LAST UPDATED: August 14, 2024

DecideAI DAO LLC, a non-profit limited liability company (the “Company”), registered as a Marshall Islands DAO LCC, with registered offices located at PO Box 852, Long Island Rd, Majuro, Marshall Islands MH 96960, (the “Company”).

Contact: support@decideai.xyz

The purpose of this document is to provide information regarding the processing of personal data by the Company.

Decide ID: As part of the Sites, the Company provides access to, among other services, the DecideAI Platform platform (the “Platform”). This Agreement governs your use of our Sites, the Platform, and all related tools, applications, data, software and other services provided by us (collectively, the “Services”).

Blockchain: refers to a distributed ledger technology (DLT) (ex: Dfinity Internet Computer).

Personal Data, Data: refers to any information relating to an identified or identifiable natural person, as defined in Article 4 of the GDPR.

DecideAI, We, Us, Our: refers to the Company, as identified in the first page.

Service: refers to the service provided by DecideAI, as described on the Platform and in the Terms.

Terms: refers to the terms and conditions applicable to the Services.

Users, You, Your: refers to any data subject to the collection and processing of Personal Data by DecideAI for a Decide ID.

Platform: refers to the website https://decideai.xyz/ and the decentralised application (dApp)https://id.decideai.xyz/ .

Unless stated otherwise, definitions stated in the singular shall have the same meaning in the plural form.

Any term defined in Article 4 of the GDPR and mentioned in this Privacy Policy shall have the same meaning.

We operate the decentralized application (dApp) https://id.decideai.xyz/., available in particular through thehttps://decideai.xyz/ website and allowing You to associate Your identity with a public cryptographic address registered on a Blockchain thanks to a Decide ID, in order to carry out Proof of Personhood on third party platforms. We believe that trust is the key to successful and lasting relationships. In this respect, the protection of your personal data and privacy is no exception. For this reason, We take great care to collect, process and store Your Personal Data only with the utmost care and in strict compliance with the applicable legal framework.

In drafting this Privacy Policy and making it available to You, We intend to fulfill Our duty to inform data subjects within the meaning of Articles 13 and 14 of the Regulation EU (2016/679) of the EU Parliament and the Council of 27 April 2016 (the “ GDPR ”).

This Privacy Policy will describe how Your Personal Data is processed when You navigate on the Platform and use the Service.

Biometric Data. To enable the creation of Your Decide ID. We collect and process Biometric Data. DecideAI gathers face geometry data points through a 3D face scan, which are used for Decide ID Proof of Personhood, as well as liveness data (referred to as "Biometric Data"). Decide ID leverages the third party services of AWS Rekognition.

The communication of this Data is a condition for the provision of the Service.

Navigational information. In order to enhance the User experience, we want to understand your interactions with the Service. Therefore, We need to analyze various navigational information collected through cookies to analyze performance related to Your use of the Platform. Such information includes: Unique identifiers (Your computer's internet protocol, browser type and settings, device type and settings, operating system). Interaction information (IP address, system activity, date and time of requests, length of navigation). Pages You browse on the Platform. To do so, We rely on Our legitimate interest to (i) understand how Our Platform is browsed by Users; (ii) improve the Platform and the performance of Our Service if necessary; (iii) inform Users about Our Service and promote the Service; and (iv) detect and prevent fraud or security issues with Our Platform and Service. The communication of this Data might be necessary for You to efficiently browse on the Platform.

Communications. We collect and process Personal Data in order to respond to any questions, requests or feedback that You may submit to us, including: Identification information (Your name and email address). The content of the message that You send to Us. This processing is based on Our legitimate interest to manage Our relationship with You. The communication of this Data is necessary for Us to respond to Your requests.

We will store Your Personal Data, including but not limited to; Biometric Face Map, Proof of Personhood Certificate and Decide ID as long as You use the Decide ID, to enhance and provide the Service. Biometric Face Map data is stored on decentralized cloud storage AWS, encrypted before storage. Proof of Personhood Certificate and Decide ID are stored in a canister on the blockchain.

We retain the data we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, comply with applicable laws, or improve our services. Typically, we securely retain information collected in accordance with our data retention practices. If required by law, we will delete your information within the mandated period. You may request the deletion of your data at any time by contacting us at support@decideai.xyz.

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries. If you are accessing our Services from the European Economic Area (“EEA”) or other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United States as necessary for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the country in which you reside we will take steps designed to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected.

You are never compelled to provide any Personal Data that We may request. However, we draw your attention to the fact that: if You refuse to provide identification Data, the creation of the Decide ID and the use of the Service will be impossible; if You refuse to provide navigational information, the access to the Platform or its performance may be impacted.

In any event, and regardless of the purpose of the processing in question, We will adhere to a strict principle of Data minimisation and will therefore only collect and process Personal Data that is necessary for the purposes mentioned above.

