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As a leader in blockchain technology and crypto software, Subspace Labs, Inc. (also referred to herein as “Subspace Labs,” “Company,” “we,” “us” and “our”) is committed to protecting the privacy of its employees, contractors, software users, investors, and ambassadors (collectively “users” or “you”). Our policy is to ask for only the information we need to provide the information you have requested. The information provided in this Privacy Statement or Notice (“Policy”) explains how we collect and use the information that you share with us and that we collect from you. By submitting your Personal Information, you are providing consent to the use of your information as set out in this Policy. This Policy also outlines your privacy rights and our obligations to you under the General Data Protection Regulation (“GDPR”), California (California Consumer Protection Act (“CCPA”)), and the Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”). For the convenience of individuals who have rights under the GDPR, this Policy calls out how the Company honors your rights and provides information to you about how to exercise your rights pursuant to these laws and regulations in the “Exercising Your GDPR Rights” section below.
Subspace Labs, Inc. collects Personal Information or EU Personal Data (as defined below) about you in two ways: 1) directly from you and 2) indirectly from you via your use of websites operated by us.
Personal Information means any information or data, recorded in any form, relating to you that can directly or indirectly identify you, such as but not limited to your name, birthdate, postal address, email address, telephone number, driver’s license number, Social Security Number or other government-issued identification number, location data, online identifiers, credit card number, medical history, physical and mental conditions, or other unique identifiers. Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even when combined with other data. Personal Information does not include Business Information as defined below.
Business Information means any information directly relating to a business, partnership, corporation, or other commercial or non-commercial venture, including, but not limited to, financial account information, addresses, business records, or other information that does not identify a natural person.
EU Personal Data means, in addition to Personal Information, other identifying information or attributes specific to your physical, physiological, genetic, mental, economic, criminal and other legal proceedings records, or, cultural, sexual orientation, religious, political, and other social identity, association, or membership that you submit, disclose, or consent to be Processed to or by Subspace Labs (or to a third party that transfers it to Subspace Labs for Processing) while you are in the European Union (“EU”) or United Kingdom (U.K.).
Processing (and Process) includes collecting, recording, organizing, storing, transferring, sharing, using, disclosing, erasing, or destroying your EU Personal Data, whether or not via the Company’s information technologies.
The type of information that we collect related to you depends on how you choose to engage with us. Below is a summary of the types of Personal Information that we collect from you and how it is collected.
If you choose to submit your resume or apply for a specific job for which Subspace Labs is recruiting, we will collect Personal Information about you such as your name, location, email address and career history whether you submit your application through our online application portal or directly via communications with a Subspace Labs department or representative. In all these cases, we are collecting Personal Information from you to provide job recruitment services to you.
Personal Information that you may provide for employment candidacy purposes may also include, but it is not limited to, language skills, salary requirements, race and ethnic information (at your option), veteran status (at your option), and education and work history. With the exception of race, ethnic, and veteran status information, we may use the details you provide on your application and any communications, together with any supporting documents you submit, additional details and documents provided by any references or third parties, including education records and work history records, and any records we make during the recruitment and application process. For race, ethnic, and veteran status information, we only collect and disclose this Personal Information with your consent and then only for government reporting purposes and not for hiring decisions.
In addition to the job candidacy information described above, we may also collect: (i) information you provide at the time of requesting new or additional positions; (ii) records and copies of your correspondence with us; and (iii) any other information you submit to us or which is submitted on your behalf in connection with your application for employment.
Subspace Labs will maintain a copy of the materials you submit in connection with your application for employment for a period of at least 6 years.
Applications for Employment—from the EU or United Kingdom.
