Last Modified: June 5, 2019

This Privacy Policy (“Policy”) describes the collection, use, and disclosure of personal information by Hypernet Labs, Inc. (“Hypernet Labs,” “we,” or “us”) from users that access or use the websites or blogs provided by us (collectively, the “Sites”), as well as all related applications, software, tools, and other services provided by us (collectively, together with the Sites, our “Services”). This Policy only applies to users and customers who access or visit the Services owned or operated by Hypernet Labs; it does not apply to any third-party websites, services or applications, even if they are accessible through our Services.  We may refer to users and customers collectively as “you” within this Policy.


Please read Hypernet Labs’ Terms of Service and any Terms of Service that may be specific to a particular Service (collectively, the “Terms”). By accepting the Terms, you agree with our privacy practices as described in this Policy.  If you do not agree with this Policy or the Terms, please stop accessing or using our Services.


We may modify or update this Policy from time to time by posting a revised version and updating the “Last Modified” date above. We may provide you with additional forms of notice as appropriate under the circumstances, such as email notices to the most recent email address we have on file for you. Your continued use of our Services after any modification to this Privacy Policy will constitute your acceptance of such modification.

In addition, we may provide you with “just-in-time” disclosures or additional information about the data handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.


Personal information is any information that identifies you or makes you identifiable (“Personal Information”). Any information that is anonymized or aggregated is no longer Personal Information.  We collect your Personal Information in order to provide you with our Services and support.  

We may collect the following types of information:

  • Information You Provide to Us. When you use the Services or engage in certain activities, such as registering for an account with Hypernet Labs, posting on our Services, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
    • Account Information. If you create an account through Hypernet Labs, we’ll collect certain information that can be used to identify you, such as your name, email address, username, encrypted password, connection status, and IP address. If you create an account using your login credentials from one of your social media accounts such as Facebook, Google, or Twitter, we may be able to access and collect your name, email address and other information (such as gender and date of birth) that your privacy settings and/or the privacy policy on the social media account permit us to access.
    • Ethereum Account, Wallet and Blockchain. If you choose to use additional features of the Services, you may decide to register for an Ethereum account and wallet.  Ethereum is a separate third-party company, and you should read its privacy policy and terms of service. You should be aware that Personal Information stored on the blockchain cannot be changed or deleted.
    • Transaction Details. If you make a transaction using any Service, we record the status of the transaction, information about the recipients, amount, and additional technical details.  We also store a unique ID that can be used as proof that a payment was made.  To help create and maintain a trusted environment, we may collect and retain Personal Information for identity verification purposes (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. This Personal Information may be shared with our third-party service providers for identity verification and compliance purposes.
    • Communications with Us. We may collect Personal Information from you such as name, user name, phone number, email address, or mailing address when you choose to request information about our Services, register for our newsletter or blog, request customer or technical support, or otherwise communicate with us.
    • Contests, Leaderboards and Surveys. From time to time, you may participate in online contests, leaderboards or surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. We may use such information to improve our products and Services and/or in any manner consistent with the policies provided herein.
    • Interactive Features. Our Services contain interactive functionality that allows you to engage with other users on the Services, provide feedback, post comments to our forums, upload videos, photographs and other content (the “User Materials”), participate in contests and surveys, and otherwise interact with the Services and with other users. If you use any interactive functionality on our Services that require or permit you to provide us with Personal Information (including, for example, any Services that allow you to post User Materials on any of our Services), we collect the Personal Information that you provide to us in the course of using these interactive features. If you choose to submit content to any public area of a Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
    • Device Information and Activity Data. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other identifiers that are automatically assigned to your desktop, laptop, tablet, or phone (“Devices”) when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
    • Geolocation Information.  We may collect your geolocation information if your Device has enabled sharing of your precise geolocation data.  If you do not want us to collect your geolocation, you may change your location-sharing preferences in the settings of your mobile device.
  • In addition, we may collect Personal Information disclosed by you on our message boards, chat features, blogs and our other Services to which you are able to post information and materials. Any information that is disclosed in those forums becomes public information and may therefore appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties.  It could also be read, collected or used by other users to send you unsolicited messages. Please do not post any information that you do not want to reveal to the public at large.


We may receive information about you from other sources, including through third-party services and organizations, that supplements information provided by you. For example, if you access our Services through a third-party application, such as an app store or Amazon Simple Notification Service (“SNS”), we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through app stores or SNS accounts may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts on the application or SNS. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

5. How Your PERSONAL Information IS USED

Our primary purpose in collecting Personal Information is to ensure our customers have a smooth and customized experience. In general, we use Personal Information to operate, deliver, and improve our Services.  We may use your Personal Information for a variety of business purposes, including:

  • Providing the Services.  When accessing our website or otherwise using our Services, we collect certain information about you to be able to support your requests.  For example, we collect your account information so that you can access and use our Services securely. We cannot provide you with our Services without processing your Personal Information.
  • Providing Service-Related Communications.   If you are using our Services, we will send you administrative or service-related information.  Such communications may include confirmation of your transactions, technical notices, security updates, or other relevant information.  Service-related communication are not promotional in nature and are not marketing communications. You cannot unsubscribe from service-related communications because they may affect the way you access and use the Services.
  • Enforcing our Terms, Agreements or Policies. We process your Personal Information to enforce certain terms, agreements and policies relevant to our relationship with you, including any agreements with third-party partners. We may collect fees based on your use of the Services, and actively monitor, investigate, prevent or mitigate any alleged or actual prohibited, illicit or illegal activities on our Services. This processing allows us to maintain a trusted environment for you. We cannot perform the Services without such processing.
  • Providing Secure Services. We are committed to ensuring your Personal Information is processed securely on our Services. To maintain the security of our Services, we may process your Personal Information to investigate, detect, prevent or report fraud, misrepresentation, security incidents or breaches, spam, malware, malicious activities or other prohibited or illegal activities.  In addition, we process your Personal Information to improve the security of our Services. We cannot provide the Services securely without such processing.
  • Engaging in Marketing Activities.  We may use Personal Information provided by you or obtained from third parties to provide you with materials about offers, products, services, contests, promotions, discounts, incentives, surveys, rewards and more offered by us or our business partners that may be of interest to you. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. You may unsubscribe from marketing communications at any time and without charge, as further described below.
  • Conducting Research and Product Development. We may process your Personal Information to improve, optimize or expand our Services or features of our Services. We do so by processing information about your use of the Services, any information you provide to us, and by measuring, tracking and analyzing trends and usage in connection to your use or the performance of our Services. We take additional security measures when processing your Personal Information for such purposes, such as de-identifying your Personal Information to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, or de-identified information about the Device from which you access the Services.  Such anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.   We may use such information alone or in the aggregate with information obtained from other sources in order to help us optimally deliver our existing products and Services or develop new products and Services. Additionally, from time to time, we may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf.  All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve our users by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If you participate in a survey, the information provided will be used along with that of other survey participants.
  • Providing Customer Support.  Whenever you contact us for customer support or any other reason (e.g., to diagnose or fix technology problems, to provide feedback, to notify us of a dispute, etc.), we process any information you provide to us and any information we already have about you. Without processing your Personal Information for such purposes, we cannot respond to you or ensure your continued use and enjoyment of the Services.  
  • Providing Services via Mobile Devices. From time to time, we may provide Services that are specifically designed to be compatible with and used on mobile Devices. We will collect certain information that your mobile Device sends when you use such Services, like a Device identifier, user settings, location information, mobile carrier, and the operating system of your Device.  Mobile versions of our Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts.  In addition, we may enable users to download an application, widget, or other tool that can be used on mobile or other computing Devices.  Some of these tools may store information on mobile or other Devices. These tools may transmit Personal Information to us to enable users to access accounts and to enable us to track use of these tools.  Some of these tools may enable users to email reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices we provide.
  • Maintaining Legal or Regulatory Compliance. We may be required to process your Personal Information under certain laws and regulations, such as tax laws or other business obligations, or as otherwise required by applicable law. We cannot provide the Services to you without such processing.  

We will disclose to you any other uses of your Personal Information in connection with our Services prior to processing your Personal Information for such purposes. You may choose not to allow us to process your Personal Information for any purposes that are not compatible with the purposes for which we originally collected it or subsequently obtained your consent. However, you should be aware that if you choose to limit how we use your Personal Information, some or all of our Services may not be available to you.


We share your Personal Information only with third parties who have a legitimate purpose for accessing it. We will only share your information in the following circumstances:  

  • Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. We have executed appropriate contracts with our service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
  • Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested.  We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear along with our name.  We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they use or maintain on our behalf and not to use it for any purpose other than the purpose for which we have provided.
  • Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, we may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). As permitted under applicable law, we may also share certain information we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Hypernet Labs related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
  • Sharing between Users. Where you direct us to do so through the Services, we will share your content, which may include Personal Information, with other users. If that content includes any Personal Information about any person other than yourself, you warrant that you have obtained all necessary consents to provide that Personal Information to other users and that you will use that Personal Information as directed.
  • Disclosures to Protect You, Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) disclose your Personal Information in good faith where it is otherwise necessary or advisable.

    In addition, from time to time, server logs may be reviewed for security purposes, e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement entities so they may identify users in connection with their investigation of the unauthorized activities.
  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, we will notify you with any choices you may have regarding your information, and we will direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected.  


When you access or use our Services, your information may be processed in the United States or any other country in which we, our affiliates or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop using the Services.


You have the right to opt out or unsubscribe from marketing communications from us as follows:

  • Email and Telephone Communications.   If you receive an unwanted email from us, you may use the “Unsubscribe” link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Hypernet Labs and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Policy).We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within at least 60 days after receipt, or such shorter time as may be required by law.
  • Mobile Devices.  We may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile or other Devices.


You may access and update the Personal Information we have about you by contacting us directly at hypernet@hypernetwork.io.  We may need to verify your identity before we grant access or otherwise modify the information we have on file for you. Such requests will be processed in compliance with the applicable law and technical limitations.

