Privacy Policy

Your privacy is important to us.

Blockheads LLC (“Merlin,” “We,” “Us,” or “Our”) has prepared this Privacy Policy to explain what personal information We collect, how We use and share that information and your choices concerning our information practices. Through Our website (the “Site”) and mobile device (the “App”), we track your cryptocurrency portfolio’s performance, help calculate related capital gains and losses, exit plans, and send notifications (the “Service”).

Before using the Service or submitting any personal information to Merlin, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site, or otherwise use the Service. This Privacy Policy forms part of our Terms of Service.

1. PERSONAL INFORMATION COLLECTION

Personal Information You Provide:

We collect the following categories of personal information from you:

Identification Information:

We collect your email address and password, first name, last name, and phone number.

  • Cryptocurrency Information:
    We collect the wallet address for each cryptocurrency you link to our Service and the associated transaction history including the dates and amounts of each transaction. Depending on how you setup your Merlin account, we may pull the transaction history directly from a blockchain, collect it from the exchange that processed the transaction for you (if you give us read access to your account at the relevant exchange through our Vezgo or other API connectors) or get it from materials or information you upload through the Service manually.

  • Financial Information:
    Our payment processor(s) will collect and store the financial information necessary to process your payments, such as your payment card number and authentication details or PayPal information etc. Please note, however, that We store only a reference transaction record of such information and do not maintain payment card information on Our servers.

  • Communication Information:
    We may collect personal or contact information, such as email addresses, cell phone, number, country, IP addresses, etc… when you contact Us with questions, concerns, technical issues, feedback, and/or when you voluntarily respond to questionnaires, surveys, or requests for market research seeking your opinion and feedback.

  • Social Media Information:
    We maintain a social media presence on platforms including, but not limited to, Twitter, Facebook, YouTube, Twitch, Discord and LinkedIn. When you interact with Us on social media, we may receive personal information that you provide or make available to us based on your settings, such as your profile information.

Internet Activity Information:

When you visit, use, and interact with our Service, the following information may be created and automatically logged in our systems:

  • Device Information:
    The manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Service. The information we collect may vary based on your device type and settings.

  • Usage Information:
    Information about how you use the Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We may use Google Analytics or similar web analytics platforms to help collect and analyze usage information.

  • Location Information:
    We may derive a rough estimate of your location from your IP address when you visit the Site.

  • Email Open/Click Information:
    We may use pixels in our email campaigns that allow Us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

The following technologies may be used to collect Internet Activity Information:

  • Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Internet Activity Information

When you visit, use, and interact with our Service, the following information may be created and automatically logged in our systems:

Personal Information Collected from Third Parties:

  • Tax Information:
    If you share your Merlin account with third party tax advisors, and those tax advisors cannot identify you based on the Identification Information we collect when you create your account, we may collect additional information about you from your advisors, such as the last four digits of your social security number, to permit those advisors to identify your account. Please note, however, that we do not store your full social security number.

  • Third-party login information:
    When you link, connect, or log in to the Service with a third-party service, such as Google, Vezgo, or any exchange We connect to on your behalf or you direct such third parties to send Us information associated with your account on that service, as controlled by that service or as authorized by you via your privacy settings at that service.

  • Personal Information We Create:
    We use your cryptocurrency information to create reports relating to your capital gains and losses, tax liability estimates, exit plans and text, SMS or emails alerts and notifications.

  • Personal Information We Process on Behalf of Our Partners:
    We occasionally integrate with certain third-party partners (such as tax preparation software providers, API integrators, etc…) and provide our Service to their users. If we do and the third party partner owns the user relationship, we will process the users’ personal information as a data processor pursuant to our agreements with our partners rather than this Privacy Policy. If you are such a user and have questions about the processing of your information or want to exercise one of your privacy rights, please contact the partner that you interact with directly.

2.PERSONAL INFORMATION USE

Your personal information may be used for the following purposes:

Service Deliver, including to:

  • Track your cryptocurrency portfolio’s performance and help calculate related capital gains and losses,

  • Provide and secure the Service,

  • Create, maintain, and authenticate your account,

  • Give your tax advisors access to your account (with your consent),

  • Create exit plans,

  • Receive emails and SMS/text notifications and alerts,

  • Communicate with Our third-party partners (i.e., whitelist educators or influencers), and

  • Process transactions through our third-party payment processors.

These activities are necessary to perform Our contract with you.

Communicating with You: To send you updates about administrative matters such as changes to our terms or policies, payment notifications, providing user support, respond to your requests, questions, feedback and portfolio alerts and notifications. These activities are necessary for Our legitimate interests of providing user support and keeping you informed of administrative changes or portfolio updates.

