Preface:

Blockchain at Cal Poly is a student-led organization at Cal Poly San Luis Obispo, with student members as well as faculty members and external partners (e.g. companies that support us). Because there are many ways members can participate in the club, we have decided to create a robust privacy policy to protect the club and its members as well as the university. This policy comes at a time when cryptocurrency and blockchain has little regulation, and sometimes can be deemed illegal if a non-regulated entity (like ourselves) issues digital assets and distributes them to members that are seeking some type of reward, whether that is grant money for a blockchain project, sponsorship for an event, or governance and voting power for club management.

To provide educational services to students, treasury management for investment decisions, decentralized applications for our members and external partners, consulting services, and open source software, the club needs some level of personal data about individual experience and participation. For example, if a student or external member joins the club and wants to participate in club management or governance, they will need to acquire tokens or NFTs that can act as a gateway for their voting power. When it comes time to make decisions on what projects to work on, how to delegate work, and how to work with our club partners, there needs to be proper record keeping for all decisions, transactions, project results, etc. By using public blockchains, we are potentially exposing our club and club members' activities to the world, and that means there is a challenge to ensure personal information cannot be linked with our on-chain work.

For this privacy policy, we used ChatGPT as well as Coinbase, Metamask, and Blockchain Creative Labs' privacy policies. [1]

1. What We Do

Blockchain at Cal Poly (Doing business as MustangDAO) (“Club” or “we”) wants you to be familiar with how we collect, use, and disclose information from and about you.  This Privacy Policy describes our practices in connection with information collected through our services such as websites, mobile sites, applications (“apps”), student-led events, educational material posted to the internet, the purchase, creation and/or display of non-fungible or other tokens (collectively “NFTs” or "Cryptocurrency"), and administrative actions (e.g. treasury management, social media, and email lists) that contain or reference an authorized link to this Privacy Policy.

To access certain features of the Club Services, you may be asked to create or connect a digital wallet (“Wallet”) account, including to enable you to receive, purchase, and/or display NFTs. Wallet accounts may be created utilizing a wallet provider either on our websites or on another website created by members of the Club. A Wallet enables you to log-in to participate in certain promotions (e.g. when you log-in to participate in certain events such as governance voting or project management).

This Privacy Policy applies to all users, including those who use the Club Services without being registered with or subscribing to a Club Service, as well as those who have registered with, subscribed to, or otherwise participated in a Club Service (including creating or connecting a Wallet, purchasing, creating, and/or displaying content, such as NFTs).  This Privacy Policy applies to Club’s collection and use of your personal information (i.e., information that identifies a specific person, such as full name, email address, wallet address, GitHub user profiles).

2. The Personal Information We Collect

Club and our service providers may collect or receive the following information from and about you:

Registration Information is the information you submit to register for a Club Service, such as to receive a newsletter; or to participate in an event or promotion, including to purchase, receive or create NFTs.  Registration Information may include, for example, name and email address.

Wallet Information.  If you use a Wallet to interact with a Club Service, we will receive information about your Wallet activity and transactions, for example, your wallet address, available balance, and information about whether you hold or have sold, purchased, or otherwise obtained or received NFTs and, if so, which ones.

Blockchain transaction information is the information we obtain from public blockchains for certain transactions, such as buying, claiming, transferring, selling, or otherwise obtaining or holding NFTs or moving them out of a wallet. It includes, for example, the sending and receiving of public wallet addresses, the amount of any transfer, and information related to the time of the transaction.

Information from Other Sources.  We may supplement the information we collect with information from other sources, such as available information about your online and offline activity from social media services, public blockchain sources, and information from our Club Affiliates or business partners such as California Polytechnic State University, San Luis Obispo, or other university blockchain clubs.

3. How Your Personal Information is Used

We may use the information we collect from and about you to provide the Club Services to you, including: to allow you to create, make accessible, purchase, receive, sell, or display NFTs or other content; to provide Club governance power to members.

We use the information we collect from and about you for these additional purposes:

To allow service providers to assist us in providing and managing the Club Services.  The information we collect from and about you may be made available to certain service providers, such as the university and other blockchain organizations that are looking for data on how university students are using blockchains.

