Privacy Policy

Project Heirloom, Inc.

Last Updated: May 12, 2023

At Heirloom, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Service in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Heirloom's Service is at all times subject to our Master Minting Platform Agreement or our Terms of Use, whichever applies to you based on the nature of your interaction with Heirloom and the Service (each, for purposes of this Privacy Policy, your “User Agreement”), each of which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in your User Agreement.

Privacy Policy Table of Contents

What this Privacy Policy Covers

Heirloom is in the business of minting, distributing, and managing verifiable credentials on blockchains for our Credential Issuing Partners through our Platform. This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Service or that we process on behalf of our Credential Issuing Partners. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. If your Credential Issuing Partner collects your Personal Data, please review their privacy policy for more information on which categories of Personal Data are collected and how it may be shared with us.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Share This Personal Data
Profile or Contact Data	• First and last name
• Email	• Credential Issuing Partners
• Parties You Authorize, Access, or Authenticate
Identifiers	• Cultural or social identifiers	• Credential Issuing Partners
• Parties You Authorize, Access, or Authenticate
Payment Data	• Payment card type
• Last 4 digits of payment card
• Billing address, phone number, and email	• Service Providers (specifically our payment processing partner, currently Stripe, Inc., Apple, Inc., and Google LLC)
Social Network Data	• Email
• Phone number
• Username	• Parties You Authorize, Access, or Authenticate
Professional or Employment-Related Data	• Resume
• Job title
• Job history
• Performance evaluations	• Credential Issuing Partners
• Parties You Authorize, Access, or Authenticate
Non-Public Education Data	• Grades or transcripts
• Student financial information
• Student disciplinary records	• Credential Issuing Partners
• Parties You Authorize, Access, or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	• Identifying information in emails or letters you or a Credential Issuing Partner send us	• Service Providers
• Credential Issuing Partners
• Parties You Authorize, Access, or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You
- When you provide such information directly to us.
  - When you create an account or use our interactive tools and the Service.
  - When you voluntarily provide information in free-form text boxes through the Service or through responses to surveys or questionnaires.
  - When you send us an email or otherwise contact us.
- When you use the Service and such information is collected automatically.
  - Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
  - If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  - If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Service, such as information regarding when you are logged on and available to receive updates or alert notices.
Third Parties
- Credential Issuing Partners
  - Credential Issuing Partners may share your information with us from time to time so we can prepare, distribute, and validate your Credentials.
- Vendors
  - We may use analytics providers to analyze how you interact and engage with the Service or third parties may help us provide you with customer support.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing, and Improving the Service
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Preparing, distributing, and validating your Credentials.
- Providing you with the products, Services, or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Service.
- Improving the Service, including testing, research, internal analytics, and product development.
- Personalizing the Service, website content, and communications based on your preferences.
- Doing fraud protection, security, and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CPRA”).