Last revised date: [•] (Version 1.0)
We respect and value your privacy as well as the integrity of the information you have provided and/or permitted us to collect. Thus, we endeavour to follow industry standards to ensure the security and confidentiality of your Personal Information when you use our Services or access the Website.
2. Our Relationship with you
The Company has the relationship with individuals on its Services as described below:
"User" is an individual providing personal information to us via our Website or the Platform, Medium pages, social media accounts, or other means. For example, User can engage and complete additional social media engagement tasks, to entitle for add up to the whitelist for each IDO fundraising event or interact with us on our social media accounts.
3. Personal Information that we collect
3.1 Information provided by you when connecting with us
Prior to connecting to accessing the Website to use our Services, you must use a single sign-on (also known as “OAuth”) by logging in to our Services using Metamask or other compatible Wallets. These services will authenticate your identity and provide you the option to share certain information with us such as your username and email address.
Furthermore, you must be required to upload facial image data, namely photo images of your face and, provide additional information when firstly connecting with the Platform such as linking to your Facebook account, Telegram, LinkedIn, GitHub, Google, or Twitter of other social media accounts, and more.
3.2 Information collected by us as you use our services
3.2.1 Usage Information
When you engage or use our Services, we will monitor your information in relation to your usage of the Company Services through your device such as your IP address, phone number, the type of device you use to access our Website, device information, which websites you visited before accessing our Services or Website, browser type, Information about your browser, Date and Time you visit Our Website, Volume of data transmitted and network operator. This information will either be directly obtained by the Company or through third party service providers.
We collect this type of information to ensure that our interface and/or Website is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.
3.2.2 Communication Information
you hereby agree that we are entitled to collect and use or process the Personal Information you have provided on our Website or generated through your usage of the Company Services for the purpose of being able to communicate with you through messages, requests, emails, live chats, file attachments in connection with your transactions on the Company, or any other information related to your contact with the Company. If you contact us, we will keep a record of the information shared during the correspondence.
3.2.3 Financial Information
Parts of the Services are public, including any information disclosed on our social media accounts, thus you acknowledge that such parts of the Services may appear on search engines or other publicly available Websites, and may be “crawled”, searched and used by the third parties or other Users and Customers of the Services. Please do not post any information that you do not wish to reveal publicly.
4. How we collect Personal Information
4.1 Information automatically collected by Us
We will collect and process Personal Information automatically provided by you under the following situations:
4.1.1 when you visit and/or firstly connect with the Website;
4.1.2 when you voluntarily complete any user survey or provide feedback to us via emails or any other electronic channels including on our social media accounts;
4.1.3 when you use browser cookies or any other relevant software upon visiting the Website; or
4.1.4 other situations where we may automatically collect your information as described in
4.2 Information collected by the third-party
We will collect your Personal Information from the third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but will not be limited to, public databases, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
4.3 Anonymized and Aggregated Data
5. How we use Personal Information
Your Personal Information will be made available to need-to-know basis to the Company, our Affiliate, our Partners and/or within our group of companies. This will include but not limited to the employees and/or any persons or third parties working for the Company who are responsible for using and protecting your Personal Information.
We use and process your Personal Information for the following purposes or in the following ways:
5.1 To provide Our Services
We respect data protection principles, and process personal data only for specified, explicit, and legitimate purpose for which such personal data were provided. We primarily use your Personal Information, either collected or delivered, in order to enable your use of the Services (including, but not limited to, processing transactions), to improve the efficiency of the Services, the process to participate in the IDO fundraising project event, and to verify your identity.
5.2 To protect users
We use the information collected to protect our Websites, Users' information, and archives. We also use IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (“DDoS”) attacks, and other security risks.
5.3 To comply with regulations and compliance
For our legitimate interests, we will use the information in compliance with our legal obligations, global and local industry standards, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e., to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfil the purpose of public interest, or to pursue our reasonable interests), We may use and process your Personal Information without obtaining your consent. you hereby expressly authorise the Company to disclose any information relating to you in the Company’s possession to any law enforcement or government officials upon a valid request.