In addition to the collection and uses described in Part A of this section, for job applicants located in the EU and the U.K., we collect EU Personal Data from you when you submit your resume or apply for employment or contract work with Subspace Labs, whether you intend to work remotely, or at one of our locations. As is the case for all of our recruitments, the EU Personal Data obtained during your recruitment and application activities, and that we Process, is for the purposes of identifying you, processing your application, verifying the information provided, deciding whether to move forward with your candidacy, and communicating that outcome to you. We may also use or disclose this information for the following statutory or public interest purposes: to prevent or detect fraud; to verify the veracity and accuracy of information provided by you related to employment actions; to meet reporting obligations, such as those in the United States (U.S.) related to equal opportunity in employment and related reports to the U.S. Department Of Labor and the U.S. Equal Employment Opportunity Commission; to assist in decisions regarding reasonable accommodations for a disability, as requested by you; and for research and statistical purposes, and in all cases, none of your EU Personal Data that can identify you will be disclosed without your consent.
We consider the Processing of your EU Personal Data in connection with your recruitment and employment or contractor application process to be necessary for us to take steps toward creating a contractual relationship with you (e.g., to assess your candidacy for jobs of your choosing), necessary for compliance with a legal obligation.We require you to provide us the information we request during the recruitment and application process to assess your candidacy properly.
As well as circulating your application, candidacy profile, and related materials to the appropriate contacts within Subspace Labs, we may share your EU Personal Data, as relevant and necessary, with your references, with entities that provide services to, or on behalf of, Subspace Labs, and with governmental organizations. If you are offered a position, we may include the EU Personal Data collected during your application process in your personnel, contractor or candidate records. For our practices related to your employment or contract engagement with our Company continue reviewing Part B of this section.
As an employee or contractor, Subspace Labs will collect, process, retain, and disclose your Personal Information and EU Personal Data in the manner described in our policies & team handbook, whether you submit your Personal Information and EU Personal Data through our online Gusto portal or directly via communications with a Subspace Labs department or representative. In all these cases, we are collecting Personal Information from you to fulfill our responsibilities to you as described in our employment contract or contractor engagement with you, or as otherwise requested by you.
Aspects of Personal Information of our employees and contractors may be published in the company directory and in analytics information technologies; if you request in writing to your department management, Subspace Labs will endeavor to withhold from publication in the company directory and analytics information technologies your EU Personal Data. Subspace Labs may disclose your EU Personal Data as described in this Policy or as otherwise described in our policies and team handbook, which includes disclosure with your consent, for employment or contractor verification when requested, under subpoena or court order, or to comply with other legal obligations to which Subspace Labs is subject.
Employment with Subspace Labs while you are in the EU establishes obligations based on a contractual relationship between Subspace Labs and you, and the Company’s duties as your employer are subject to U.S./California laws, and Subspace Labs policies and team handbook. Please note that we will need your Personal Data, and at times EU Personal Data, to comply with applicable laws, rules, regulations.
If you choose to submit an application to be considered for our ambassador program, we will collect Personal Information about you such as your name, email, location, telephone number, social media information, and general information about your occupation. We will use your Personal Information to help us determine your eligibility to join the ambassador Program and to make a decision about your membership and to communicate that decision to you.
If you choose to subscribe to our email updates, we will collect your email address from you. Your email address will only be used for the purpose of sending you updates about the progress of Subspace Labs and our ongoing innovations and projects. We use a third-party service provider to manage our email subscriptions. If you choose to subscribe, your email address will be shared with the third-party service provider only for the purposes of fulfilling your request to receive email updates.
When you visit our website, we may collect information about your visit and maintain that information in our web server logs, which are records of the activities on our website. Please review section “Information We Collect Through Cookies and Other Automatic Collection Technologies” of this Policy for details.
We may collect aggregate information about you from third-party service providers such as social media sources, e.g., Twitter or Discord, for purposes of conducting market research. We will not use this information to provide targeted advertising to you or sell it to others.
We will not disclose the Personal Information or EU Personal Data that you provide, or details of your individual visits to this website, to any outside parties except when we have obtained your consent, as provided for in this Policy, or we believe the law requires it.
Subspace Labs uses a third-party applicant tracking software to track and manage job postings, job candidate information, and to manage the jobs portal on our web site. For this reason, your information will be transferred to our applicant tracking software vendor to administer recruitment services. Additionally, we may collect and disclose Personal Information as described in this Policy in connection with the following:
In addition, we may disclose de-identified information in a way that preserves your privacy and does not identify you without restriction (unless prohibited by applicable law).
