The ACES Token, Inc., Privacy Policy is meant to inform you of our management and use of your personal information collected by us and how you may update, manage, export and delete your information. When you use our autonomous programs, services or resources (“Services”), personal information generated by you, your devices, systems and service providers is transferred to us for use on your behalf as further described herein. While regulations require that we make many of the following general statements, not all, if any, will apply to you or your information. However, we understand our responsibility and shall work hard to protect your information and to put you in control of that information as much as is reasonably possible. This Privacy Policy for ACES Token, Inc., (“ACES”, "Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services, such as when you:
Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have questions or concerns related to your information, please contact us at: privacy@acestoken.com
This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.
Personal information we process. – When you visit, use, or navigate our Services, we may process non-financial personal information depending on how you interact with ACES Token, Inc., and its Services, the choices you make, and the programs and features you use.
We do not process any sensitive personal information from consumers or consumer program administrators. – We do process non-financial sensitive personal information received from commercial program administrators, whom may acknowledge these policies and utilize the services available at their direction and discretion.
SPECIAL NOTICE - When you share information such as by posting to our BLOG, that information may be viewed by all other participants and may be captured and made publicly available beyond our control and outside our Services in perpetuity and for which we are not responsible, obligated to tract down or remove nor liable for any damages you may sustain as a result. For these reasons it is suggested that when posting anything to our BLOG that you do not include your personal information or what may be defined as sensitive personal information.
We receive limited information from third parties. We receive general information, industry related information and inquiries from third parties. However, we do not receive for collection personal information related to our participants from third parties. We do not receive for collection and use personal information from public databases, marketing partners, social media platforms, or other outside sources.
How we process your information. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law if and when it applies to us or you. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason or to accomplish activities at your direction or request.
In certain situations, we share personal information with specific types of parties. We may share that part or portion of information related to you with our systems and persons associated with your requests, services and activities necessary to perform functions essential to your objectives. We do not share your information with third parties unrelated to our services.
How we keep your information safe. We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
You have rights. Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Unfortunately, these laws are moving targets subject to political changes and court rulings. However, our Privacy Policy allows you to request access to your personal information we collect from you, change that information, or delete it in some circumstances.
How to exercise your rights. The easiest way to exercise your rights is by filling out our “Data Subject Access Request Form” available at DSAR and submitting it to us through our site or you may copy it to your own device and email it to us at privacy@acestoken.com. We will review your request and respond to you accordingly.
The following table of contents will help direct you through our Privacy Policy and let you learn more about what ACES Token, Inc., does with any information we collect.
Personal information you disclose or provide to us.
We collect personal information that you voluntarily provide to us when you register or otherwise establish an administrator account, activate or use an administrator or member account and or utilize program features and functions available over our Digital Token Driven Network System (“DTDNS”) © Program by use of such as a personal computer or mobile device.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and our Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Personal Information. We do not collect, hold, manage or process sensitive personal information of consumers. We may receive sensitive information from commercial program administrators.
Payment Data. We do not collect, hold, manage or process any financial payment information. Any payment owed to us is directed by you through a PCI Compliant Services Provider for which we do not receive personal financial information of you other than a payment amount upon receipt.
We do not have a PCI Compliant Services Provider at this time but may enlist such services in the future at which time we will update our Privacy Policy with such as a vendor name and link to their privacy policy notice if application.
Social Media Login Data. We do not provide you with the option to register with us using your existing social media account. We do not collect, hold, manage or process social media account information.
Application Data. If you use our application(s), we may collect the following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and assessments.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected.
Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice located at: Cookies
The information we collect includes:
Information NOT collected from other sources:
We Do Not collect financial, bank account or credit information, data from public databases, marketing partners, social media platforms, and other outside sources. Further, we do not collect sensitive personal information from outside sources with respect to consumers or consumer program administrators.
We process your information to provide, improve, and administer our Programs, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent or at your direction through our autonomous systems, to comply with laws, to provide you with services to enable your purpose, objectives and obligations, to protect your rights, or to achieve our legitimate business interests.
We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. Categories of third parties we may share personal information with and those lined out that we do not share information with are as follows:
We also may need to share your personal information in the following situations:
We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with our Services.
The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice located at: Cookies
If you choose to register or log in to our services using a social media account, our system may obtain or receive certain information about you that we might not otherwise have or collect. Unintentional data temporarily held during a session in which you are interacting with us is automatically deleted and cleared upon your logging out and terminating that connection with us.
Our Services do not offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). If you log in using such as Facebook, we may request access to systems and internet information necessary for our ability to interact with you. If your social media platform refuses or blocks such requests it could interfere with your ability to access our site for which you may need to reopen your browser to access our site.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States and backed up by “Cloud” services that may expand to other countries. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your non-sensitive personal information (see "WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION" above), in countries where third-party Servers are located.