5.4 For measurement, research and development purposes
We actively measure and analyse your information to understand the way you use and interact with our Services, and our Website, and to provide you with the unique and personalized experience. For example, we allow you to use social media plugins on our Services (e.g. Telegram, Twitter, and etc.), We keep track of your preferences such as display name, time zone, and so on. This review is continuously conducted by our operation teams to continuously improve our Websites' performance and to resolve issues with User experience.
In addition, we use such information to monitor trends and improve our Services, our administration, the content and layout of the Website, and to develop new Services for you.
5.5 For communication purposes
5.6 To enforce Our T&Cs, and other relevant agreements
Personal Information is also used to enforce Our T&Cs continuously and actively among, and other agreements relating to the Services on the Website. Activities in this regard include, but are not limited to, reviewing, processing, verifying, investigating, mitigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, we shall be entitled to freeze/close/delete accounts or any User activity on the Website as necessary to any User found to be engaged in any activities that violate our T&Cs and other relevant agreements.
5.7 For marketing and advertising
We will share your Personal Information with our marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising. We may send you marketing communications to alert you about new Services, yet you can opt-out of our marketing activities at any time.
5.8 For other purposes
6. How we protect Personal Information
The Company takes reasonable care to protect the Company’s security as well as your Personal Information from loss, misuse, disclosure, alteration, and destruction. We take reasonable steps to maintain physical, technical, and employ procedural safeguard to ensure the confidentiality, integrity of your Personal Information. The safeguards include the use of firewalls, and data encryption, enforcing physical access controls to our premise and files, and limiting access to Personal Information only to those employees, agents or third parties who need access to that information to process it for us.
We also implement certain reasonable security measures to protect your Personal Information from unauthorized access, and such security measures are in compliance with the security practices and procedures as prescribed under the applicable laws.
However, you agree and acknowledge that it is impossible to fully guarantee the security of your Personal Information by implementing the above-mentioned safeguard and measures. It is not absolute protection to your Personal Information and by accessing the Services.
you agree that we will not hold any responsibility for the acts committed by those who gain unauthorized access or abuse your information and services. In addition, we will not hold any responsibility for any act committed by the third-party service providers who are contractually engaged with us to maintain an appropriate security measure for protecting your Personal Information. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such your digital wallet address. you hereby agree that we will not be liable for any information leakage and other damage or loss not caused by our intention or gross negligence, including but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.
7. How long We retain Personal Information
you are aware that your Personal Information will continue to be stored and retained by us or by a third-party processor engaged by Us for KYC Verification while you have been using or accessing the Website and the Services, and after your use of the Services for a reasonable period of time as stipulated under the applicable laws.
In addition, we may be required by applicable laws and regulatory requirements to retain certain information, including your Personal Information, your identification verification materials, information relevant to AML/KYC/CTF procedures, information related to staking instructions, account agreements, and other agreements between us and third-parties, account statements, and other records after you stop accessing or engaging with our Website or Platform.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our Website will use the following types of cookies:
8.1 Strictly Necessary Cookies
These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. We will not need to obtain your consent in order to use these cookies.
8.2 Functionality Cookies
These cookies allow the website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
8.3 Performance cookies
These cookies collect information about how you use a website, for example, which pages you go to most often, how much time you spend on a page, record difficulties you may experience while using the website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
8.4 Targeting Cookies or Advertising Cookies
These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to the sites’ functionality provided by the other organizations.
you may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Company Services may not operate properly or become inaccessible, and your online experience may be limited. For Further information please visit our Cookies Policy.
9. Sharing Your Personal Information
We will not rent, sell, or disclose your Personal Information to any third parties, except to those who require access to the information to perform their tasks and duties under the binding agreements executed with us and to share with third parties who have a legitimate purpose for accessing it.
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
10. Third-Party Collection of Personal Information
Your relationship with these third parties and their services and/or tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
11. Designated Countries Privacy Rights and your Legal Rights
This provision applies to Users of the Services that are located in the European Economic Area, United Kingdom and/or Switzerland (herein collectively referred as “"Designated Countries") at the time of Data or Personal Information being collected. We may ask your information regarding your nationality, your location, which country you are in when you use our Services or Website, or we may rely on your IP address. We cannot apply this provision to Users who do not provide information about the location or obfuscates location information so as not to appear located in the Designated Countries.