We do not rent, sell, or trade any of our contact lists or your Personal Information or EU Personal Data and disclose this information only in accordance with this policy as outlined above.
Subspace Labs may, however, aggregate certain elements of your Personal Information or EU Personal Data with the information of other users of our website to analyze the usefulness and popularity of various web pages on its website, such as which areas users visit most frequently. This information is used to improve your online user experience.
Some information is automatically received and sometimes collected from you when you use the Subspace Labs website. This information may include information such as the following, for example and without limitation, (i) name of the domain and host from which you access the Internet, including the Internet protocol (IP) address of the computer you are using and the IP address of your Internet Service Provider; (ii) type and version of Internet browser software you use and your operating system; (iii) date and time you access the website and the length of your stay; (iv) information about your mobile device, including the device’s unique device identifier, mobile network information and device’s telephone number; and (v) demographic information and the language used by the computer or mobile device.
We may also collect general, non-identifying statistical information in connection with the use of the website. To the extent that any such information collected through automatic collection technologies, such as an IP address, is or becomes identified to or otherwise associated with or capable of identifying you, such information will be treated as Personal Information and we will protect it as outlined above.
We use this website activity information to monitor the usage of the website, assess performance, ensure technological compatibility, and understand the relative importance of the information provided on the website. We may also use this data to conduct statistical analyses about users of our website.
Our website uses cookies to analyze trends, support website management, track visitor activity, and to gather demographic and device details. These cookies assist us to customize, personalize and maximize your site experience, including remembering your preferences and improving search results. The cookies also aid us to spot and stop malicious website visitor activity.
Our website uses the following types of cookies:
We use a tool called “Google Analytics” to collect information about use of our website. Google Analytics collects information including how often you visit our website and what pages you visit and what other websites you used prior to coming to and after leaving our website. We use the information we get from Google Analytics only to improve our website. We also may use other analytical tools from time to time. Google Analytics collects only the IP address assigned to you on the date you visit our website. We do not combine the information collected using Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google to identify you. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Use and Google’s Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to our website by disabling cookies on your browser or by opting out of Google Analytics.
You may activate “do not track” signals and requests sent from your browser to websites you visit indicating you do not want to be tracked or monitored. Most often, you need to affirmatively elect to turn on the do not track signals or requests. Websites are not required to accept these signals or requests, and many do not. Currently, we do not track signals or requests.
Some jurisdictions (state, federal, national and international), provide individuals with certain rights regarding their personal information. Examples of these laws, (without limitation) are: California (California Consumer Protection Act (“CCPA”) or the California Privacy Rights Act (“CPRA”)), Canada (Personal Information Protection and Electronic Documents Act (“PIPEDA”), and the European Economic Area (General Data Protection Regulation (“GDPR”)). For your specific rights under the GDPR, please review the section “Exercising your GDPR Privacy Rights” below. To exercise any rights your jurisdiction may provide, contact us by using the information at the bottom of this section. Your rights will depend on the location in which you reside when your Personal Information or EU Personal Data is collected or otherwise Processed. The following illustrates the rights that may be afforded under the CCPA, PIPEDA, GDPR, or your jurisdiction collectively:
Some states require specific information regarding our practices and that your rights be provided to you in the form of a privacy notice. These notices are provided in the State Specific Privacy Notices section below.
To exercise any of your individual rights, contact us by email at hello@subspace.network or by mail at Subspace Labs, Inc., 450 Cambridge Ave, Suite 300, Palo Alto, CA 94306.
We may require that you verify your identity before exercising your individual rights. In most circumstances, individual rights are not absolute and where applicable law permits or requires, we may choose to limit or deny a request. If we limit or deny a request, we will provide an explanation in writing.
Subspace Labs will respond to your request within thirty (30) days of receipt. The period of response may be extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.
This section describes Subspace Labs’ data practices which are in accordance with GDPR requirements (“EU Privacy Provisions”).
