Last updated: October 7th, 2022
A note on privacy from the Recap Team
Recap champions user privacy and places this at the centre of our design philosophy and decision making. We carefully choose partners that protect user privacy wherever we can, and we share the minimum data required to ensure that our services are delivered securely for our customers.
We encrypt all sensitive user data using your unique recovery-phrase, only you have access to this phrase meaning we have no way to decrypt your data. This approach means it's impossible for us to connect a users email address or other personally identifiable information with your transaction history.
In short (unless you choose to share your recovery-phrase with us) it's impossible for us to see your transaction data or link any trading history back to you.
Recap Technologies Limited ("us", "we", or "our") operates the https://recap.io website and the Recap App (https://app.recap.io) (hereinafter collectively referred to as the "Service").
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
- Service is the website (https://recap.io) operated by Recap Technologies Limited and the Recap App (https://app.recap.io).
- Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies are small files stored on your device (computer or mobile device).
- Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User) is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Email address
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
Recap Technologies Limited uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Recap Technologies Limited may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
Recap Technologies Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure of Data
Recap Technologies Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Recap Technologies Limited
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Recap Technologies Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Recap Technologies Limited relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Fathom Analytics (https://usefathom.com)
Visit https://usefathom.com/gdpr-ccpa-pecr-compliant to learn more about their approach.
Cloud services and Hosting
Amazon Web Services
Amazon Web Services is used for operating the Recap website and supporting services. For more information about Amazon’s privacy practices, see their privacy page. https://aws.amazon.com/privacy/
Postmark is a transactional email service provided by Wildbit, LLC. Postmark handles all of Recap's transactional email. For more information about Postmark's privacy practices, see their privacy page. https://wildbit.com/privacy-policy .
We use Auth0 for authentication and user management. User emails, names and login details are stored on their EU infrastructure. For more information about Auth0's privacy practices, see their privacy page. https://auth0.com/privacy
We use Chargebee for billing management. Prior to subscription payments this stores user emails and names, and upon subscription includes payment details. For more information about Chargebee's privacy practices, see their privacy page. https://www.chargebee.com/privacy/
We use Stripe for payment processing. Upon payment Stripe will store user emails, names, and payment details. For more information about Stripe's privacy practices, see their privacy page. https://stripe.com/en-gb/privacy-center/legal
We offer users the ability to pay using PayPal. If you opt to pay with PayPal, PayPal will store user emails, names, and payment details. For more information about PayPal's privacy practices, see their privacy page. https://www.paypal.com/uk/webapps/mpp/paypal-and-your-data
We use Covalent for blockchain address indexing. User wallet addresses are used to automatically retrieve transaction activity. For more information about Covalent's privacy practices, see their privacy page. https://www.covalenthq.com/privacy-policy/
We use Alchemy for blockchain address indexing. User wallet addresses are used to automatically retrieve non fungible token metadata and images activity. For more information about Alchemy’s privacy practices, see their privacy page. https://www.alchemy.com/policies/terms
We use EtherScan for blockchain address indexing. User wallet addresses are used to automatically retrieve on-chain transaction activity. For more information about EtherScan’s privacy practices, see their privacy page. https://etherscan.io/privacyPolicy
We use Sentry, an error tracking tool from Functional Software Inc., 132 Hawthorne St, San Francisco, CA 94107, USA. To improve the accessibility and technical stability of our website by monitoring system stability and detecting code errors, we may automatically send the following information to Sentry in the event of a software failure:
- Device information (operating system)
- The IP address of the device
- Date and time of the error
- The error body
We use Intercom to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilise Intercom to collect data for analytics purposes when you visit our website or use our product.
We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.
We use Trustpilot to collect customer reviews of our products and services. In particular, we provide your email address to Trustpilot to enable them to contact you on our behalf and ask you to submit a review. We do not share any other data with Trustpilot.
We use Google Forms to better understand our customers though surveys.
We never correlate answers to email addresses without explicit consent.
As a data processor acting on our behalf, Google collects our forms results and tracks completion of the survey through cookies and local storage.
We use Office365 (provided by Microsoft) as our company email service provider. Upon direct contact with a user, Office365 will store user emails. For more information about Microsoft’s privacy practices, see their privacy page. https://www.microsoft.com/en-gb/trust-center/privacy/gdpr-overview
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
What are cookies
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access the Service, we may place a number of cookies files in your web browser.
To enable certain functions of the Service
To provide analytics
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For any other web browser, please visit your web browser's official web pages.
Where can you find more information about cookies?
You can learn more about cookies at the following third-party websites:
Network Advertising Initiative: http://www.networkadvertising.org/
This website is owned and operated by Recap Technologies Limited.
We are registered in England and Wales under registration number 11218777, and our registered office is at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
Our principal place of business is at Office 4, Mosaic, Thomas Parker House, 13-14 Silver Street, Lincoln, LN21DY.
- By email: firstname.lastname@example.org