We use and process your Personal Information based on a valid lawful basis of the GDPR and any equivalent regulations (collectively referred as "Data Protection Laws"). The lawful basis for processing your Personal Information includes (i) your consent, (ii) performance of a contract, (iii) a legitimate interest, (iv) a compliance with legal obligations, (v) protection your vital interest, and (vi) public task.
Under certain circumstances when you use our Services, you have the rights under the Data Protection Laws in relation to your Personal Information. These rights include the followings:
You reserve the right to be informed about the collection, use, and process of your Personal Information.
11.2 Right of access
You reserve the right to make a request for a copy of the Personal Information we hold about you and specific information regarding Our processing of this information.
11.3 Right to rectify
You reserve the right to request Us to update, correct, or complete your Personal Information that you believe to be outdated, inaccurate or incomplete. you will rectify at any time by informing us via our contact channels.
11.4 Right to Erasure ("Right to be Forgotten")
You may request to have your Personal Information deleted from our records where (i) your Personal Information is no longer necessary to be used for the Services or on the Website, (ii) Personal Information was collected in relation to processing that you previously consented to, but later withdrew such consent, or (iii) your Personal Information was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
Please be informed that the Right to be Forgotten mentioned above is not an absolute right. We are compelled to fulfil your request only where the retention of your Personal Information might cause an infraction of the GDPR or applicable laws to which we are subject. We shall exercise reasonable efforts in having your Personal Information erased to the extent required by the GDPR or applicable laws including in communicating erasure to our recipients of your Personal Information unless that proves to be impossible or a disproportionate effort.
11.5 Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We will provide you, or the third party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented us to use.
11.6 Right to restrict processing
You may request Us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
11.7 Right to object
You may object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights. you may also object to our process of your Personal Information for direct marketing purposes.
11.8 Right to withdraw consent ("Opt-out")
You reserve the right to withdraw your consent at any time where we are relying on it to process your Personal Information. A withdrawal of your consent does not affect the lawfulness of our processing of your Personal Information prior to such withdrawal.
If you wish to exercise these rights, please inform and contact us via our Website or send a request to [•].
Please also be noted that there are some limitations when you wish to exercise any one of these individual rights. We may limit your individual rights in the following situations:
12. Cross Border Transfer of Personal Information
As a part of your use of and to ensure better and seamless delivery of the Services to you, we may store, process, analyse, transfer your Personal Information in location globally, including countries other than your home jurisdiction, and/or locations outside the Designated Countries where there may have data protections with less protection than the EU GDPR or the equivalent data protection laws.
Our Service and Website contain the transmission of your Personal Information to or to be transferred to or to be processed outside of the country where you are located or outside the Designated Countries, it is not suggestible if your Personal Information is restrictive.
However, if you wish to continue using Our Services outside the Designated Countries and your home locations, we will ensure that we will transfer your Personal Information only to country that has the required contractual provisions for transferring Personal Information in place with the third parties to which your Information is transferred, or to country where is approved by the EU authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information. In this manner, you hereby expressly consent to this transfer, and agree that we will not be responsible for any additional T&Cs, policies or any other guidelines implemented by any party receiving the information.
13.1 Our Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of country or jurisdiction where you are using Our Services or Website. If you are not over 18 or of the legal age of your country, you will not provide any Personal Information to us, or to engage in our services. We reserve the right to access and verify any Personal Information collected from you. If we are aware that you are under 18 or under the legal age who already shared your Personal Information with us, we will then discard such information and block your access to the Company’s Website immediately.
13.2 We cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information will not occur. you hereby agree that you play a vital role in protecting your Personal Information, including your credentials.
Furthermore, we may provide you with the “just-in-time” disclosures or additional information about our data collection process, purposes for processing, or other information with respect to collection of your personal information. The purpose of the just-in-time notification is to supplement or clarify our privacy practice or provide you with additional choices about how we process your personal information.
15. How to contact the Company