These EU Privacy Provisions supplement Subspace Lab’s Privacy Statement and should be read together with the Privacy Statement. These EU Privacy Provisions are intended to be consistent with the GDPR principles of privacy, fairness, lawfulness, transparency, purpose limitation, accuracy, storage limitation, integrity, and accountability. For more information regarding the GDPR and these principles, please refer to the full text of the GDPR. Terms in these EU Privacy Provisions are used consistent with their definitions in the GDPR.
These EU Privacy Provisions apply to you only if and to the extent that Subspace Labs is Processing your EU Personal Data (as defined above), where the Processing is related to the Company offering goods or services to you in the EU, or where the Company is monitoring your behavior in the EU (e.g., through website activity analytics).
We may Process your EU Personal Data in accordance with these EU Privacy Provisions, the Company’s Privacy Statement (along with any relevant Privacy Notices), and as permitted or required by law. If you do not agree with these EU Privacy Provisions, please do not provide any EU Personal Data to Subspace Labs. If you choose not to provide any EU Personal Data that is necessary for us to perform requested actions or to provide you with specific products or services, the Company may not be able to act upon your requests or provide those products or services to you.
We will only process the Personal Information and EU Personal Data subject to the GDPR as it is described in this Policy if we have a lawful basis for doing so, which may include but is not limited to the following conditions:
For U.K. and EU residents protected by the GDPR, you have certain rights relating to your Personal Information and EU Personal Data, subject to local data protection laws.
To exercise these rights, please submit your specific request by email at hello@subspace.network; or by mail at Subspace Labs, Inc., 450 Cambridge Ave, Suite 300, Palo Alto, CA 94306.
We may require that you verify your identity before exercising your individual rights. In most circumstances, individual rights are not absolute and where applicable law permits or requires, we may choose to limit or deny a request. If we limit or deny a request, we will provide an explanation in writing. Please review the “Data Retention” section below before submitting your request.
Subspace Labs will respond to your request within thirty (30) days of receipt. The period of response may be extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.
You may also file a complaint concerning the processing of your EU Personal Data with the applicable EU Supervisory Authority. You can also utilize the Supervisory Authority Contact Information for all EU countries.
The Subspace Labs web site does not constitute an offer or contract. Information on this website may contain inaccuracies or typographical errors. Information may be changed or updated without notice.
If you click on links within the website (such as social media) that take you to third-party websites, you will be subject to the third parties’ privacy policies, practices and statements. We are not responsible for the actions or inactions of any third-party websites, the accessibility of any third-party website or the policies or practices of any third-party website.
The website is targeted for use only by adults. Accordingly, we do not knowingly collect any Personal Information from children under the age of 13. In the event we discover that a child has provided information to us, we will delete that information to the extent technologically possible. If you believe we have received information about a child, please contact us using the information provided at the end of Your Individual Rights (above).
We are committed to protecting the security of your Personal Information and EU Personal Data as applicable. We use a variety of measures to ensure that your Personal Information (including the information in your resume) is protected from unauthorized access and improper use or disclosure. However, the Internet is an open system and Subspace Labs cannot guarantee that the Personal Information you submit will not be intercepted by others. You should also be aware that your current place of employment may monitor your online activity, including the sites that you visit.
Our website may include links to external websites operated by other organizations that may collect Personal Information from visitors to their site. We cannot guarantee the content or privacy practices of any external websites and do not accept responsibility for those websites. Before engaging with external websites, please review their privacy policy and practices.
Notwithstanding your privacy rights under the GDPR and other applicable privacy laws and regulation, the Company maintains a data retention policy to ensure and demonstrate compliance with various U.S. laws and regulations. For these reasons, please be aware that Subspace Labs may not always be able to fulfil particular requests for data erasure of Personal Information or EU Personal Data as contemplated in the GDPR or jurisdiction-specific data privacy laws. Before submitting requests related to your data rights, please review the following retention periods applicable to you:
Upon the passing of the pertinent retention period, we will securely and permanently destroy the above-referenced records comprising your Personal Information and EU Personal Data.
Under Colorado’s Consumer Privacy Act (CPA), which goes into effect July 1, 2023, Colorado residents have certain rights around Subspace Labs’ collection, use, and sharing of their Personal Information.