To provide co-branded services and features.  We may offer co-branded services or features, such as contests, sweepstakes, or other promotions together with other companies such as MustangDAO, a Decentralized Autonomous Organization governed by members of Blockchain at Cal Poly as well as external organizations that are providing money and services to students of the Club.

To contact you.  Club may periodically send promotional materials or notifications related to the Club Services.  If you want to stop receiving promotional materials, follow the unsubscribe instructions at the bottom of each email.

4. Accessing Your Information

If you would like to access personal information we hold about you or delete your personal information you have previously provided directly to us, please email calpolyblockchain@gmail.com.  Please note that, for security reasons, we will ask you to verify your identity in order to proceed with your request. You may also request your data be deleted or not be shared.

If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law.

6. Retention of Personal Information

Updates to this Privacy Policy.  Club may modify this Privacy Policy.  Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we notify you, such as by posting the revised Privacy Policy on the Club Services.

Data Retention.  We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information may remain viewable in some circumstances where, for example, you have shared information with social media or other services. It may not always be possible to completely remove or delete all of your information due to technical constraints, financial, legal requirements, or university requirements.

7. CONTACT US

If you have questions about this Privacy Policy, please contact us at:

• Website: https://calpolyblockchain.com/

• Email: calpolyblockchain@gmail.com

• Twitter: https://twitter.com/polyblockchain

• Discord: https://discord.gg/KtNtWd2akR

8. California Consumer Privacy Act

This California Consumer Privacy Act Notice Section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”).  Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident and includes the categories listed below.  This Section 8 provides details about the categories of Personal Information of California residents that we have collected, disclosed, or “sold” during the last 12 months, as well as rights California residents have under California law.

Categories of Personal Information Collected, Disclosed, and/or Sold: The categories of Personal Information that we collected, disclosed, and/or “sold” are below, along with the categories of third parties to whom each category of Personal Information was disclosed, and/or “sold.”  Please note that we disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered a “sale” under the CCPA.  Also, depending on the California resident’s interactions with us, Club may not have collected, disclosed, or “sold” each of these categories about each individual.  Additionally, we do not knowingly “sell” Personal Information of minors under 16 years of age.

Sources of Personal Information.  We collect this Personal Information directly from California residents themselves, and we may also collect this Personal Information from Blockchain at Cal Poly; Wallet providers; blockchains; joint marketing, co-promotional, or advertising partners, including advertising technology companies and advertisers; Club Affiliates; and sources of demographic and other information.  We also may obtain Personal Information that is made available to Blockchain at Cal Poly or us by social media platforms or SSO providers (e.g., if the individual has created an account via SSO or connected a social media account to a Club Service).  Depending on the individual’s interactions with us, Club may not have collected Personal Information from each of these categories of sources.

Purposes.  We may use this Personal Information for the following purposes:

• to operate, manage, and maintain our business;

• to provide our products and services;

• to accomplish our business purposes and objectives, including:

  • developing, improving, repairing, and maintaining our products and services;

  • personalizing, advertising, and marketing our products and services;

  • conducting research, analytics, and data analysis;

  • maintaining our facilities and infrastructure;

  • quality and safety assurance measures;

  • conducting risk and security controls and monitoring;

  • detecting and preventing fraud;

  • performing identity verification;

  • performing accounting, audit, and other internal functions;

  • complying with law, legal process, and internal policies;

  • maintaining records; and

  • exercising and defending legal claims.

Depending on the California resident’s interactions with us, Club may not have used Personal Information collected about that resident for each of these purposes.

 California Rights.  If you are a California consumer, you have the following rights:

• Right to Know. You have the right to request that we disclose to you the following information:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information during the 12 months prior to your request;

• The specific pieces of Personal Information we collected about you during that time period;

• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you;

• The categories of Personal Information about you that we sold and the categories of third parties to whom we sold that Personal Information; and

• The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed that Personal Information.

9. References:

[1] https://www.coinbase.com/legal/privacy

[2] https://www.bcl.xyz/privacy-policy/

[3] https://consensys.net/privacy-policy/