Last Updated: 30 January 2024
Thank you for choosing Starknet RPC Node VM ("the Product'') provided by Demerzel Solutions Limited (t/a Nethermind and hereinafter referred as "Licensor," "we," "us," or "our"). This Privacy Policy outlines how we collect, use, and protect information when you use the Product. Any terms not defined herein shall have the same meaning as assigned to them in the End User Licence Agreement (“EULA”) entered into between us and the end user ("Licensee," "you," or "your") of the Product.
We are a company incorporated and registered in England and Wales. Our company number is 10908862. Our registered office address is at 30 Churchill Place, London, England, E14 5EU. Our processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.
Email address: legalnotices@nethermind.io
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Information We Collect:
Google-Provided Data (includes your personal data): In accordance with the terms of the Vendor Agreement (between Google and us) and the GCM Terms of Service (between Google and you), Google may share certain reports and data with us, including but not limited to Customer Insight Reports, Charges and Usage reports and VM Customer Tracking Reports. These reports may include your personal data, and its processing by us is governed by the Marketplace Partner Information Protection Addendum (Marketplace PIPA). The data processed by us will include:
Your name, email address, phone number and company name (if applicable);
Your country, state or province and postal code, if applicable; and
Data related to how you use our Product, which includes, inter-alia:
Resources Usage: Information on the quantity of resources used by you.
SKU ID: The SKU that you were charged for.
SKU Description: Description of the SKU, indicating the nature of the charge.
Unit: The metric used to measure usage, such as hours or gibibyte hours.
Number of VMs: The total number of virtual machines you have deployed the Product on.
vCPU Cores: The number of virtual CPU cores in your deployment.
RAM Size: The size of RAM in your deployment.
Number of GPUs: The total number of GPUs in your deployment.
GPU Types: A list of GPU types in your deployment, indicating the specific GPUs used
VM Creation Date: The dates on which you created a live virtual machine.
Machine Type Counts: A list of new and total counts per machine type, indicating the usage of different machine types.
Vendor-Collected Data (i.e., Performance Data): We may collect and process "Performance Data," which includes information related to your use of the Product. This data is aggregated and excludes any personal data, as defined in the EULA. Aggregated data helps protect user privacy by ensuring that specific user identities or personally identifiable information (PII) are not exposed.
How Is Your Personal Data Collected?
Google Provided Data including your personal data is collected by us through reports provided by Google.
Performance Data may be collected through your use of the Product, as outlined in the EULA.
How We Use Your Personal Data?
We have set out below, in a table format, a description of all the ways we plan to use your data including personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Type of data | Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Your Personal Data in Google Provided Data |
| Performance of a contract with you |
| Data related to how you use our Product |
| Necessary for our legitimate interests i.e., to study how you use our Product, to develop the Product, to grow our business and to inform our marketing strategy. |
| Performance Data | Performance Data is collected for the purpose of enhancing the functionality and performance of the Product. It may be used for internal analysis, product improvement, and the creation of anonymized statistics for marketing purposes. | Necessary for our legitimate interests - Aggregated data and performance metrics enable us to make informed strategic decisions. This includes identifying trends, forecasting demand, and planning for future product updates or expansions based on customer usage patterns. |
Opting Out: You have the right to opt-out of certain data processing activities. For more information or to exercise this right, please contact us at legalnotices@nethermind.io
Data Retention: We will retain Google Provided Data, including personal data, and Performance Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your Legal Rights: Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Access to information: You have the right to request a copy of the information we hold about you.
Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or complete information that is inaccurate or incomplete.
Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.
Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
Preventing direct marketing: We do not sell your personal data. From time to time, we may send emails containing information about new features and other news about us. This is considered direct marketing. We will always inform you if we intend to use your personal data or if we intend to disclose your information to any third party for such purposes.
Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at legalnotices@nethermind.io. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.