We utilize SMS text message services to enable you to receive notifications and updates regarding all aspects of your merlin account. We respect your privacy and are committed to protecting it through our compliance with this privacy policy. We will send you text messages including but not limited to account notifications such as billing notifications (balance present, balance change, etc…), payment notices (payment success or failure, credit card expiration, payment options, etc…) payment reminders, customer support responses, account setup and portfolio alerts/notifications.

You can cancel the SMS service at any time. Just text "STOP" to the SMS/text message. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just resubscribe or contact us and we will start sending SMS messages to you again.

If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at 800-419-1139 or at [email protected].

Carriers are not liable for delayed or undelivered messages. As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency varies. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

Service Improvement, including to:

  • Improve the Service and create new features,

  • Personalize your experience, and

  • Create and derive insights from de-identified and aggregated information.

These activities are necessary for Our legitimate interest in analyzing how the Service is used, enhancing and personalizing users’ experience, improving the Service, and developing new features and services.

Marketing and Advertising:
we may use your personal information for marketing and advertising purposes, including:

  • Direct Marketing:
    to send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers, and events via email or through the web notification tool of Our own products and services or products/services from Our whitelisted partners. We will not sell your personal information and it will only be shared with our whitelisted partners who will also be bound to not sell your personal info under this agreement.

  • Interest-Based Advertising:
    We engage advertising partners, including third-party advertising companies and social media companies, to display ads on the Service and other online services. These companies may use cookies and similar technologies to collect information about your interaction over time across the Service, our communications, and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising.

Where necessary, we may obtain your consent for marketing.

Compliance and Protection, including to:

  • Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities,

  • Protect Our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims),

  • Audit Our compliance with legal and contractual requirements and internal policies, and

  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

These activities are necessary to comply with Our legal obligations and for Our legitimate interest in exercising or protecting rights and maintaining safety and security.

3. PERSONAL INFORMATION SHARING

We do not sell, rent, license, or lease your personal information to third parties. However, in certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:

  • Service Providers:
    To assist Us in meeting business operations needs and to perform certain services and functions, We may share personal information with service providers, including hosting services, cloud services, and other information technology services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to Our instructions, these parties will access, process, or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards We apply to your personal information.

  • Professional Advisors:
    We may share personal information with Our professional advisors such as lawyers and accountants where doing so is necessary to facilitate the services they render to us. If you share your Merlin account with one of your tax or other advisors we will share your personal information with those advisors.

  • Business Transfers:
    If We are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of Our assets, or transition of service to another provider (collectively a “Transaction”), your personal information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.

  • Legal Requirements:
    We do not volunteer your personal information to government authorities or regulators, but We may disclose your personal information where required to do so for the Compliance and Protection purposes described above.

  • White Label Partners:
    We may share personal information, such as email, logins, phone numbers, or logos, with Our partners that you registered through so they can communicate with you and share their information or products and services with you.

4. PERSONAL INFORMATION RETENTION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while We have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

To determine the appropriate retention period, We will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which We use your personal information, and whether We can achieve those purposes through other means, and the applicable legal requirements.

5. YOUR RIGHTS AND CHOICES

As a Merlin user you have the following rights:

  • Knowledge:
    You can request information about the categories of personal information that Merlin has collected about you, the business purpose for collecting your personal information, the categories of sources from which the personal information was collected, whether Merlin has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information (we provide this information in the Personal Information Collection, Use, and Sharing sections above),

  • Access and Data Portability:
    You can request a copy of the personal information that we maintain about you in a structured, commonly used, and machine-readable format, and

  • Deletion and Correction:
    You can ask us to delete or correct the personal information that we hold about you.

  • Objection:
    You may have the right to object to how we use your personal information.

  • Restrict Processing:
    You may ask us to suspend our processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.

  • Opt-Out:
    You can opt-out of marketing communications by following the opt-out or unsubscribe instructions contained in any marketing communication we or our third parties send you.

  • Withdraw Consent:
    Where We rely on your consent to process personal information about you, you have the right to later withdraw your consent in the manner indicated when you consent or by contacting Us as described in this Privacy Policy.

Please contact Us to exercise your rights. Your authorized agent may submit requests in the same way. After receiving your request, We may request additional information to verify your identity. You can also submit a complaint to the data protection regulator in your jurisdiction. We will not treat you differently for exercising your rights.

6. CHILDREN

Our Service is not directed to children who are under the age of 18. Merlin does not knowingly collect personal information from children under the age of 18. If you believe that a child under the age of 18 provided personal information to Merlin please contact Us and we will delete that information.

7. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites not operated or controlled by Merlin, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. SECURITY

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information We collect. However, no security measures are 100% failsafe, and We cannot guarantee the security of your personal information. You use the Service at your own risk.

9. CHANGES TO THE PRIVACY POLICY

Our Service and our business may change from time to time. As a result, We may change this Privacy Policy at any time without any notice. When We do We will post an updated version on this page unless another type of notice is required by applicable law. By continuing to use our Service or providing Us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it.

10. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to email us at [email protected].