Curvegrid Privacy Policy
This Privacy Policy applies to Curvegrid, MultiBaas, MultiBaas for Google Sheets, and NeoCB. It describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.
We use your Personal Data to provide and improve the Service. This Privacy Policy explains how we handle that data. By using the Service, you acknowledge that your Personal Data will be handled as described in this Privacy Policy. Please read it together with the Terms of Service that apply to your use of the Service.
1. Interpretation and definitions
1.1 Interpretation. The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
1.2 Definitions. For the purposes of this Privacy Policy:
“Account” means a unique account created for you to access our Service or parts of our Service.
“Applicable Data Protection Law” means the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, as amended) (the “APPI”) and, to the extent they apply, Regulation (EU) 2016/679 (the “GDPR”), the GDPR as retained in UK law (the “UK GDPR”), and any other data protection laws that apply to our handling of your Personal Data.
“Company” (referred to as “the Company”, “we”, “us” or “our” in this Privacy Policy) refers to Curvegrid Inc., a Japanese company.
“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
“Country” refers to: Japan
“Customer” means an individual or organization that has agreed to Terms of Service with the Company for the use of MultiBaas or NeoCB.
“Customer Data” means data that a Customer or its users upload to, or generate within, a MultiBaas deployment, as further described in the MultiBaas Terms of Service.
“Device” means any device that can access the Service such as a computer, a mobile phone or a digital tablet.
“NeoCB” means the wallet applications, APIs, signing-coordination services and related software that the Company provides under the NeoCB Terms of Service, accessible from https://neocb.com.
“Personal Data” is any information that relates to an identified or identifiable individual.
“Service” refers to the Website, the MultiBaas platform (including MultiBaas for Google Sheets), NeoCB, and related services provided by the Company.
“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
“Usage Data” refers to 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).
“Website” refers to the Company’s websites, accessible from https://curvegrid.com, https://multibaas.com, https://multibaas.app and https://neocb.com.
“you” or “your” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
2. Scope and Customer Data
2.1 Scope. This Privacy Policy applies to Personal Data that the Company handles for its own purposes, such as information about visitors to the Website, Account holders, NeoCB Customers and their authorized users, and contacts at Customers, prospective customers and business partners.
2.2 MultiBaas Customer Data. When a Customer uses MultiBaas, it may upload or generate Customer Data, which can include Personal Data about its own users or other individuals. The Company processes Customer Data on behalf of, and on the instructions of, the Customer, as described in the data protection provisions of the applicable Terms of Service. The Customer is responsible for providing any required notices and obtaining any required consents for that data. If your Personal Data is contained in Customer Data, please direct any requests about it to the relevant Customer. We will assist the Customer as required by the Terms of Service and Applicable Data Protection Law.
2.3 NeoCB. The Company handles the account, verification, device, organizational and transaction information described in Section 3.5 for its own purposes of providing, securing and administering NeoCB and meeting its legal obligations, and this Privacy Policy applies to that information. A Customer that provides us with Personal Data about other people, such as its authorized users, must have authority to do so and give any required notices.
2.4 Signing material. Cryptographic signing and recovery material, such as the server-side key share for NeoCB Native Wallets, is governed by the NeoCB Terms of Service rather than this Privacy Policy.
3. Types of data collected
3.1 Personal Data. 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. Personally identifiable information may include, but is not limited to:
(a) Email address
(b) First name and last name
(c) Phone number
(d) Address, State, Province, ZIP/Postal code, City
(e) Usage Data
(f) Company name
3.2 Usage Data. Usage Data is collected automatically when using the Service.
3.3 Usage Data may include information such as your Device’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.
3.4 We may also collect information that your browser sends whenever you visit our Service.
3.5 NeoCB data. If you use NeoCB, we also collect the following information:
(a) Verification information, such as information about identity, age, address, legal existence, authority, ownership or control, intended use, sanctions exposure and, where risk justifies it, source of funds or wealth. We may obtain some of this information from verification providers.
(b) Organizational information, such as your organization’s authorized users, their roles, and the approval and recovery rules you configure.
(c) Transaction information, such as wallet addresses, transaction instructions, approvals, and related records.
(d) Device information about the devices you use with NeoCB.
3.6 Tracking technologies and Cookies. We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
3.7 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 parts of our Service.
3.8 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.
3.9 We use both session and persistent Cookies for the purposes set out below:
(a) Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
(b) Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
(c) Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
3.10 You can manage or delete Cookies at any time through your browser settings. Where Applicable Data Protection Law requires your consent for Cookies that are not strictly necessary, we will ask for it before setting them.
4. Use of Personal Data
4.1 Purposes of use. The Company may use Personal Data for the following purposes:
(a) To provide and maintain our Service, including to monitor the usage of our Service.
(b) To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
(c) For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
(d) To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
(e) 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.
(f) To manage your requests: To attend and manage your requests to us.
(g) For security and legal compliance: to detect, prevent and respond to fraud, abuse, security incidents and other harmful activity, and to comply with applicable laws.
(h) To verify NeoCB Customers: to verify identity, eligibility and authority, to screen for sanctions exposure, and to decide whether to onboard, restrict or suspend a Customer as described in the NeoCB Terms of Service.
