Merge pull request #44 from PufferFinance/add-policies

feat: add policies and terms

docs/cookie-policy.md

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+# Cookie Policy
+
+> Last Updated: November, 2023
+
+This Cookie Policy explains how Puffer Foundation, a Cayman Islands foundation company (referred to herein as "_Puffer_", "_we_", "_our_", or "_us_") uses cookies and similar technologies in connection with our website located at [https://puffer.fi](https://puffer.fi) and any content, functionality, and services offered on or through such website ("Services"). This Cookie Policy should be read in conjunction with our [Privacy Policy](https://docs.puffer.fi/privacy-policy). If you have any questions or concerns about the Cookie Policy, please contact us at [email protected] or as otherwise described in our Privacy Policy.
+
+### What are cookies and similar technologies?
+
+- **Cookies** are text files that websites store and access on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser to allow us distinguish you from other users of our Services for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand activity and patterns, and facilitating online advertising.
+
+- **Local storage technologies**, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
+
+- **Web beacons**, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
+
+This Cookie Policy refers to all these technologies, and other types of tracking technologies used through our Services, collectively as "cookies."
+
+### What kind of cookies do we use?
+
+Our website may use cookies to distinguish you from other users of out website. This may help us to provide you with a good experience when you browse our website and may also allow us to improve our website. By continuing to browse our website, you are agreeing to our use of cookies as well as the terms of this Cookie Policy. A cookie is a small file of letters and numbers that we may store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We may use the following cookies:
+
+- **Strictly necessary cookies**. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of the Websites, use a shopping cart or make use of e-commerce payment processing services.
+
+- **Analytical/performance cookies**. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This may help us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
+
+- **Functionality cookies**. These cookies are used to recognize you when you return to our website. They may enable us to personalize our content for you, greet you by name, or remember your preferences (for example, your choice of language or region).
+
+- **Targeting cookies**. These cookies record your visit to our website, the pages you have visited and the links you have followed.
+
+Depending on your location, the maximum expiration period for the cookies above is 2 years.
+
+We may also use web beacons in promotional emails and other communications with you, to allow us to count how many people read them and to verify any clicks through to links within an email. We (or our marketing service providers on our behalf) use this to help us understand how an email campaign performed, what types of emails and content our recipients find interesting, and what actions our recipients took, so we can improve our email campaigns in the future and make our emails more relevant to our recipients. If you do not wish for the web beacon to be downloaded onto your device, you should select to receive emails from us in plain text rather than HTML.
+
+Where legally required, you will be presented with a cookie banner or other tool to provide permissions before we or our service providers set non-necessary cookies. In this case, we only set these non-necessary cookies with your consent. You may revoke your consent at any time with future effect by clicking on the cookie settings link in the bottom corner of the website at any time.
+
+### Online tracking opt out
+
+There are a number of ways to limit online tracking, which we have summarized below:
+
+- **Blocking cookies in your browser**. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit [www.allaboutcookies.org](www.allaboutcookies.org).
+
+- **Blocking advertising ID use in your mobile settings**. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
+
+- **Using privacy plug-ins or browsers**. You can block our services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
+
+- **Platform opt outs**. The following platforms offer opt out features that let you opt out of use of your information for interest-based advertising: Facebook, Google, LinkedIn, X.
+
+- **Advertising industry opt out tools**. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies: Digital Advertising Alliance for Websites: [https://optout.aboutads.info](https://optout.aboutads.info), Digital Advertising Alliance for Mobile Apps: [https://youradchoices.com/appchoices](https://youradchoices.com/appchoices), and Network Advertising Initiative: [http://optout.networkadvertising.org](http://optout.networkadvertising.org/).
+
+Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
+
+### Do Not Track
+
+Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit [http://www.allaboutdnt.com](http://www.allaboutdnt.com).

