Any Data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
Our Website contains information that enables a quick electronic contact. If a Data subject contacts us via the contact form of our Website, the Personal data transmitted by the Data subject, e.g. name and email address, are automatically stored and processed in his capacity of a Controller of Personal data.
Such Personal data is transmitted on a voluntary basis by a Data subject to the Controller. It is stored for the purpose of processing or contacting the Data subject. There is no transfer of this Personal data to third parties.
The Personal data necessary for the registration of the Data subject to the ICO of a specific client may vary, but it mainly consists of:
Phase 1 – Registration:
Phase 2 – Verification/KYC:
Date of birth;
Source of wealth;
ID front and back;
Proof of address – utility bill or bank statement;
Hereinabove Personal data, for both Phase 1 and Phase 2, is transmitted on a voluntary basis by a Data subject via the relevant ICO.
The registration of the Data subject (Phase 1), with the voluntary indication of Personal data, is intended to enable the Controller to offer the Data subject contents or services that may only be offered to registered users due to the nature of the matter in question.
After the Registration is completed a confirmation e-mail is sent to the Data subject in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address is authorized to make a registration.
The verification of the Data subject (Phase 2), with the voluntary indication of Personal data, is intended to meet the Anti-Money Laundering (AML) requirements for prevention the use of the ICO projects and token sales for money laundering and terrorist financing. All such data is used for the purpose of verification only.
Although, neither the Controller, not the Processor are required to perform AML measures, it is possible that in the future AML obliged entities might be broadened to include companies performing ICO and token sale, thus the good practices require the verification of buyer’s identity and residency and Controllers/our clients have decided to perform Know Your Client (“KYC”) procedures. Regarding this, each Controller, at its own discretion, may decide to use an independent KYC Provider, which will be involved in the process and will be handling with the KYC forms and the token buyer’s data. KYC providers are appointed only by the Controller at its own discretion, and the latter can only be held liable for the organizational and technical measures those KYC providers apply regarding the protection of Data Subjects’ Personal data. We has no contractual relations with any of its clients’ KYC providers and cannot be held liable for any of their actions.
On the ICO of our clients Data subjects are given the opportunity to subscribe to a newsletter by ticking the relevant box. Data subjects may at any time revoke a given consent and for this purpose a corresponding link is found in each newsletter or email including a newsletter.
Personal data is stored up until the termination of user’s account. After that, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or there is no other legal ground on processing the data.
We will not disclose any Personal data to a third party. Our clients though, i.e. the Controllers may disclose the Personal data of the Data subjects to other processors, for example KYC providers, Еmail providers, SMS providers.
1. Right of confirmation
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor confirmation as to whether or not Personal data concerning him or her are being processed.
If a Data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the Controller/Processor.
2. Right of access
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor free information about his or her Personal data stored at any time and a copy of this information. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data subject, this information shall be provided in a commonly used electronic form. Furthermore, the European regulations grant the Data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the Controller/Processor rectification or erasure of Personal data, or restriction of processing of Personal data concerning the Data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the Personal data are not collected from the Data subject, any available information as to their source;
- the existence of automated decision-making, including profiling.
Furthermore, the Data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the Data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a Data subject wishes to avail himself of this right of access, he or she may, at any time, contact the Controller/Processor.
3. Right to rectification
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor without undue delay the rectification of inaccurate Personal data concerning him or her. Taking into account the purposes of the processing, the Data subject shall have the right to have incomplete Personal data completed, including by means of providing a supplementary statement.
If a Data subject wishes to exercise this right to rectification, he or she may, at any time, contact the Controller/Processor or directly make the necessary changes from the functionalities of the site.
4. Right to erasure (Right to be forgotten)
Each Data subject shall have the right granted by the European legislator to terminate his or her account and obtain from the Controller/Processor the erasure of Personal data concerning him or her without undue delay and, and the Controller/Processor shall have the obligation to terminate the account and erase the Personal data without undue delay, as long as the there is no other legal ground for the processing.
If a Data subject wishes to terminate his or her account and erase his or her Personal data stored by us, he or she may, at any time, contact the Controller/Processor or directly erase his/her account.
5. Right of restriction of processing
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor restriction of processing where one of the following applies:
- accuracy of the Personal data is contested by the Data subject, for a period enabling the Controller/Processor to verify the accuracy of the Personal data;
- processing is unlawful and the Data subject opposes the erasure of the Personal data and requests instead the restriction of their use instead;
- Controller/Processor no longer needs the Personal data for the purposes of the processing, but they are required by the Data subject for the establishment, exercise or defence of legal claims;
- Data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller/Processor override those of the Data subject.
If one of the aforementioned conditions is met, and a Data subject wishes to request the restriction of the processing of Personal data, he or she may at any time contact the Controller/Processor.
The Controller/Processor, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the Personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller/Processor shall inform the Data subject about those recipients if the Data subject requests it. We will arrange all the necessary measures in any individual cases.
6.Right to data portability
Each Data subject shall have the right granted by the European legislator, to receive the Personal data concerning him or her, which was provided to a Controller/Processor, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the Controller/Processor to which the Personal data have been provided, as long as the processing is based on consent, or on a contract, and the processing is carried out by automated means.
Furthermore, in exercising his or her right to data portability, the Data subject shall have the right to have Personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the Data subject may at any time contact the Controller/Processor.
7. Right to object
Each Data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of Personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Controller/Processor shall no longer process the Personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data subject, or for the establishment, exercise or defence of legal claims.
If the Controller/Processor processes personal data for direct marketing purposes, the Data subject shall have the right to object at any time to processing of Personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the Data subject objects to the processing for direct marketing purposes, we will no longer process the Personal data for these purposes.
In addition, the Data subject has the right, on grounds relating to his or her particular situation, to object to processing of Personal data concerning him or her by the Controller/Processor for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the Data subject may contact the Controller/Processor. In addition, the Data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
8. Automated individual decision-making, including profiling
We do not perform automated decision-making and profiling.
9. Right to withdraw data protection consent
Each Data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her Personal data at any time.
If the Data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the Controller/Processor.
10. Right to a complaint
Each Data subject shall have the right granted by the European legislator to lodge a complaint with the competent supervisory authority and before the competent courts of the Member States of his or her habitual residence, place of work or place of the alleged infringement if the Data subject considers that the processing of personal data relating to him or her is in breach of the provisions of the GDPR.
11. Right to information on action taken
Each Data subject shall have the right granted by the European legislator to be provided by the Controller/Processor with information on action taken on a request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller/Processor shall inform the Data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the Data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data subject.
12. Right to information in case of data breach
Each Data subject shall have the right granted by the European legislator to be informed without undue delay by the Controller/Processor about a personal data breach which is likely to result in a high risk to the rights and freedoms of natural persons.
We have implemented all kinds of technical and organisational measures to ensure that processing is carried out in accordance with the GDPR, including:
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to Personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
If you believe that any information about you is false or inaccurate, please inform us as soon as possible on: email@example.com
Last updated: 11.04.2019