4.2 Marketing. You may opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us.
4.3 No sale or AI training. Across all of our products, we will not sell non-public customer data or use it to train general-purpose AI models without separate permission.
4.4 Sharing. We may share your personal information in the following situations:
(a) With Service Providers: We may share your personal information with Service Providers to host and operate the Service, to verify NeoCB Customers, to monitor and analyze the use of our Service, and to contact you. We require Service Providers to protect your Personal Data and supervise their handling of it as required by Applicable Data Protection Law.
(b) For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
(c) With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
(d) With third-party services you enable: when you connect an external wallet, custodian or other integration to the Service, we exchange the data and instructions needed for its disclosed functions, subject to any separately required consent.
5. Retention of Personal Data
5.1 The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
5.2 The Company 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 time periods.
5.3 When we no longer need your Personal Data, we will delete or anonymize it.
6. Transfer of Personal Data
6.1 Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information 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.
6.2 We generally process Personal Data in Japan and the United States, and may also process it in other countries where we or our Service Providers operate.
6.3 Where we provide Personal Data to a third party in a foreign country, we do so in accordance with the APPI. For example, we may confirm that the recipient maintains a system meeting the standards required under the APPI, or ask for your consent after giving you the required information about that country’s personal information protection system. You may contact us for more information about the countries involved and the safeguards we use.
6.4 The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
7. Disclosure of Personal Data
7.1 Business transactions. If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
7.2 Law enforcement. Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
7.3 Other legal requirements. The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
(a) Comply with a legal obligation
(b) Protect and defend the rights or property of the Company
(c) Prevent or investigate possible wrongdoing in connection with the Service
(d) Protect the personal safety of users of the Service or the public
(e) Protect against legal liability
8. Security of Personal Data
8.1 The security of your Personal 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.
8.2 We maintain organizational, personnel, physical and technical safeguards appropriate to the risk, including access controls, encryption of data in transit, confidentiality obligations for our personnel, and supervision of Service Providers.
8.3 If a data breach occurs that is likely to harm your rights and interests, we will notify the relevant authorities and affected individuals where required by Applicable Data Protection Law. We will also notify affected Customers of material security incidents without undue delay, subject to lawful restrictions and mandatory reporting duties.
9. Blockchain data
9.1 The Service enables interaction with public blockchain networks. Information recorded on a public blockchain, such as wallet addresses and transaction details, is publicly visible and, by design, generally cannot be altered or deleted by the Company or anyone else. Please consider this before recording any information that could identify you or others on a public blockchain.
10. Your rights
10.1 Subject to Applicable Data Protection Law, you may have the right to request access to, correction of, addition to or deletion of your Personal Data; to request that we stop using or disclosing it; and to request records of our provision of your Personal Data to third parties. If other data protection laws apply to you, you may have additional rights under those laws.
10.2 To make a request, contact us using the details in Section 15. We may need to verify your identity before responding, and we will respond within the period required by Applicable Data Protection Law.
10.3 If you are not satisfied with our response, you may contact the Personal Information Protection Commission of Japan.
11. Additional information for individuals in the EEA and UK
11.1 Applicability. This Section applies only where the GDPR or the UK GDPR applies to our processing of your Personal Data. For Personal Data covered by this Privacy Policy, the Company is the controller. For MultiBaas Customer Data, the Company acts as a processor on behalf of the Customer, as described in Section 2.2.
11.2 Legal bases. We process your Personal Data on the following legal bases: to perform a contract with you or to take steps at your request before entering into one; for our legitimate interests in operating, securing and improving the Service and communicating with business contacts, where those interests are not overridden by your rights; to comply with legal obligations; and with your consent, where we ask for it. Where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
11.3 Your rights. In addition to the rights described in Section 10, you may have the right to access, rectify or erase your Personal Data; to restrict or object to its processing, including objecting at any time to processing for direct marketing; and to receive your Personal Data in a portable format. To exercise these rights, contact us using the details in Section 15.
11.4 International transfers. The European Commission has recognized Japan as providing an adequate level of protection for personal data, and the United Kingdom has done the same. Personal Data we receive from the European Economic Area or the United Kingdom in reliance on those decisions is handled in accordance with the Supplementary Rules adopted by Japan’s Personal Information Protection Commission. Where we transfer that Personal Data onward to the United States or another country that does not have an adequacy finding, we use appropriate safeguards recognized under the GDPR or the UK GDPR, such as standard contractual clauses.
11.5 Complaints. You have the right to lodge a complaint with the data protection supervisory authority in the country where you live or work, or where you believe an infringement occurred.
12. Children’s privacy
12.1 The Service is intended for businesses and is not directed to children. MultiBaas users must be at least 13 years old, and individual NeoCB Customers must be at least 18 years old. We do not knowingly collect Personal Data from anyone under the age of 13. If you believe a child has provided us with Personal Data, please contact us and we will take steps to delete it.
13. Links to other websites
13.1 Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
13.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
14. Changes to this Privacy Policy
14.1 We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
14.2 We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the effective date at the top of this Privacy Policy.
14.3 You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
15. Contact us
15.1 If you have any questions about this Privacy Policy, or wish to exercise your rights, you can contact us by email at support@curvegrid.com.
15.2 The Company’s address and the name of its representative are available on request.