This Privacy Policy describes how Provenance Blockchain Labs collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.

When we refer to “Provenance Blockchain Labs”, we mean Provenance Blockchain Labs, Inc., as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Applicability of This Privacy Policy

This Privacy Policy applies to Provenance Blockchain Labs’s online platform and Services (collectively, the “Services”), NuvaLabs.com and other Provenance Blockchain Labs' websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Provenance Blockchain Labs. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of Provenance Blockchain Labs’s business. For the avoidance of doubt, this is the only privacy policy that applies to Provenance Blockchain Labs.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Provenance Blockchain Labs platform (“Third-Party Services”), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of data such as documents, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into a Master Services Agreement (“Customer”) controls its instance of the Services (its “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “Information Use.” To learn more about exercising your California Privacy Rights please review the “California Privacy Rights” section below.

Information We Collect And Receive

Provenance Blockchain Labs will collect and receive information through operating the Services and Websites, and through other interactions with Provenance Blockchain Labs. Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:

• Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data (such as documents, files or other content submitted through Services accounts) to Provenance Blockchain Labs when using the Services.

• Other Information. Provenance Blockchain Labs also collects, generates and/or receives the following categories of Other Information:

  1. Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) may supply Provenance Blockchain Labs with a name, email address, phone number, digital wallet address, and/or other account set up details.

  2. Usage information:

     • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services. For example, Provenance Blockchain Labs may log the Workspaces, people, features, content, and links you view or interact with, the types of files shared and what Third-Party Services are used (if any).

     • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.

     • Device information. Provenance Blockchain Labs may collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

     • Location information. We receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes. We also use a Third-Party Services to run geo / IP blocking and digital wallet blocking, as required for regulatory compliance.

  3. Cookie information: Provenance Blockchain Labs may use a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie Policy.

  4. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace, with exception to those required to achieve regulatory compliance, and Provenance Blockchain Labs can receive personal data from such Third-Party Services. To make changes to Third-Party Services, the Customer should contact their Provenance Blockchain Labs’ Account Manager. Typically, Third-Party Services are software that integrate with our Services. Once enabled, the provider of a Third-Party Service may share certain information with Provenance Blockchain Labs. For example, if a cloud storage application you are using is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorized Users, along with additional information that the application makes available to Provenance Blockchain Labs to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Provenance Blockchain Labs. When a Third-Party Service is enabled, Provenance Blockchain Labs is authorized to connect and access Other Information made available to Provenance Blockchain Labs in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information which Provenance Blockchain Labs may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to Provenance Blockchain Labs usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.

  5. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import or log in the Services is collected when using the Services.

  6. Third-Party data: Provenance Blockchain Labs may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from Customers, affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

  7. Additional information provided to Provenance Blockchain Labs: We also receive Other Information when submitted to our Websites or in other ways, such as lead form competitions, responses or opinions you provide, feedback you provide about our products or services, information you provide if you apply for a job with Provenance Blockchain Labs, enroll in a webinar or other program hosted by Provenance Blockchain Labs or a vendor, request support, interact with our social media accounts or otherwise communicate with Provenance Blockchain Labs.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How We Process Your Information and our Legal Bases for Doing So

Customer Data will be used by Provenance Blockchain Labs in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Master Services Agreement, a Customer’s use of Services functionality, and as required by applicable law. Provenance Blockchain Labs is a processor of Customer Data and the Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share, make changes to Third-Party Service providers, and remove Customer Data, and otherwise apply its policies to the Services.

Provenance Blockchain Labs uses Other Information to operate our Services, Websites, and business. More specifically, Provenance Blockchain Labs uses Other Information for the following purposes:

Compliance With A Legal Obligation:

Provenance Blockchain Labs processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, and Additional information provided to Provenance Blockchain Labs for compliance with a legal obligation.

Legitimate Interests:

We rely on our legitimate interests or the legitimate interests of a third-party where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests").

We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, and Additional information provided to Provenance Blockchain Labs for the following legitimate interests:

• To provide, update, maintain and protect our Services, Websites and business.

  
  

  This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.

  • It is in our and your interests to provide, update, maintain and protect our Services, Websites, and business.

• To develop and provide productivity tools and additional features.

  
  

  Provenance Blockhain Labs tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may:

  • make Services or Third-Party Service suggestions based on historical use and predictive models;

    • identify organizational trends and insights;

    • customize a Services experience; or

    • create new productivity features and products.

  • It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.

• To investigate and help prevent security issues and abuse.

  
  

  We may process, including in an automated fashion, Other Information to better understand how Provenance Blockchain Labs is used or to prevent spam or abuse.

  • It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.

• To aggregate or de-identify information.

  
  

  In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.

  • It is in our interest to research and improve the Services;

  • It is in the interests of Customers and Authorized Users to practice data minimisation and privacy by design in respect of their information.

• Share information with others including law enforcement and to respond to legal requests.

  • It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of Provenance Blockchain Labs, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.

• Transfer, store or process your information outside the European Economic Area.

  
  

  As the Websites and Services operate globally, with Customers around the world, we need to share information we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea, and the United States, to provide, update, maintain and protect our Services, Websites and business.

  
  

  For more information, review the “International Data Transfers” section below.

  • In our and your interests to provide, update, maintain and protect our Services, Websites and business.

We use Workspace and account information, Third-Party Services Information, Third-Party data, and Additional information provided to Provenance Blockchain Labs for the following legitimate interests:

• To communicate with you by responding to your requests, comments and questions.

  
  

  If you contact us, we may use your Other Information to respond.

  • It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).

• To send service emails and other communications.

  
  

  For example, we may:

  • send you service, technical and other administrative emails, messages, and other types of communications; or

  • contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. It is in our Customers and Authorized Users’ interests to address service related issues.

