Introduction

This Privacy Policy outlines how Cielo (“Cielo”) processes your personal data when you use our website and Cielo Products. References to "we" and "us" in the following refer to the company Cielo. Cielo is the controller of the processing activities described in this policy. This Privacy Policy is designed to help you, as a user of the Cielo Product, understand the Personal Data we collect, why we collect it, how we use it, and your data privacy rights.
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‍Purpose and Basis for the Information We Collect

Cielo collects personal data for providing the Cielo Product, website analysis and improvement, direct marketing, and product updates. Personal Data refers to any information related to an identified or identifiable natural person. All processing of Personal Data by Cielo complies with applicable data privacy legislation. We process your data for the following purposes:

2.1. Providing the Cielo Product

We collect and process the following Personal Data when you use the Cielo Product: Wallet, Telegram / Discord, E-mail address, IP address, Web browser, Navigation information on cielo.finance or other domains where the Cielo product is accessible.

Personal Data collected for offering the Cielo Product is used to: Administer and provide you with the Cielo Product, Contact you for software updates or changes to this Privacy Policy or other agreements relevant to your use of the Cielo Product.

Users should note that the social nature of the Cielo product means that anything you decide to make public will be publicly viewable. See the Terms of Use for more information. The legal basis for this processing is to fulfill an agreement with you

2.2. Website and Product Analysis and Improvement

We collect and process the following Personal Data for website and product analysis and improvement: E-mail address, IP address, Web browser / location*, Navigation information on cielo.finance or other domains where the Cielo product is accessible
*Via Google Analytics

Personal Data collected for website analysis and improvement is used to: Analyze trends and usage patterns on the website.Improve the website by adapting its configuration and design to behavioral patterns.All private wallet labels are always private!

For web3 native ads on Spindl via our web app feed your login wallet address to Cielo may be used to serve targeted ads to our free tier users.

We only collect aggregate wallet data. The legal basis for our processing of your personal data in this manner is that we consider that we have a legitimate interest under article 6(1)(f) of the General Data Protection Regulation. Our legitimate interest consists of being able to provide and improve our services.

2.3. Troubleshooting or Support

We may process your Personal Data and usage logs when you submit a request for troubleshooting or support for your use of the Cielo Product. Such Personal Data and usage logs are not used for any other purposes than to provide you with the requested support or troubleshooting. We collect and process the following Personal Data for troubleshooting and support: Name, E-mail address, IP address, Web browser, Navigation information on cielo.finance or other domains where the Cielo product is accessible.

The legal basis for this processing is to fulfill an agreement with you (see article 6(1)(b) of the General Data Protection Regulation).

2.4. Direct Marketing and Product Updates

Cielo will use your name and contact information to keep you updated on product launches, software updates, or similar marketing-related communications related to the Cielo Product. You may opt out of any marketing communications by sending an email to [email protected].

We collect and use the following information for marketing purposes:E-mail address, Telegram Username, Navigation information on cielo.finance or other domains where the Cielo product is accessible. The legal basis for this processing is that we consider that we have a legitimate interest under article 6(1)(f) of the General Data Protection Regulation. Our legitimate interest consists of our business interest in reaching out to users and sending relevant information.
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‍Retention Period

Personal Data will be deleted upon request from the user or termination of your user account.
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‍Information Sharing

Cielo will not share the Personal Data of its users with any third parties,  except when we are legally compelled to share the data. We share your data only with our processors, with the sole purpose of providing the service to you. We use Stripe as a payment processor. Stripe is located in the US, and we have entered into Singapore standard contractual clauses to ensure Stripe’s use is in accordance with relevant privacy legislation. We use Intercom to receive feedback and provide customer support. Intercom hosts the data in the US, and we have entered into Singapore’s standard contractual clauses to ensure Intercom's use is in accordance with relevant privacy legislation.
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‍Your Rights

When providing us with your Personal Data, you may request access to your Personal Data, as well as information on how we process your Personal Data. You may also request rectification, erasure, and restriction of the processing, as well as to have your Personal Data exported in a structured, commonly used, and machine-readable format (data portability).

Requests pursuant to the above rights may be submitted to: [email protected].

You may also file a complaint with your applicable data protection authority if you believe that Cielo has failed to comply with your rights as a data subject.
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‍Changes to This Privacy Policy

Cielo reserves the right to adjust or change this Privacy Policy. We will notify you of such changes before they are implemented. You agree to such modifications or changes by continuing to use the Cielo Product after such information has been made available to you.