This Privacy Policy applies to EdenX, a Delaware based Company, (“we”, “us”, “our”), operating This Privacy Policy applies to Personal Information (“PII”) that we collect from interested parties and from our website and other online users (hereinafter “you”), as well as information that we collect automatically during your visits to our website (e.g., information collected via cookies). 

For purposes of this Privacy Policy, “PII” means any data, such as your name, telephone number, email address, IP (“Internet Protocol”) address or location data.

We act as the data controller in accordance with the Delaware Online Privacy and Protection Act (“DOPPA”), and the EU`s General Data Protection Regulation (“GDPR”).

Information we collect

We may ask you for PII when you

  • Use our website and services,
  • Participate online or otherwise in marketing activities,
  • Join the Eden waiting list marketing and promotional emails or other materials,
  • Interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties); or
  • Contact us.

Our use of PII

Eden may use your PII for the following purposes:

  • Sending notifications to you, including information about the services, about specific Eden programs in which you may wish to participate, about our solutions and services,
  • Enabling you to use our website,
  • Providing support to respond to your online inquiries,
  • Customize, analyze, and optimize our solution, services (including content to gauge usage trends and determine the effectiveness of our marketing campaigns), technologies, notifications and business relationships with you,
  • Better understanding website users, 
  • Personalizing content and implementing your preferences,
  • Prevention of fraud and other prohibited or unlawful activities,
  • Protecting the security and integrity of our website, businesses, and services; and
  • Other functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Legal basis for processing

Our legal basis for collecting and using your PII as described in this Privacy Policy depends on the PII involved and the specific context in which we collect it. Generally, your PII will be collected and processed by us on one or more of the following legal bases:

  • Your consent,
  • Compliance with contractual obligations, 
  • Compliance with legal obligations, and
  • On the basis of our legitimate interests.

If you have any questions or need more information about the legal basis for the collection of your PII, please contact us. 

Use of cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.


The hosting service used for the purpose of operating my website is Bluehost (Newfold Digital Inc). In doing so Bluehost processes all data and communication data of my customers, interested parties and visitors of our website and services that are provided through the website. We use Bluehost, on the basis of our legitimate interests in an efficient and secure provision of the website and services. 

Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your request.

Waiting list

If you join our waiting list, we process your email address to keep you informed of our launch, and upcoming products and services. In this case, we may send you newsletters and communications on a regular or occasional basis based on your consent, which you have given us when joining. 

Unsubscribing is possible at any time and can be done either by sending a message to the contact option described below or via a link provided for this purpose in the newsletter. After unsubscribing, we will delete your email address unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law. 

Our newsletter is sent as part of processing on our behalf by Mailchimp (Intuit Inc) to whom we pass on your email address for this purpose.

Data Automatically Collected by Us

We may automatically collect information about user behavior and usage regarding your visits to our websites, such as the pages you view, the links you click, and other actions you take in connection with our website. 

We may also collect certain information about the browser you use to access our website, such as your IP address, device identifier, location data, browser type and language, and your access times, the URL (“Uniform Resource Locator”) of the website from which you arrived at our website, and the URL to which you are directed after leaving our website if you clicked on a link on our website.

Data from third party sources

We may obtain data about you from third-party sources, such as public databases, our business partners, joint marketing partners, social networks, and other third parties. We may use this data to better analyze your user behavior to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

Retention of your data

We will retain your PII as necessary in connection with the purposes described in this Privacy Policy, for as long as you are actively working with us, and in accordance with Delaware`s Retention Periods and other applicable laws.

International transfers

Eden may transfer your PII to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your PII may be transferred to countries outside the USA. In order to provide adequate protection for your PII when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the PII we transfer.

Sharing of PII by us.

With your consent, we may disclose your PII for any purpose. In addition, we may disclose your PII: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Eden (or a part of Eden) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect Eden, its clients or the public. In all cases other than those described above, PII will not be disclosed by us to third parties for their own marketing purposes without your consent.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. 

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any PII or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

Your rights 

Under the DOPPA and the GDPR, you can exercise the following rights:

  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to information
  • Right to data portability
  • Right of objection
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the PII we hold about you, or if you wish to request the erasure or rectification of PII we hold about you, or to exercise any of your other rights as a data subject, please contact us. 

How we protect your PII

Eden takes all reasonable steps to protect your PII from misuse, alteration, and loss, and from unauthorized access, alteration or disclosure. To this end, we use the following means, among others:

  • Use of encryption when collecting and transmitting sensitive data such as credit card information, technical and organizational measures to ensure the continuous integrity, availability and fail-safety of processing systems and services,
  • Restricting physical access to our sites,
  • Restricting access to data we collect about you,
  • Ensuring appropriate safeguards are in place at our facilities and those of our business partners to ensure the security of your PII; and,
  • where required by law, deleting or anonymizing PII.

Collection and Use of Children’s PII

Eden takes the privacy of children very seriously. We do not knowingly collect PII from children through our website. 

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change Eden’s use of your PII, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your PII.

Queries and Complaints

If you would like to contact us regarding our privacy practices for any reason, please contact us.

Effective Date

Friday, January 20, 2023