Date of last update: December 15, 2023

This privacy policy (“Privacy Policy”) describes how and why we collect, use, and share data that we obtain through your use of the Internet sites, applications, email and newsletter communications, and services (the “Site”) operated by, controlled by, or affiliated with MIDAO Directory Services, Inc., and MIDAO Global, Inc. (collectively, “MIDAO,” “we,” “us,” or “our”). If you are a resident of California, please review our California Privacy Policy for additional disclosures required by California law. If you are a resident of the European Union, please review our EU Privacy Policy for additional information relating to your rights.

By using the Site, you agree to the practices described in this Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this Privacy Policy periodically. Updates will be referenced by the “Date of last update” shown above.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at notices@midao.org.

We collect data from you in several different ways on the Site, including personal data and data about your use of the Site which does not identify you personally. Personal data means information, or combination of information, that can reasonably be used to identify you personally (including, but not limited to: your name, phone number, address, username, contact preferences, contact or authentication data, billing addresses, debit/credit card numbers, identification card such as license, passport, or other government issued identification, and email address).

Personal Data That You Voluntarily Provide

We collect personal data that you voluntarily provide to us (such as when you submit an inquiry or subscribe to our Services as defined in the Terms of Use), including name, email address, wallet address, and any other data you choose to provide.

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Data Collection 

When you access and use the Site, our hosting, website, technology, and tools may automatically collect and record certain data about your use of and interaction with the Site that does not identify you personally (such as your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring webpage, pages visited, and search terms).

We and our host may also use various tracking technologies (such as cookies and pixel tags) to collect data about your use of and access to the Site. Cookies are small data files stored on your hard drive or in device memory by websites you visit, applications you use, or advertisements you view and help us improve the Site and your experience on the Site. Pixel tags are electronic images that generate a generic notice of a visit to the Site and are used in conjunction with cookies to anonymously track activity on the Site by a particular browser.

Third parties, including our host, may also automatically collect data about you.

Some content on the Site may be served by third-party content providers and may also use cookies, pixel tags, or other similar tracking technologies to automatically collect data about you, both on the Site and throughout the Internet. We do not control the technologies of those third parties. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

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Use of Collected Data

We use the data we collect to assist in the administration and operation of the Site, register DAO LLC entities in the Republic of the Marshall Islands, and provide you an efficient, meaningful, and customized experience.

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We may use data to:

Fulfill our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry, registering your DAO LLC, or providing you with information, products, or services that you request from us or that may be of interest to you);

Allow you to participate in certain features of the Site;

Improve the Site or our products, events, and services and for other business or commercial purposes;

Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences);

Provide co-branded services and features (such as contests, sweepstakes, or other promotions);

Notify you about changes to the Site (including this Privacy Policy);

Carry out any other purpose described to you at the time the data was collected; and

Carry out any other purpose with your consent or as permitted by law.

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Additionally, we may use data for marketing purposes to:

Provide you with additional information regarding products, events, promotions, and services from MIDAO and third parties that may be of interest to you via email, or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and

Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and the use of social media platform tools for advertising (such as the creation of Facebook Lookalike Audiences).

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Third-Party Websites and Services

Through the use of the Site, you may access, directly or indirectly, other websites or services, including from our service providers, business partners, and other third parties, in each case, that are not owned or controlled by us. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

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Sharing of Collected Data

We may share the data we collect as follows:

With the proper government agencies, such as the Republic of the Marshall Islands to properly register your entity.

With our current and future partners, subsidiaries, and other companies under common control and ownership;

With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);

With our sponsors, promotional partners, or event partners in connection with certain contests, sweepstakes, promotions, or ticketed events;

With our third-party vendors and partners that sell items, offer promotions, or provide services to you through our services (either alone or jointly with us);

To comply with a court order or other legal obligation, to enforce the Site Terms of Use, and to protect the rights, property, or safety of our users and other third parties;

With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity;

In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets; and

With your consent or at your direction.