We use Workspace and account information and Usage information for the following legitimate interests:

• For billing, account management and other administrative matters.

  
  

  Provenance Blockchain Labs may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.

  • It is in our interest to facilitate the effective provision and administration of the Websites and Services.

We use Workspace and account information, Usage Information, Cookie information, Third-Party Services Information, Third-Party data, and Additional information provided to Provenance Blockchain Labs for the following legitimate interests:

• To send marketing emails and other communications.

  
  

  We sometimes send emails about new product features, promotional communications or other news about Provenance Blockchain Labs. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Provenance Blockchain Labs please get in touch through the contact mechanisms described below.

  • It is in our interest to promote the Websites and Services and send our direct marketing.

How We Share and Disclose Information

This section describes how Provenance Blockchain Labs may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. Provenance Blockchain Labs does not control how a Customer or any third party chooses to share or disclose Information.

• The Customer’s Instructions. Provenance Blockchain Labs may share and disclose Information in accordance with the Master Services Agreement or with other written consent from a Workspace Owner and Administrator, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process.

• Displaying the Services. When an Authorized User submits Information, it may be displayed or discoverable to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s name or digital wallet address may be displayed within and outside of their associated Workspaces.

• Customer access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details, or to export logs of Workspace activity.

• Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist Provenance Blockchain Labs with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, Provenance Blockchain Labs may share your Information.

• Third-Party Services. A Customer may enable Third-Party Services. When Third-Party Services are enabled by a Customer, Provenance Blockchain Labs may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Provenance Blockchain Labs and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.

• Public Blockchain. Certain Information, e.g., your digital wallet address(es) and the digital wallet address(es) of your Employer and certain metadata contained within the transactions associated with those wallets, will be publicly available.

• Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by Provenance Blockchain Labs, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.

• Corporate Affiliates. Provenance Blockchain Labs may share Information with our corporate affiliates, parents and/or subsidiaries.

• During a Change to Provenance Blockchain Labs’ Business. If Provenance Blockchain Labs engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Provenance Blockchain Labs' assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.

• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research, or as aggregate data presented in the Services or on the websites.

• Law Enforcement and Regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may at times include information that Provenance Blockchain Labs, Inc. processes in its role as a subprocessor, including as pursuant to the terms of any Master Services Agreement between Provenance Blockchain Labs and its Customers.

• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Provenance Blockchain Labs, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.

• With Consent. Provenance Blockchain Labs may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For Workspaces registered to corporate entities, Provenance Blockchain Labs may share Information with consent of the Workspace primary owner or authorized corporate officer, or their designee. For workplaces created without a formal affiliation, Provenance Blockchain Labs may require user consent.

Data Retention

Provenance Blockchain Labs will retain Customer Data in accordance with the Master Services Agreement and as required by applicable law. Upon further written request, the deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information.

Provenance Blockchain Labs may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for Provenance Blockchain Labs to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

Security

Provenance Blockchain Labs takes security of data very seriously. Provenance Blockchain Labs minimizes the need to retain any sensitive or personally identifiable data. Provenance Blockchain Labs works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Provenance Blockchain Labs cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

Provenance Blockchain Labs does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

Provenance Blockchain Labs may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.

International Data Transfers

Provenance Blockchain Labs may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, Provenance Blockchain Labs will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Provenance Blockchain Labs’ obligations.

Data Protection Officer

To communicate with our Data Protection Officer, please email legal@nuvalabs.com, with the subject line: Data Protection Office.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Provenance Blockchain Labs is the processor of Customer Data and the controller of Other Information.

• Provenance Blockchain Labs, Inc, a U.S. company based in Monmouth Beach, New Jersey is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers globally.

Your Rights

Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information. You can do this by emailing legal@nuvalabs.com with the subject line: My Personal Data.

To the extent that Provenance Blockchain Labs’ processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Provenance Blockchain Labs primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting Provenance Blockchain Labs” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. Provenance Blockchain Labs may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Provenance Blockchain Labs' use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by the California Privacy Rights Act or “CPRA”.

California law requires that we detail the categories of personal information that we collect and disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of Privacy Policy. In addition to the information provided above in the ‘Information We Collect And Receive’ section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Services for our business purposes:

• Identifiers/contact information;

• Commercial information;

• Internet or electronic network activity information;

• Financial information;

• Geolocation information;

• Professional or employment-related information;

• In limited circumstances where allowed by law, information that may be protected under California or United States law; and

• Inferences drawn from any of the above categories.

We collect this information for the business and commercial purposes described in the ‘How We Process your Information and our Legal Bases for Doing So’ section above. We share this information as described in the ‘How We Share and Disclose Information’ section above. Provenance Blockchain Labs does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-Provenance Blockchain Labs websites, applications, and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any “sales”, to know and opt out of sharing of personal information for delivering advertisements on non-Provenance Blockchain Labs websites, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at legal@nuvalabs.com, with the subject line: My Personal Data in California. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.

If you would like to opt-out of sharing activity based on your cookie identifiers, turn on a Global Privacy Control in your web browser or browser extension. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. If you would like to opt-out of sharing activity based on other identifiers (like email address or phone number), contact us in accordance with the “Contacting Provenance Blockchain Labs” section, below.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Provenance Blockchain Labs’ use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.

Contacting Provenance Blockchain Labs

Please also feel free to contact Provenance Blockchain Labs if you have any questions about this Privacy Policy or Provenance Blockchain Labs' practices, or if you are seeking to exercise any of your statutory rights. Provenance Blockchain Labs will respond within a reasonable timeframe. You may contact us at legal@nuvalabs.com or at our mailing address below:

Provenance Blockchain Labs, Inc.

36 Beach Road, #178

Monmouth Beach, New Jersey 07750

United States