Privacy Policy

Last Updated: March 30, 2023

This Privacy Policy describes the privacy practices of MAKE Technology LLC and our subsidiaries and affiliates (collectively, “MAKE”, “we”, “us”, or “our”) and how we handle personal information that we collect through our websites, mobile applications, and related services in connection with our Casper Wallet, CSPR.name service, CSPR.click service, CSPR.cloud middleware, NFT minting services and marketplace, and block explorer (collectively, the “Services”).

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Services or otherwise includes:

• Contact details, such as your first and last name, , email and mailing addresses, and phone number, that you may choose to provide when you create an NFT Collection or in other specific instances. You do not need to provide this contact information to us for general use of our Services.
• Wallet information, including the cryptocurrency wallet’s public key you provide to us when you interact with any of our Services, including when you buy, store, and transfer NFTs or other cryptocurrency assets on our NFT marketplace, or when you use our wallet extensions. Note that MAKE does not have access to your private keys.
• Cryptocurrency transaction information, including information about the transactions you make using our Services, such as the public key of the recipient, transaction amount, and timestamp.
• Interests, usage, and connections, including information about your interests (if you choose to add them), how you use the Services, such as the types of content you create and engage with, content you share, features you use, actions you take, and people or accounts you interact and connect with.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may combine personal information we receive from you with information we obtain from other sources, such as:

• Third-party login information. When you link, connect, or login to the Services with a third party service (e.g. Google or Single Sign-On), you direct the service to send us information such as your registration, name, email address, photo, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Public sources, including blockchains and social media companies we maintain pages with, such as Discord and Twitter.
• Marketing partners, such as companies that have entered into joint marketing relationships with us.

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online Services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G).
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.

How we use your personal information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Providing our Services. We use personal information to operate, maintain, and provide you with our Services, including to process your transactions. In particular, we use personal information to perform our contractual obligations under our Terms of Use.

Communicating with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts and support and administrative messages.

Improving, monitoring, personalizing, and protecting our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

• understanding your needs and interests, and personalize your experience with the Services and our communications;
• troubleshooting, testing and research and to keep the Services secure; and
• investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below.
• Interest-based advertising. We may engage third-party advertising companies, such as Google, to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our services to them or similar users on other online platforms. For more information, or to understand your choices, please visit our Cookie Policy.

Except where we seek your consent, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.

Compliance and protection. We may use personal information to comply with legal obligations, and it is in our legitimate business interests to use your personal information to defend us against legal claims or disputes, including to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the services;
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

How we share personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

At your direction. For example, you may direct us to share your personal information with NFT creators when you purchase an NFT in the marketplace.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners. Third party advertising companies for the interest-based advertising purposes described above. The disclosure of this information may constitute a data “sale” under certain privacy laws.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional Services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, MAKE or our affiliates (including, in connection with a bankruptcy or similar proceedings).

How you share personal information

You may share your personal information with the following parties:

The public. When you establish an account with us, you share certain profile information with the MAKE community on our Services. This information may include your name, username, NFTs owned, public blockchain transactions, and your wallet public addresses.

MAKE users. MAKE users with whom you have some affiliation may receive notifications about actions you take on the platform, such as following or interacting with content and/or users. MAKE users with whom you transact on the NFT marketplace may receive additional information.

Other third parties and partners. Users will have the option to share their personal information with interested third parties, social media platforms, and our partners.

Privacy rights and choices

Opt out of marketing communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communication we send you or by contacting us as provided in the How to Contact Us section below. You may continue to receive services-related and other non-marketing emails.

Online tracking opt out. You can opt out of third-party cookies as described in our Cookie Policy.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information:

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes. You can delete any personal information we might collect about you by logging out of your account.
• Opt out of targeted advertising and the sale of personal information. We collect and share personal information with advertising partners that display targeted advertisements to users around the web. You can limit online tracking as described in our Cookie Policy or by clicking Your Privacy Choices on the footer of our website.
• Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please email us or write to us as provided in the How to Contact Us section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. Additionally, as data on a blockchain cannot be changed or deleted by design, your ability to exercise your personal information requests with respect to on-chain personal information may be affected. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below.

Right to complain. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. Click here to find your local supervisory authority.

Other sites and services

The Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

International data transfer

You will provide personal information directly to our website in the United States. We may also transfer personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the How to Contact Us section below.

Children

The Services is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention of personal information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Changes to this privacy policy

We reserve the right to modify this Privacy Policy at any time. We will post the update Privacy Policy on the website. If we make material changes to this Privacy Policy, we will let you know.