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Transfer of Collected Data

The Site is operated partly in the United States. If you are located in another jurisdiction, please be aware that the data we collect will be transferred to, stored, and processed in the United States. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this Privacy Policy.

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Data Security

We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk, and you agree to assume all risk in connection with data sent to us or collected by us.

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Data Retention

We retain data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

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Minimum Age 

By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian.If you become aware that a minor has provided us with personal data, please contact us at notices@midao.org.

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Our “Do Not Track” (DNT) Policy

Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or any similar mechanisms transmitted by web browsers. 

Communications

If you no longer wish to receive emails or other communications from MIDAO, please follow the instructions in the emails to opt-out from receiving such emails in the future or submit a request to our email at notices@midao.org.

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Cookies, Pixel Tags, and Other Similar Tracking Technologies

You may remove or reject cookies by adjusting settings on your browser, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data. These tracking technology opt-out tools are device and browser specific so you must repeat the opt-out from each of your devices and browsers. Please note that removing or rejecting cookies could affect the functionality of the Site.

You may also remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools).

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California Privacy Policy

If you are a resident of California, please review our California Privacy Policy below for additional disclosures required by California law.

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EU Privacy Policy

If you are a resident of the European Union, please review our EU Privacy Policy below for additional information about your rights.

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Contact Us

If you have any questions about this Privacy Policy, please email us at notices@midao.org.

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California Privacy Policy

This California Privacy Policy supplements the information contained in the Privacy Policy of MIDAO with additional disclosures required by the California Consumer Privacy Act (“CCPA”) and other California privacy laws that apply only to residents of California. Any terms defined in the Privacy Policy or in the CCPA have the same meaning when used in this California Privacy Policy.

By using the Site, you agree to the practices described in this California Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this California Privacy Policy periodically. Updates will be referenced by the “Date of last update”   shown above.

As defined in the CCPA, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

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Notice of Collection of Personal Information

We may collect and may have collected in the last 12 months the following categories of Personal Information:

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CATEGORY EXAMPLES

Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.

Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Online activity; Internet or other electronic network activity information. Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.

Geolocation data. Physical location or movements.

Inferences drawn from any of the information. Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Please note that the categories and examples listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were or will be in fact collected about every Site visitor, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected.

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We collect the categories of Personal Information listed above from the following categories of sources:

Directly from you when you provide it to us.

Indirectly and automatically from your devices. For example, when you visit or interact with the Site.

Directly from our partners, subsidiaries, and other companies under common control and ownership.

Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.

From vendors who provide services to us.

From other third parties. For example, sponsors or event partners in connection with certain ticketed events, social networking providers, and advertising companies. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to the Site.

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Use and Disclosure of Personal Information

We may use and disclose the Personal Information as described in this Privacy Policy for business and commercial purposes.

Additionally, we may use or disclose and may have used or disclosed in the last 12 months the following categories of Personal Information for business or commercial purposes:

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Identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Commercial information.

Online activity; Internet or other electronic network activity information.

Geolocation data.

Inferences drawn from any of the information.

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Your California Consumer Privacy Rights

The CCPA provides residents of California with the following rights regarding their Personal Information:

Right to Know About Personal Information Collected or Disclosed

You have the right to request, twice in a 12-month period, that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the last 12 months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you within the time required by the CCPA, the relevant information.

Right to Request Deletion of Personal Information

You have the right to request that we delete any of your Personal Information that we collected from you and retain, subject to certain exceptions. Once we receive and confirm a verifiable consumer request from you, we will delete (and direct our service providers to delete) your Personal Information from our records within the time required by the CCPA, unless an exception applies.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights. We will not discriminate against you for exercising any of your CCPA rights.

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Exercising Your California Privacy Rights

To exercise any of the rights described above, please email us at notices@midao.org.

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Verification of Requests

When you submit your request, we will reasonably verify your identity prior to processing your request to access or delete any Personal Information we may hold about you. You must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a request does not require you to create an account with us. We will only use Personal Information provided in a request to verify the requestor’s identity or authority to make the request.

