The purpose of this document is to provide information regarding the processing of personal data by Exa Labs in compliance with article 13 of the GDPR.
Exa Labs does not have a data protection officer but Users may contact the team at the following email address : [email protected].
Users could write to the team at:
Exa Labs
229 rue Saint Honoré
75001 PARIS
1. Definitions
Where drafted in upper case, the following definitions are applicable to the entire Privacy Policy.
Account | refers to a digital interface associated with a Blockchain Address in the Websites. |
Blockchain | refers to a type of technology that supports the distributed recording of encrypted data and as the case may be, the Algorand blockchain. |
Blockchain Address | refers to a unique sequence of numbers, letters and cryptographic functions stored on a Blockchain. |
Creator | refers to any natural or legal person selling NFTs on the Primary Market on EXA.Market or any natural or legal person who has created a NFT collection. |
Exa Labs | refers to Exa Labs, a French joint-stock corporation (“société par actions simplifiée”), registered under the laws of France at the trade companies register of Paris under the number 904 520 178. |
EXA.Market | refers to the website: https://exa.market and its functionalities and services. |
Primary Market | refers to the functionalities of EXA.Market providing for a market of first sale of NFs from Creators to Users. |
Secondary Market | refers to the functionalities of EXA.Market providing for a market of secondary sales of NFTs between Users. |
Services | refers to the services provided by Exa Labs on EXA.Market and defined in the T&Cs. |
T&Cs | refers to the terms and conditions applicable to the Services. |
Users, User | refers to Creators, any user of the Services and/or any data subject. |
Websites | refers to the website https://www.exa.market and all its subdomains. |
Unless stated otherwise, definitions stated in the singular shall have the same meaning in the plural form.
Any term defined in article 4 of the GDPR and mentioned in this Privacy Policy shall have the same meaning.
2. Foreword
The following Privacy Policy has been drafted by Exa Labs. Exa Labs operates EXA.Market.
EXA.Market is an advanced decentralized marketplace enabling users to buy, sell and exchange Crypto assets, NFTs and other digital assets between each other.
This Privacy Policy will describe how Exa Labs processes personal data provided by its Users in the context of the use of those services.
Exa Labs may amend this Privacy Policy from time to time, in which case they will update Users by any available means, including by way of notification on its Websites.
In drafting this Privacy Policy and making it available to its Users, Exa labs intends to fulfill its duty to inform data subjects within the meaning of articles 13/14 of the Regulation EU (2016/679) of the EU Parliament and the Council of 27 April 2016, better known as the “GDPR”.
3. Exa Labs’s role; other recipients
Exa Labs is the data controller of any User personal data.
Other recipients may include third-party service providers such as:
hosting service providers, acting as data processor (e.g AWS);
payment service providers ;
customer service solutions (e.g Hubspot, Stonly).
4. Data Exa Labs collects
Exa Labs collects the following data from its Users:
All Users | Blockchain Address Email address Name Profile name Profile Picture Bio Social media and website links Usage data (content of a wallet, buy/sale activity, time spent on the Services) Chat data Customer service data (e.g. chat, help center) |
Creators | Blockchain Address Email address Name Profile name Profile picture Content generated for the description of the NFT Collection |
5. Purposes and legal basis
Below is a table which summarizes the various processing Exa Labs does, the categories of data it collects (the what), the purposes of such collection (the why) and the legal basis (the how).
Processing | Purpose | Legal Basis |
Newsletter; marketing | Inform its Users of news related to the business | The legitimate interest of informing its Users on its activities (emailing based similar products and services) |
Operational emailing | Inform its Users of its actions while using the Services, e.g. auctions | Execution of a contract (T&Cs or Creator Agreement) |
Asset displaying through Exa wallet | Display a User’s assets in order to offer a better user experience | Execution of a contract (T&Cs) |
Creator onboarding | Onboard Creators to make at their disposal Exa Market | Execution of a contract (Creator agreement) |
Analytics | Have a better understanding of the use of the Services by its Users Provide personalized recommendations to Users | The legitimate interest of developing its activities |
Chat | Allow Users to communicate between each other in order to facilitate transactions | Execution of a contract (T&Cs) |
6. Data storage
Exa Labs may retain Users’ personal data as long as they continue to use the Services, have an Account on the Website, or for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy.
Exa Labs may continue to retain Users’ personal data even after they deactivate their Account and/or cease to use the Service if such retention is reasonably necessary to comply with its legal obligations (including statute of limitation rules), to resolve disputes, prevent fraud and abuse, enforce its T&Cs or other agreements, and/or protect its legitimate interests.
This includes, at the moment, all of the personal data they process.
7. Users’ rights
Users are informed that they have a right of access, a right to rectification and erasure, a right to restriction of processing, a right to personal data portability under the conditions provided for in articles 15 to 22 of the GDPR.
According to French privacy laws (articles 84 to 86 of Act n°78-17 of 6 January 1978), Users also have the right to specify instructions defining how Exa Labs shall manage personal data after their death under the conditions of such law.
Although Users have rights, the exercise of such rights is not unlimited; each of the rights offered by the GDPR may be subject to specific conditions. This being said, Users should be aware of the following:
their identity: to exercise their rights or for any question on privacy, Users shall make a request accompanied by a proof of their identity (by email at [email protected]);
delay to respond: Exa Labs will process the requests within a reasonable timeframe taking into account the complexity and the number of requests. Exa Labs shall strive to reply without undue delay and at the latest within one (1) month of receipt of the request. Exa Labs may extend this period to three (3) months in the case of a complex requests;
potential costs: the exercise of the rights offered by the GDPR are in practice free. However, where Users’ requests may involve important costs, they may have to bear some of them.
Finally, Users have the option to refer to the competent supervisory authority, the Commission Nationale Informatique et Libertés (“CNIL”), in order to submit a claim.
8. Cookies
A cookie is a small computer file playing the same role as a tracker, stored and read for instance at the moment where a website is visited, an email is read or a mobile app is used, whatever the device used.
In compliance with EU privacy regulations, Users are informed that “non-essential” cookies may be deposited on their device without their consent. Non-essential cookies include (i) cookies having as their essential purpose to allow or enable electronic communications and (ii) are strictly necessary for the provision of online communication service.
In practice, Exa Labs uses authentication and identification cookies in order to ensure the proper functioning of its Services.
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EXA Labs' Privacy Policy - V2.0 - June 2024