Under certain data privacy laws, including the General Data Protection Regulation for users in the EEA, you may have the right to exercise certain privacy rights available to you under applicable data protection laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

• Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain Personal Data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
• Right of access and/or portability. You may have the right to access the Personal Data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
• Right of erasure. In certain circumstances, you may have the right to request the erasure of Personal Data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
• Right to object to processing. You may have the right to request that DecideAI stop processing your Personal Data and/or to stop sending you marketing communications.
• Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.
• Right to restrict processing. You may have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the Personal Data we hold about you is not accurate or lawfully held).
• Right to a manual review of automated decisions. If we have determined you are not eligible to receive a Decide ID or if your Decide ID was frozen or revoked based on our automatic decision-making procedures, you may have the right to request a manual review.
• Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your Personal Data.

This section is applicable to residents of California. If you are a resident of California, you have certain rights described below. The following do not apply to individuals who do not live in California on a permanent basis.

Rights Provided By California Civil Code Section 1798.83

A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. We do not disclose personal information to any third party for their direct marketing purposes.

Rights Under the California Consumer Privacy Act

This section of our Privacy Policy provides California residents with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California consumers regarding their personal information under the California Consumer Privacy Act (“CCPA”). This section applies to all California residents (but not including legal entities, such as companies). The section will not apply, however, if we do not collect any personal information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available). “Personal information,” for purposes of this section regarding the rights of California residents, does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

In the past 12 months we have collected the following categories of information about you:

• Identifiers such as your name, address, identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Financial, credit card, or debit card information.
• Characteristics of protected classifications under California or federal law, such as your age and national origin.
• Biometric information.
• Internet or other electronic network activity information.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• All such information was collected from sources as described in the section “Personal Data We Collect” and for the purposes described in the section “How We Use Information We Collect”. We only disclose such information to third parties as described in the section “How We Disclose Your Information”. We do not sell personal information.

Under the CCPA, California residents have the following rights:

• Right to know about personal information collected, disclosed, or sold. California residents have the right to request that we disclose what personal information it collects, uses, discloses, and sells. This is called the “Right to Know”. Under the Right to Know, you can request a listing of the types of personal information we have collected about you, the sources of that information, how we use the information (e.g., our business or commercial purposes for collecting or selling personal information), other individuals and business with whom we share personal information, and the specific pieces of personal information that we have collected about you. In certain cases, a Request to Know may be denied, for example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.
• Right to request deletion of personal information about you.California consumers have a right to request the deletion of their personal information that we have collected or maintain. In certain cases, a request for deletion may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing services. If we deny your request, we will explain why we denied it and delete any other information that is not protected from deletion.
• Right to opt-out of the sale of personal information.California consumers have a right to opt-out of the sale of their personal information by businesses. We do not sell personal information, however, so opt-out is not relevant.
• Right to non-discrimination for the exercise of a consumer’s privacy rights. You have a right not to receive discriminatory treatment by us for exercising any of your privacy rights conferred by the CCPA. We will not discriminate against any California consumer because such person exercised any of the consumer’s rights under CCPA, including, but not limited to:
  • Denying goods or services.
  • Charging different prices or rates for goods and services, including through the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services.
  • Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided to you by your data.

If you would like, you may designate an authorized agent to make a request under the CCPA on your behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.

To exercise any of the rights above including under the CCPA, contact us at suport@decideai.xyz or using the contact information listed below. Please identify yourself and specify your request. If you have a password protected account, we may generally use your account information to verify your identity. If not, we may ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

We use commercially reasonable efforts to address requests to delete your Personal Data but may retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

We take steps that we deem as commercially reasonable in an effort to ensure that your information, including Personal Data, is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure or error free, and we cannot ensure or warrant the security or integrity of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services or third-party websites.

By using the Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an email to you.

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us at support@decideai.xyz. If we learn that we have collected any child’s Personal Data in violation of applicable law, we will promptly take steps to delete such information.

We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, access times, location information (including inferred location based off your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with your account and the devices you use.

Cookies, Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.

Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may use Google Analytics and other service providers to collect information regarding behavior and demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You may be able opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

We may collect information about you from additional online and offline sources including commercially available third-party sources, for the purposes of verifying eligibility and securely offering our Services to you. We may combine this information with the personal and other information we have collected about you under this Privacy Policy.

We may review and update this Policy. Any changes we make will be posted on the Platform and, where appropriate, notified to You. Please check back frequently to see any updates or changes to Our Privacy Policy. If you have any concerns about how your data is managed, you may contact us at support@decideai.xyz.

It is important that any Personal Data We hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

For any questions or concerns regarding your privacy or this Privacy Policy, please contact support@decideai.xyz

If you have any questions about our privacy practices or this Privacy Policy, or you would like to exercise your rights described above, please contact us at:

DecideAI DAO LLC
Attn: PO Box 852, Long Island Rd, Majuro, Marshall Islands MH 96960
Email: support@decideai.xyz