docs/privacy-policy.md

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+# Privacy Policy
+
+> Last Updated: November, 2023
+
+Puffer Foundation, a Cayman Islands foundation company (as "_Puffer_", "_we_", "_our_", or "_us_"), currently provides services including, but not limited to, the website located at [https://puffer.fi](https://puffer.fi), and any content, functionality, and services offered on or through such website ("Services"). We take the protection of your personal data very seriously. We collect and use your personal data in accordance with this privacy policy and in compliance with the Cayman Islands Data Protection Act (as amended) and, in respect of any EU data subjects, the EU General Data Protection Regulation (together, the "Data Protection Legislation"). This privacy policy ("Privacy Policy") provides you with information about the collection and use of your personal data when using our website.
+
+### Information obtained when you access our website
+
+When you access our website, we and our service providers may obtain or request information about you, your computer or mobile device, and your interaction over time with our website, as described below.
+
+- **Personal information that is automatically collected**. When you visit our website, we and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our website, our communications and other online services, such as:
+  - Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
+
+  - Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
+
+- **Personal information that you may be asked to provide**. When you visit our website, you may be asked to provide the following information to us:
+  - Contact and account information, such as your first and last name, email address, phone number, date of birth, photographic identification, government issued identification and other contact details.
+
+  - Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.
+
+  - Usage information, such as information about how you use our website and interact with it, including information associated with any content you upload to our website or otherwise submit to us, and information you provide when you use any interactive features of our website.
+
+  - Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
+
+- **Personal information that we obtain from third parties**. When you visit our website, we may obtain information from the following sources:
+  - Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.
+
+
+### How we use your personal information
+- We may collect, store and use your personal data for purposes including the following. The processing is necessary for the performance of a contract, including:
+  - administering or managing Puffer;
+  - facilitating the continuation or termination of the contractual relationship between you and Puffer; and
+  - administering and facilitating any transaction between you and Puffer.
+
+- The processing is necessary for compliance with applicable legal or regulatory obligations, including:
+  - undertaking due diligence including anti-money laundering and counter-terrorist financing checks, including verifying identity and addresses (and, where applicable, in relation to beneficial owners);
+  - sanctions screening and complying with applicable sanctions and embargo legislation;
+  - complying with requests from regulatory, governmental, tax and law enforcement authorities;
+  - surveillance and investigation activities;
+  - carrying out audit checks, and instructing our auditors;
+  - maintaining statutory registers; and preventing and detecting fraud.
+
+- In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, including:
+  - complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;
+  - assessing and processing requests you make;
+  - investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
+  - providing you with, and informing you about, products and services;
+  - managing our risk and operations;
+  - complying with audit requirements;
+  - ensuring internal compliance with our policies and procedures;
+  - protecting Puffer against fraud, breach of confidence or theft of proprietary materials;
+  - seeking professional advice, including legal advice;
+  - facilitating business asset transactions involving Puffer or related entities;
+  - monitoring communications to/from us (where permitted by law); and protecting the security and integrity of our IT systems.
+
+We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.
+
+### Sharing your personal data
+  - **Service providers**. We may share your personal information with third party companies and individuals that provide services on our behalf or help us provide the Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, and database management services).
+
+  - **Web3 partners**. We may share your personal information with our web3 partners as necessary to provide the Services.
+
+  - **Professional advisors**. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
+
+  - **For compliance, fraud prevention and safety**. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
+
+  - **Business transfers**. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
+
+### Sending your personal data internationally
+Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Data Protection Legislation. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of the Data Protection Legislation.
+
+### ‍Retention and deletion of your personal data
+We will keep your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.
+
+### Automated decision-making
+We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.
+
+### Your rights
+You have certain data protection rights, including the right to:
+  - be informed about the purposes for which your personal data are processed;
+  - access your personal data;
+  - stop direct marketing;
+  - restrict the processing of your personal data;
+  - have incomplete or inaccurate personal data corrected;
+  - ask us to stop processing your personal data;
+  - be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);
+  - complain to the Data Protection Ombudsman; and
+  - require us to delete your personal data in some limited circumstances.
+
+### Changes
+We reserve the right to change this policy from time to time by updating this Data Privacy Policy on the website.
+
+### Contact Us
+We are committed to processing your personal data lawfully and to respecting your data protection rights. Please contact us at [email protected] if you have any questions about this notice or the personal data we hold about you marking your communication "Data Protection Enquiry".