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Making a Request through an Authorized Agent

You may submit a request through an authorized agent. The agent will need to state that they are acting on your behalf when making the request, have proof of the authority to act on your behalf, and be prepared to provide sufficient Personal Information to enable us to identify you in our records.

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Contact Us

To submit a request relating to our California Privacy Rights or if you have any questions about this California Privacy Policy, please email us at notices@midao.org.

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EU PRIVACY POLICY

This EU Privacy Policy (this “EU Privacy Policy”) supplements the information contained in the Privacy Policy of MIDAO with additional information relating to your rights under the General Data Protection Regulation (“GDPR”) that applies only to residents of the European Union. Any terms defined in the Privacy Policy or in the GDPR have the same meaning when used in this EU Privacy Policy.

By using the Site, you agree to the practices described in this EU Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this EU Privacy Policy periodically. Updates will be referenced by the “Date of last update”  shown above.

We will only collect and process your personal data in accordance with applicable data protection and privacy laws. The data controller for the personal data that you provide or that is collected by MIDAO can be reached at notices@midao.org.

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The GDPR provides residents of the EU with the following rights regarding their personal data:

Right to be informed about the collection and use of your personal data

Right to access your personal data

Right to have any inaccurate personal data corrected

Right to have your personal data erased

Right to restrict use of your personal data

Right to personal data portability

Right to object to the processing of your personal data

Right to object to automated decision making

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To exercise any of these rights, please submit a request by emailing notices@midao.org. We will respond to any requests within the time required by the GDPR. After you submit your request, you will be sent a confirmation email. Please note that we may need additional information from you to verify your identity before we process your request.

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Legal Basis for Processing Personal Data

To the extent you provide us with personal data, we are processing your personal data under one of the following lawful bases:

Consent. By opting-in, you consent to permit us to process your personal data for the purposes set forth in our Privacy Policy.

Compliance with Legal Obligations. We may process your personal data in order to comply with certain of our legal obligations.

Cookies, Pixel Tags, and Other Similar Tracking Technologies

To the extent required by applicable law, we will obtain your consent before collecting data using cookies, pixel tags, and other similar tracking technologies on the Site. If you have accepted our use of cookies, pixel tags, and other tracking technologies, we will collect your data in accordance with our Privacy Policy based on your affirmative informed consent, which you may withdraw through the methods provided herein. If you have not accepted, then we only collect your personal data based on our legitimate interests. 

Consent. By opting-in, you consent to permit us to process your personal data for the purposes set forth in our Privacy Policy.

Compliance with Legal Obligations. We may process your personal data in order to comply with certain of our legal obligations.

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COOKIE POLICY

This Cookie Policy explains how MIDAO Global, Inc. ("Company," "we," "us," and "our") uses cookies and similar technologies to recognize you when you visit our website at https://www.midao.org/ ("Website"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

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What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, MIDAO) are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

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Why do we use cookies?

We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Website for advertising, analytics, and other purposes. This is described in more detail below.

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How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our website. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies.

The specific types of first- and third-party cookies served through our Website and the purposes they perform are described in the table below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

Essential website cookies:

These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas.

Name: NAME

Purpose: Prevents malicious attacks.

Provider:

Service:

Country: United States

Type: server_cookie

Expires in: 1 year

Performance and functionality cookies:

These cookies are used to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.

Analytics and customization cookies:

These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

Advertising cookies:

These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Unclassified cookies:

These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

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How can I control cookies on my browser?

As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information. 

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What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

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Do you use Flash cookies or Local Shared Objects?

Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention, and for other site operations. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

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Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. They can accomplish this by using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details, or other details that directly identify you unless you choose to provide these.

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How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

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Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at notices@midao.org

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Contact Us

To submit a request to exercise Your Rights, please email notices@midao.org.

If you have any questions about this Privacy Policy, please email us at notices@midao.org.