Binding Corporate Rules:
Our policies include a set of Binding Corporate Rules ("BCRs") established and implemented by ACES Token, Inc. Our BCRs are consistent with those recognized by international data protection disciplines as providing an adequate level of protection to the personal information we process. Our BCRs are intellectual proprietary property and not publicly disclosed for security reasons. Further, we do not collect, store or transfer sensitive personal information and any such information inadvertently transferred to us is automatically deleted, dropped or purged upon break or close of your communication with us.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework(s), we are subject to the investigatory and enforcement powers of the US Federal Trade Commission ("FTC"). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We keep your information for as long as necessary to achieve the purposes outlined in this privacy notice unless otherwise required by law.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
We do not knowingly collect data from children under 18 years of age unless they are designated members of an ACES Program under the supervision of a Program Administrator.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from unsupervised children under age 18, please contact us at privacy@acestoken.com
In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. It is our policy to enable you to review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us through our contact details provided in the section “CONTACTING US REGARDING THIS NOTICE” below.
We will consider and act upon any request in accordance with applicable data protection laws and this Privacy Policy.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "CONTACTING US REGARDING THIS NOTICE?" below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Further, if you withdraw your consent for us to process all of your information including that which we receive from your computer and mobile devices and internet service provider, our automated system will process that same information should you log in to our site after your withdrawal of consent and your information will not be removed until after you terminate your internet connection with us.
Opting out of awareness and enhancement communications: You can unsubscribe from our awareness and enhancement communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send. You will then be removed from the relevant list — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other logistics or operations purposes.
Account Information
You may review or change the information in your account or terminate your account free of charge as follows:
SPECIAL NOTICE: If you are an administrator or token writer of an ACES Program Account associated with one or more active tokens acknowledged as digital property, of which you have transferred to another person acknowledged as the holder of such a token, that you will remain obligated and liable to said holder under the terms and conditions, covenants, conditions and restrictions regarding a redemption of such a token in exchange “On Order” or “As Promised” by you for the object represented by the token regardless of your request to terminate and our action to terminate your account. We shall continue to process your information with respect to any open and active tokens as described herein and in accordance with our programs, policies and disciplines, which you may review on our website located at: www.acestoken.com.
WARNING: if you are a member of a program account and you request us to terminate your account and the processing of your information held by us, our autonomous system normally directed by you to take an action on your behalf may be blocked and prevent you from taking such action.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based awareness communications or by advertisers on our site visit click the “Unsubscribe” button on the communication you received. For further information, please see our Cookie Notice: Cookies.
If you have questions or comments about your privacy rights, you may email us at privacy@acestoken.com
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell your personal information. You can exercise that right by contacting us as directed below or by email to privacy@acestoken.com with the subject line containing “Nevada Do Not Sell Request” and providing your username and email address associated with your account with us.
While we are required to provide this notice to you and a manner to exercise your rights, we do not sell the personal information of our participants as defined and described under Nevada Revised Statutes Chapter 603A and therefore this portion of our Privacy Policy does not apply to anyone.
If you are a consumer (natural person) residing in California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits our participants who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct awareness purposes and the names and addresses of any, should they exist, third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with us, whether supervised by an administrator or not, you have the right to request removal of unwanted data that you or your administrator publicly post on our site. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on our site, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
The California Consumer Privacy Act of 2018 (“CCPA”) gives you more control over the personal information that we collect about you and the CCPA regulations provide guidance on how to implement the law. This law secures new privacy rights for you as a consumer residing in California, including:
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
With the exception of real names and addresses, which are generally only received from account administrators or commercial participants, we have collected the following categories of personal information from consumers in the past twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. | YES |
| B. Personal information categories listed in the California Customer Records statute | Name and contact information education, employment, employment history, and financial information | YES NO |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with ours and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location – for date and time zone | YES |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories where you interact with us in person, online, or by phone or mail in the context of:
More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: Cookies
We do not sell your personal information and therefore do not have such a link on our website. However, you may wish to opt out from the selling of your personal information by disabling cookies in your Cookie Preference Settings.
You may contact us by email at privacy@acestoken.com or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION".
ACES has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
Your rights with respect to your personal data.
Right to request deletion of your data.
You may request the deletion of your personal information. If you request us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as, but not limited to, the exercise by another consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed.
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for Exercising your Consumer Privacy Rights
We will not discriminate against you if you exercise your privacy rights. However, if in exercising your rights you block or otherwise interfere with our autonomous Systems’ ability to interact with you then you may need to create a new account using different personal identifiers to continue use of our Services.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by email at privacy@acestoken.com or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Financial Incentives
"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information.
ACES’ does not have a financial incentive program as described above, and
ACES’ does not provide a financial incentive to consumers as compensation as described above.
Metrics
Our metrics for all CCPA requests received for the previous calendar year can be found here:
ACES had no CCPA requests for the previous year.
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
We do not employ a Data Protection Officer (“DPO”) given the limited amount of personal information collected from participants and the limited use of that data, which is primarily autonomously directed by you in processing activities and objectives requested by you.
If you have questions or comments about this notice, you may contact us through our Data Integrity contact as follows:
ACES Token, Inc.
Data Integrity
privacy@acestoken.com
Please include your phone number, email address and account identification along with your questions or comments.
You may request access to personal information we collect from you, change that information, or delete it in some circumstances.
The easiest way to review your personal information is to fill out our “Data Subject Access Request Form” available at DSAR and submit it to us through our site link or you may copy it to your own device and email it to us at privacy@acestoken.com. We will review your request and respond to you accordingly.
CAUTION should be observed by you when requesting that we terminate your account or to delete all of your personal information, which may interfere with your ability to self-direct our autonomous Services in authentication, validation and verification processes necessary to perform functions later requested by you.