How to contact us

Responsible entity. MAKE Technology LLC is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law). MAKE is not the controller of information that is stored on public blockchains.

Contact us. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at

privacy@CSPR.live or by writing to us at:

MAKE Technology LLC
30 N Gould St., Ste R
Sheridan, WY 82801
United States of America

EEA and UK Representative Contact Information. For users in the EEA, we have appointed DataRep, at 12 Northbrook Road, Dublin, Ireland as our EU data representative and our UK data representative. You can contact our EU/UK representative at the address above or alternatively by sending an e-mail to DataRep at datarequest@datarep.com quoting MAKE Technology, LLC in the subject line.

Privacy Snapshot

Here is a high-level snapshot of our privacy practices, but you need to read the entire Privacy Policy for complete information.

Data Categories Collected	How We Collect	Primary Purposes of Processing	Key Recipients / Disclosures	Can You Limit Sharing?
Identifiers such as a real name, Internet Protocol address, email address, or other similar identifiers	When you visit our website or use our Services	To provide our Services; to improve, monitor, and personalize our Services; and for marketing and advertising	Service providers	No
			Advertising partners At your direction	Yes
Personal information categories listed in the California Customer Records Statute (e.g., name, contact details)	When you visit our website or use our Services	To provide our Services; to improve, monitor, and personalize our Services; and for marketing and advertising	Service providers	No
			Advertising partners At your direction	Yes
Commercial information, including but not limited to records of products or services purchased	When you visit our website or use our Services	To provide our Services; to improve, monitor, and personalize our Services; and to communicate with you	Service providers	No
Internet or other electronic network activity information, including but not limited to browsing history and search history	When you visit our website or use our Services	To provide our Services; and for marketing and advertising	Service providers	No
			Advertising partners	Yes
Geolocation data	When you visit our website or use our Services	To provide our Services; and for marketing and advertising	Service providers	Advertising partners
			No	Yes

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Cookie Policy

This Cookie Policy explains how MAKE Technology LLC uses cookies and similar technologies in connection with our Services. This Cookie Policy should be read in conjunction with our Privacy Policy.

If you have any questions or concerns about the Cookie Policy, please contact us at privacy@CSPR.live or as otherwise described in our Privacy Policy.

What are cookies and similar technologies?

• Cookies are text files that websites store and access on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser to allow us distinguish you from other users of our Services for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

This Cookie Policy refers to all these technologies, and other types of tracking technologies used through our Services, collectively as “cookies.”

How do we use cookies and other similar technologies?

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. We use persistent cookies, for example, to record your choice of language and country location. The cookies placed through your use of our website are either set by us (first-party cookies) or by a third party at our request (third-party cookies).

We also allow our advertising partners to collect this information through our website.

What types of cookies and similar technologies do we use?

We use the following categories of cookies:

Essential. We use essential cookies to help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. You can set your browser to block or alert you about these cookies, but then some parts of the websites will not work.

Functionality / performance. We use these cookies to enhance the functionality and performance of the services.

Analytics. We use these cookies to help us understand how our services are performing and being used. Specifically, we use Google Analytics to collect information about how users use our services, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Advertising. We and our third-party advertising partners use these cookies to collect information about how you use our website and use that information to serve online ads that may be relevant to your interests. Please find examples of the third-party advertising cookies we use and links to their platform opt out pages in the following section.

Email Interaction Technology: Our emails may contain web beacons to tell us whether they are opened and verify any clicks through to links within an email. We (and our marketing service provider on our behalf) use this information to help us understand how an email campaign performed, what types of emails and content our recipients find interesting, and what actions our recipients took, so we can improve our email campaigns in the future and make our emails more relevant to our recipients. If you do not wish the web beacon to be downloaded onto your device, you should select to receive emails from us in plain text rather than HTML.

How can you control the use of cookies?

Depending on where you access the Services from, you may be presented with a cookie banner or other tool to provide permissions prior to non-Essential cookies being set. In this case, we only set these non-Essential cookies with your consent.

You can also limit online tracking by:

• Blocking cookies in your browser: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Use the following links to learn more about how to control cookies and online tracking through your browser:

• Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS)

• Blocking advertising ID use in your mobile settings: Your mobile device settings can provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers: You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Advertising industry opt-out tools: You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: optout.aboutads.info
  • Network Advertising Initiative: optout.networkadvertising.org/?c=1
• Platform opt-outs: Some of our advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising, including:
  • Google: adssettings.google.com
  • Facebook: www.facebook.com/about/ads

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.