10. Data Retention

We store your Personal Information securely for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, or comply with applicable laws.  We have established internal policies for the deletion of a user’s Personal Information following termination of a user’s account.  

11. Security of Your Information

We use commercially reasonable safeguards to ensure that your information is treated securely and in accordance with this Policy.  Unfortunately, the Internet is not a 100% secure environment, and we cannot ensure or warrant the security of any information you provide to us.

By using the Services or by providing Personal Information 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 posting a notice on the Sites or Services or sending an email to you.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur.  Please recognize that you play a vital role in protecting your own Personal Information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves you and until it reaches us.  If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

12. Children’s Privacy

The Services are not directed to children under 13 years of age (16 in some jurisdictions), and we do not knowingly collect Personal Information from children under 13 years of age (16 in some jurisdictions).  In the event your child wishes to use the Services and provide us with Personal Information, we require that a parent or guardian provide consent through email to the address provided in the “How to Contact Us” section below.  If you learn that your child has provided us with Personal Information without your consent, you may alert us through email to the address provided in the “How to Contact Us” section below. If we learn that we have collected any Personal Information from children under 13 years old (16 in some jurisdictions) without parental consent, we will promptly take steps to delete such information and terminate the child’s account.


We are not responsible for the practices employed by any third-party websites or services linked to or from our Services, including the information or content contained within them. Please remember that when you use a link to go from our Services to another website or service, this Policy does not apply to those third-party websites or services, even if they are offered within or through our Services, and we encourage you to read the privacy policies of such third parties.

Our Services may include publicly accessible blogs, community forums, or private messaging features.  Our Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies and other Technologies (defined below) may be set on your Devices when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or other online venue, or that you share in an open forum, may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with such social media platforms, and by using such third-party services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

We may use third-party software development kits (“SDKs”) or APIs, as part of the functionality of our Services. Third party SDKs may allow third parties, including advertisers, to collect your Personal Information to provide content that is more relevant to you. You may opt out of such tracking by contacting us at hypernet@hypernetwork.io.

14. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

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

We generally treat information collected by cookies and other tracking Technologies as non‑personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat cookie information with identifiers as Personal Information. If we combine non-personal information with Personal Information, then the combined information will be treated as your Personal Information for as long as it remains combined.

  • COOKIES. Cookies are small text files placed in visitors’ computer 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.
    • Who Owns Cookie Data?
      We use both first-party and third-party cookies on our Services. First-party cookies are cookies that are placed on your Device by us, while third-party cookies are set by parties other than us.  Third-party cookies are operated by third parties that can recognize your Device both when it visits our Services and when it visits other websites or mobile apps. We do not control how third-party cookies are used, and we encourage you to check the websites of any third-party cookie providers for more information about how they use cookie information.
    • How to Manage Cookies
      • First-Party Cookies: You can enable, disable or delete cookies via your browser settings. To do this, follow the instructions provided by your browser, usually located within the “Help”, “Tools” or “Edit” settings of your browser. Please be aware that if you set disable cookies on your browser, you may not be able to access secure areas of the Services and parts of the Services may also not work properly (e.g., referral links, preferences, etc.).
      • Third-Party Cookies: Any cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third-party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on a Site that collects information about users’ engagement on that web page. 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.
  • Social Media Buttons and Widgets: Our Sites include social media features such as the Facebook, Twitter, Reddit, Pinterest, Google+ and LinkedIn buttons. These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the third-party company involved.
  • Analytics. We may use analytics services such as Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
  • COOKIES AND INTEREST-BASED ADVERTISING.  You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences.  Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile Devices, application users may opt out of certain mobile ads via their Device settings. See http://www.networkadvertising.org/mobile-choice.The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our third-party advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, http://youradchoices.ca/choices/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each Device and browser on which you wish to opt out.  For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile Device. You must separately opt out on each Device. Advertisements on third-party websites that contain the AdChoices link [and that link to this Policy] may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. Even if you opt out, we may still collect and use information regarding your activities on our Services and/or information from the advertisements on Third Party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

[OPTIONAL SECTION:  Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary. We may use cookies, web beacons, or other similar Technologies that are necessary to the operation of our Services. This includes Technologies that allow you access to our Services; that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or, that allow you to make use of our functions such as shopping-carts, saved searches, or similar functions;
  • Performance Related. We may use cookies, web beacons, or other similar Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content or Services;
  • Functionality Related. We may use cookies, web beacons, or other similar Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
  • Advertising or Targeting Related. We may use our cookies and web beacons or those of a third party to deliver content, including ads relevant to your interests, on our Sites or on third-party sites. This includes using Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.]

15. “Do-Not-Track” SIGNALS

“Do-Not-Track” is an optional browser setting that allows you to express your preferences about online tracking across websites.  We do not have a way to respond to Do-Not-Track signals.

16. California Privacy Rights

California law permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided in the “How to Contact Us” section.  


If you have any questions about this Policy or our Services, please contact us at: galileo@hypernetlabs.io.