We do not currently sell any Personal Information we collect to any third parties. We also do not engage in “targeted advertising” as the term is defined in the CPA. If we were to do so in the future, we will update this Policy, and provide Colorado residents with the opportunity to opt-out of any targeted advertising or the sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.
We collect various categories of Personal Information depending on how you choose to engage with us as described in the sections Information We Collect About You and How We Use and Disclose Personal Information. How We Use and Disclose Personal Information also describes how and under what circumstances Personal Information may be shared with third parties.
If you are a resident of Colorado, starting July 1, 2023, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under the CPA and other laws may allow Subspace Labs to retain and use your Personal Information notwithstanding your deletion request); and (4) obtain a copy of your Personal Information.
If you have any questions or comments, or would like to exercise any of your rights, please contact us using the information in the Questions, Comments and Contact Information section below.
Under the Connecticut Data Privacy Act (CTDPA), which goes into effect July 1, 2023, Connecticut residents have certain rights around Subspace Labs’ collection, use, and sharing of their Personal Information.
We do not currently sell any Personal Information we collect to any third parties. We also do not engage in “targeted advertising” as the term is defined in the CTDPA. If we were to do so in the future, we will update this Policy, and provide Connecticut residents with the opportunity to opt-out of any targeted advertising or the sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.
If you are a resident of Connecticut, starting July 1, 2023, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under CTDPA and other laws may allow Subspace Labs to retain and use certain Personal Information notwithstanding your deletion request); and (4) obtain a copy of your Personal Information.
If you have any questions or comments, or would like to exercise any of your rights, please contact us using the information in the Questions, Comments and Contact Information section below.
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operators may collect about them.
We do not presently sell any personal information we collect to any third parties. If we were to do so in the future, we will update this Policy, and provide Nevada residents with the opportunity to opt-out of the sale of their personal information
Under Utah’s Consumer Privacy Act (UCPA), which goes into effect December 31, 2023, Utah residents have certain rights around Subspace Labs’ collection, use, and sharing of their Personal Information.
We do not presently sell any personal information we collect to any third parties. We also do not engage in “targeted advertising” as the term is defined in the UCPA. If we were to do so in the future, we will update this Policy, and provide Utah residents with the opportunity to opt-out of any targeted advertising or the sale of their Personal Information.
If you are a resident of Utah, starting December 31, 2023, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request deletion of your Personal Information (exceptions under UCPA and other laws may allow Subspace Labs to retain and use certain Personal Information notwithstanding your deletion request); and (3) obtain a copy of your Personal Information.
If you have any questions or comments, or would like to exercise any of your rights, please contact us using the information in the Questions, Comments and Contact Information section below.
Under Virginia’s Consumer Data Protection Act (CDPA), which goes into effect January 1, 2023, Virginia residents have certain rights around Subspace Labs’ collection, use, and sharing of their Personal Information.
We do not currently sell any Personal Information we collect to any third parties. We also do not engage in “targeted advertising” as the term is defined in the CDPA. If we were to do so in the future, we will update this Policy, and provide Virginia residents with the opportunity to opt-out of any targeted advertising or the sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.
We collect various categories of Personal Information depending on how you choose to engage with us as described in the sections Information We Collect About You and How We Use and Disclose Personal Information. How We Use and Disclose Personal Information also describes how and under what circumstances Personal Information may be shared with third parties.
If you are a resident of Virginia, starting January 1, 2023, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under CDPA and other laws may allow Subspace Labs to retain and use certain Personal Information notwithstanding your deletion request); and (4) obtain a copy of your Personal Information.
If you have any questions or comments, or would like to exercise any of your rights, please contact us using the information in the Questions, Comments and Contact Information section below.
This Policy, which incorporates the GDPR data policies and practices of the Company, was last modified on the date identified below. If we change our Policy, we will post those changes on our website. You are responsible for visiting this Privacy Statement and Notice to check for any updates.
If you have any questions or comments concerning our Privacy Statement, please contact us by email at hello@subspace.network; or by mail at Subspace Labs, Inc., 450 Cambridge Ave, Suite 300, Palo Alto, CA 94306.
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