Scope and Application

This Privacy Policy explains how Ripple Labs Inc. and its subsidiaries (collectively, "Ripple", "we", "our", or "us") collects, uses, stores, shares and protects personal information we collect about you, including when you interact with us through our Websites, events, and Services.

Ripple acts as a data controller for personal information that we collect about individuals:

- who visit a website that Ripple owns and/or maintains (including ripple.com, developers.ripple.com, and xrplresources.org) (collectively “Websites”);
- with whom we otherwise interact in a business context (e.g., employees or representatives of our customers or suppliers); and
- who utilize (as end users) products and services provided by Ripple to customers under Ripple’s service agreements (“Services”).

This Privacy Policy does not apply to the XRP ledger software, which is open source, or the distributed open-source global network accessed through that software.

The Data We Collect

“Personal data” or “personal information” means any information about an individual from which that person can be identified. It does not include data where all identifying information has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

- Basic Information: including your name, title, location, employer, role, email address, telephone numbers, and other similar contact information.
- Identity Information: including tax ID, date of birth, government-issued identification, billing address, and residential address.

Commercial Information: including:
- Financial Data - bank account number, tax identification number and internally or externally prepared financial statements.
- Wallet Data - wallet address and related information.
- Transaction Data - details about the transactions made on our Services, such as name of sender, name of recipient, expected transaction amount, payment method, description of the transaction, date and time, and other information to facilitate payment.

Internet or Network Activity Information: when you visit our Websites or use our Services, we may use cookies, pixel tags, and similar tracking technologies to collect certain data including your internet protocol (IP) address, geolocation, device information (type of device, identifiers associated with your device, device characteristics, etc.), connection information (browser type, version, characteristics, operating system, etc.), language preferences, referring/exit pages, clickstream data and dates and times of visits. For more information on our use of such technologies, see the “Automated Online Tracking Technologies” section under “How We Collect Your Personal Data” below.

- Profile Information: including your Ripple username and password.
- Marketing and Communications Information: including your preferences in receiving marketing from us and your communication preferences.
- Survey and Customer Feedback Information: including information you provide in any survey or feedback forms on our Services.

Ripple does not collect sensitive personal information, as defined by applicable privacy laws.

Collection of your personal data

Our collection of personal data differs based on the nature of your relationship or interaction with us.

Automated Online Tracking Technologies

When you visit our Websites, we may obtain certain information by automated means, such as by utilizing cookies, web beacons, web server logs, and other similar technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we collect through cookies and similar technologies helps us (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our Websites; (3) measure the usability of our Websites and the effectiveness of our communications; and (4) otherwise manage and enhance our Websites, and (5) help ensure our Websites are working properly. We also permit third parties to use online tracking technologies on our Websites for analytics and advertising, to help manage and display advertisements and to tailor advertisements to your interests which may appear on our website, on other websites, or in our email communications.

We do use cookies or similar technologies without your express consent. To the extent these online tracking technologies are deemed to be a “sale” / “sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable U.S. state laws, you can opt-out of these online tracking technologies as described in the “Exercising Your Rights” section of this Privacy Policy. Ripple does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.

Do Not Track Requests

“Do Not Track” signals are options on your browser that inform website operators that you would not like to have your online activity tracked. Currently, there is no industry standard regarding any appropriate action that websites should take when they receive “Do Not Track” signals. As there is no industry standard, please note that we do not alter our Websites’ data and information collection and use practices when we receive a “Do Not Track” signal from your browser.

Publicly Available Sources and Other Sources

We may obtain information about you from public databases or where such information is publicly available (e.g., on a Ripple customer’s website, or through publicly available resources relating to employees, officers, or directors of Ripple customers and potential customers). We may also link or combine information we collect from you with information we get from others to help understand your needs and provide you with better service.