Last updated: 18 May 2022
Thank you for choosing to be part of the community (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your (“the user’’) right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
We understand that when you visit our website (“Site”) you trust us with your personal information.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE COLLECT AND STORE DATA AND TRANSMIT YOUR INFORMATION?
- HOW WE PROTECT YOUR INFORMATION?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.
The personal information that we collect depends on the context of the user's interactions with us and the Sites, the choices you make and the products and features you use. The personal information we COLLECT can include the following:
Name and Contact Data: We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor, and you should review its privacy policies and contact the payment processor directly to respond to your questions.
All personal information provided to us via the user must be true, complete and accurate, and the user is required to notify us of any changes to such personal information.
Information automatically collected
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Information collected from other Sources
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your full name, gender, date of birth, email address, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
HOW DO WE COLLECT AND STORE DATA AND TRANSMIT YOUR INFORMATION?
We usually collect and store information including in paper, physical and electronic form provided by you when you communicate with us by telephone, email, web-based form, letter, facsimile or other means, including when:
- you contact us over the phone;
- we provide you with our services via telephone, email or our Sites;
- we provide you with assistance or support for our products or services;
- you participate in our functions, events or activities or on our social media pages;
- you request that we provide you with information concerning our products or services;
- you upload or submit information to us or our Sites; or
- you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products or services.
Where practicable we will only collect information from you personally. However, we will also collect your information through our partners and third parties who supply services to us.
Please note that we use our own and third party computer servers including our Site hosts, data backups and payment gateway(s), which may be located Overseas and your information will likely be stored and transmitted Overseas as part of the normal operation of our business.
We also collect information from your computer or mobile device automatically when you browse our Sites. This information may include:
- the date and time of your visit;
- your domain;
- operating system;
- the server your computer or mobile is using to access our Sites;
- your browser and version number;
- search terms you have entered to find our Sites or access our Sites;
- pages and links you have accessed both on our Sites and on other websites;
- the last website you visited;
- the pages of our Sites that you access;
- the device you use to access our Sites; and
- your IP Address.
While we do not use some of this information to identify personally, we may record certain information about your use of our Sites such as which pages you visit and the time and date of your visit and that information could potentially be used to identify you.
It may be possible for us to identify you from information collected automatically from your visit(s) to our Sites. If you have registered an account with us, we will able to identify you through your user name and password when you log into our Sites. Further, if you access our Sites via links in an email we have sent you, we will be able to identify you.
The device you use to access our Sites may collect information about you including your location using longitude and latitude co-ordinates obtained through GPS, Wi-Fi or cell site tri-angulation.
For information about your ability to restrict the collection and use of such information, please use the settings available on your device.
We may use statistical analytics software tools and software known as cookies which transmit data to third party servers located Overseas. To our knowledge, our analytic providers do not identify individual users or associate your IP Address with any other data held by them.
HOW WE PROTECT YOUR INFORMATION?
We will endeavour to take all reasonable steps to keep secure and protect any information which we hold about you, including:
- securing our physical premises and digital storage media;
- using technologies to ensure that your information is encrypted and sent across the Internet securely;
- placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure; and
- taking regular back-ups of our electronic systems.
Notwithstanding that we will take all reasonable steps to keep your information secure, data transmission over the internet is never guaranteed to be completely secure. We do not and cannot warrant the security of any information you transmit to us or from any online services.
HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Sites for a variety of business purposes described below.
We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:
- To facilitate account creation and logon process: If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
- To send you marketing and promotional communications: We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
- To protect our Sites: We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies: for Business Purposes, Legal Reasons and/or possibly Contractual.
- To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes: We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share and disclose your information in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with:
- our related entities, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other third parties to satisfy the purposes for which the information was collected (as outlined above) or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;
- third parties who help us to verify the identity of our clients and customers, and other software service providers who assist us to provide the services we provide to you;
- third parties who help us analyse the information we collect so that we can administer, support, improve or develop our business and the services we provide to you;
- merchants and the recipients of funds to identify you as the sender of the funds and to a party whom sends you funds in connection with a transfer to you of funds;
- third parties, including those in the blockchain and fintech industry, marketing and advertising sectors, to use your information in order to let you know about goods and services which may be of interest to you;
- our professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors so that we can meet our regulatory obligations, and administer, support, improve or develop our business;
- to debt recovery agencies who assist us with the recovery of debts owed to us.
- Restructure, Merger, Acquisition. We may disclose personal information collected from you to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers. In the event of a proposed restructure or sale of our business (or part of our business) or where a company proposes to acquire or merge with us, we may disclose personal information to the buyer and their advisers without your consent subject to compliance with the law If we sell the business and the sale is structured as a share sale, you acknowledge that this transaction will not constitute the ‘transfer’ of personal information.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers are located in India. If you are accessing our Sites from outside India, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” Section above), in India and other countries.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please note that we cannot guarantee that the internet in itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. We would like to advise our users to only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site and Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please email us at firstname.lastname@example.org. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing completed before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to lodge a complaint to your local data protection supervisory authority.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:
- Noting your preferences at the time you register your account with the Sites;
- Logging into your account settings and updating your preferences;
- Contacting us using the contact information provided below.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US?
If you have any queries in relation to this policy, you wish to access or correct the information we hold about you, or make a complaint, please contact us in writing at:
303 Shirley, Street, Nassau, Bahamas
We aim to acknowledge receipt of all privacy complaints from you within 15 working days and resolve all complaints within 60 business days. Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay as well as advising the time by which we expect to resolve the complaint.
In order to disclose information to you in response to a request for access we may require you to provide us with certain information to verify your identity. Local laws may contain exceptions which may affect your right to access your information.
We may (depending on the request) charge you a fee to access the information. We will inform you of any fees payable in respect of accessing your information prior to actioning your request. All requests for information will be handled in a reasonable period of time (within 15 calendar days after the request is made).
If you wish to have your information deleted, please contact us using the details above and we will take reasonable steps to delete the information (unless we are obliged to keep it for legal or auditing purposes). To the extent that any information is stored on a blockchain it may be impracticable, unfeasible or impossible to delete.
In the event that you believe that there has been a breach of law, we invite you to contact us as soon as possible.
If you are not satisfied with our handling of a complaint or the outcome of a complaint you may make an application to: email@example.com. ; or 303 Shirley, Street, Nassau, Bahamas.