, for example, declining a transaction or terminating Services.
To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through our suggestions, and providing news updates and articles for your reading pleasure.
To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on the latest crypto regulations; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.) We may also provide occasional in-app announcements, polls and surveys with relevant information. Unless you modify the open-source code, you cannot easily opt out of the in-app announcements.
To recruit and hire new employees. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or (5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on.

We can share information about you in limited circumstances, and with appropriate safeguards on your privacy.

Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like the Teachable payment gateway that processes your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications); other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about dcv.teachable.com users, please see our Legal Guidelines.
To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of DCV, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that DCV goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We have a policy that we do not sell, trade or rent our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly. That means information like your public profile, posts, discord channel comments, other content that you make public are all available to others — and we hope they get a lot of views! Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it. For example, we keep web server logs that record information about a visitor to one of our websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to our websites and investigate issues if something goes wrong on one of our websites.

Security

While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.

Choices

You have several choices available when it comes to information about you:

Limit the information that you provide: If you create an account using any of our Services, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, premium courses that carry an additional charge — may not be accessible.
Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like QR code scanning.
Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
Set your browser to reject cookies: You can usually choose to set your browser to remove or reject browser cookies before using DCV’s websites, with the drawback that certain features of DCV’s websites may not function properly without the aid of cookies.
Close your account: While we’d be very sad to see you go, you can unenroll from the School, leave the Discord server and close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

Request access to your personal data;
Request correction or deletion of your personal data;
Object to our use and processing of your personal data;
Request that we limit our use and processing of your personal data; and
Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. We may collect the following categories of personal information from California residents, depending on the Services used:

Identifiers (like your name, contact information, and device and online identifiers);
Commercial information (your billing information and purchase history, for example);
Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
Internet or other electronic network activity information (such as your usage of our Services);
Geolocation data (such as your location based on your IP address);
Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
Professional or employment-related information (for example, information you provide in a job application); and
Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
Request deletion of personal information we collect or maintain;
Opt out of any sale of personal information; and
Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to “How to Reach Us” to, well, find out how to reach us. When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us via email at privacypolicy@daringcryptoventures.com. This is the fastest ways to get a response to your inquiry.

Other Things You Should Know (Keep Reading!)

Transferring Information

Because DCV’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include entering into European Commission approved standard contractual arrangements with entities based in countries outside the EEA. You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by DCV and does not cover the collection of information by any third-party advertisers or analytics providers.

Third-Party Software and Services

If you’d like to use third-party software or services, please keep in mind that interacting with them may mean providing information about yourself to those third parties. For example, some third-party services may request or require access to your data via a pixel or cookie. For example, to use the HODL Totals add-on you will need a Google account that is subject to Google’s privacy policy and practices. Please note that if you use a third-party service or grant access, your data will be handled in accordance with that third party’s privacy policy and practices. We don’t own or control these third parties, and they have their own rules about information collection, use, and sharing, which you should review before using the software or services.

Privacy Policy Changes

Although most changes are likely to be minor, DCV may change its Privacy Policy from time to time. DCV encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our homepage, blog or sending you a notification through email or your dashboard). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

Your Acceptance of these terms

By enrolling in the School, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not enroll in the School. Your continued enrollment in the School following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

By installing the HODL Totals add-on, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not install the HODL Totals add-on. Your continued use of the add-on following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

By subscribing to our email newsletter, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not sign up for our email newsletter. By taking no action to unsubscribe from our newsletter email list following the posting of changes to this Privacy Policy, this inaction will be deemed your acceptance of those changes.

By joining the Discord server, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not join our Discord server. Your continued membership in the Discord server following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

Translation

Our Privacy Policy was originally written in English (US). We may translate it into other languages. In the event of a conflict between a translated version of our Privacy Policy and the English version, the English version will control. That’s it! Thanks for reading.

Change log

April 25, 2021: Added additional reason for using data (To claim you are a customer)
February 2, 2021: Initial draft.