Privacy Policy

1. Introduction

This Privacy Policy reflects the obligations taken on by Security Token Network under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

This Privacy Policy shall inform you on:

a. The Website’s Privacy Practices when handling your Personal Data

b. The Website’s Sources on collecting of your Personal Data

c. The Website’s method of processing of your Personal Data

This Privacy Policy shall apply in cases where we are acting as a data Controller with respect to the Personal Data of our Users and Website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

We may use some third-party services and cookies with your explicit permission. You can find our disclosure Section in Section 11 of this Privacy Policy.

1.1. References

References in this document to: “Service”, “Website”, “Security Token Network”, “We” or “Us” mean a Data Controller in the context of Regulation (EU) 2016/679. The Website’s contact details may be found in Section 10 of this Privacy Policy, or on our website at https://token.security

References to “You”, “Your” and “User” mean the person, group or other entity utilizing Security Token Network. References to “Data Subject” mean Users, which are natural persons, to whom the GDPR regulation grants the appropriate rights as described in this Privacy Policy.

 “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

2. Collection and Usage of your Personal Data

2.1. What Data do we collect? – In order to provide you with our services, we may process certain data in connection to your personal profile (such as: your name, address, telephone number, e-mail address, gender, date of birth, profile picture), data in connection to our services (data we have collected in order to provide you with our services), publication data (we may process information that you post for publication on our Website), enquiry, correspondence and notification data (any data you provide us with in any enquiry you submit to us, for example through our Customer Support e-mail, or by your consent to opt in to subscription for newsletters or promotional e-mails), your transaction data (information in relation to transactions, without exclusion to purchases of goods and services, that include your contact details and transaction details).

2.2. How do we use your Data? – We process your data in accordance to these Terms of Service and Privacy Policy at all times. We do not store or retain data that is connected to your transactions, unless you have authorized us to do otherwise.

2.3. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process the data as described in this subsection, where such processing is necessary for compliance with a legal obligation to which we may be subjected to, or in order to protect your vital interests or the vital interests of another natural person.

2.4. We do not require from you to enter any other person’s personal data, unless prompted by us to do so. Please do not share any other person’s personal data with us without our explicit request.

3. Sharing of your Personal Data with third parties.

3.1. When appropriate and effective, we may share some of your personal Data with third parties that perform certain services to us – for example, we may share your personal identification, transaction publication, or enquiry Data with our Website’s billing, marketing and technology services, or your transaction details with our authorized payment provider (for more details, please see our third-party services list in Section 11). All of these service providers have an established agreement with us and shall process the data in accordance to the best of privacy standards available. All of the data that is relating to your enquiries or financial transactions that are sent from the web browser to our server will be protected by using encryption technology. Personal Data including your name, contact information, cardholder data and possible stored passwords will always be stored in encrypted form.

3.1.1. We may disclose your personal identification data to any member of our group of companies (such as: our subsidiaries, our ultimate holding company and all its subsidiaries), insofar as necessary and reasonable for the purposes and legal bases set out in this Privacy Policy. We may further disclose this data to our supplier(s) and subcontractor(s), insofar as reasonably necessary for the purposes of them providing you with product(s) or service(s) offered throughout our Website. Your enquiry data that you share with us may be shared with third parties, so that they may contact you in connection to any of your requests or information about the set product(s) or service(s) offered throughout our Website. For more information on any of these service providers, please see our list in Section 11 of this Privacy Policy.

3.1.2. Financial transactions relating to the product(s) and service(s) offered on our Website may be handled by our payment processors. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, dealing with complaints, queries relating to payments or possible refunds. For more details on our payment processors, please see Section 11 of this Privacy Policy.

4. Subscriptions and Opt-Outs

4.1. Subscriptions – If you chose to do so, you may subscribe to our Newsletters, in order to stay informed about the new products and/or service that the Service offers. Once subscribed, you may unsubscribe at any time, at which point all periodic newsletters shall further not be sent out to you. You should find the unsubscribe option directly on the Newsletter’s footer, or contact our Customer Support to be unsubscribed from this option.

4.2. Opt-Outs – In certain aspect of usage, Users are given the opportunity to opt-out of having their personal information used for certain purposes. All further usage of your personal information provided to you by us shall be subject to your informed consent. Your personal data is your explicit right. You may opt to deny us access or not providing us this information, manually change your privacy preferences within your User Account, or (in case such manual preferences are not available), contact the Customer Support on (Customer Support e-mail) to opt-out of certain privacy settings. For more information on your rights under the current privacy regulations, please see Section 7 of this Privacy Policy.

5. International transfers of your personal data

5.1. In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2. We have our offices and facilities and hosting facilities stationed in the United States. The European Commission has recognized the United States as adequate in respect to the data protection regulations in the United States in coherence with the Privacy Shield framework (EU-US Data Shield) as agreed between the EU and United States. Transfers of data to the United States will be protected by appropriate safeguards, namely the EU-US Data Shield, for which you may obtain some information and a copy of the provisions on the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield.

5.3. We may offer options for you to provide certain personal data that you submit for publication through our Website. You acknowledge and agree that, with submitting such data for publication, such data will be available to the World Wide Web. You acknowledge that your Personal Data that you opted to publish throughout our Website may be seen and used by any User that has an Internet connection, and that the Website cannot prevent any cases of its misuse.

6. Retaining and deleting Personal Data

6.1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

– Personal data will be retained for a period of 1 years or less, following the time of input and for a maximum period of 2 years following the time of input of such Data.

6.2. In some cases, namely when it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period of retention of personal data as determined on our behalf.

7. Your Rights

7.1. Your personal data is your right, and our obligation is to be transparent about the way we may use it for the purposes of providing our services to us. We have compiled a list of your rights that you may exercise at any time. For more information, please send us a question on our Customer Support e-mail, or inform yourself about your rights in-depth by reading the new privacy regulations. You may exercise the rights included below by sending a notice to us at any time:

7.1.1. Right to Access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information (which includes details of the purpose of processing, categories of personal data concerned and the recipients of the personal data). Where there is no legal constraint, we will supply to you a copy of your personal data. The first copy will be provided free of charge, with the additional copies being subject to a reasonable fee.

7.1.2. Right to Rectification- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.1.3. Right to Erasure – In certain cases, you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

7.1.4. Right of Processing Restriction – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.1.5. Right to Object Processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.1.6. Right to Data Portability – To the extent that the legal basis for our processing of your Data is: – consent; – necessary for the performance of a contract to which you are the party, or to take steps at your request prior to entering into contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, provided that there are no legal restrictions as foreseen by privacy regulations.

7.1.7. Right to a Complaint to a Supervisory Authority – If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.1.8. Right to Withdraw Consent – In cases in which the legal basis for our processing of your Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8. Cookies and Privacy

8.1. What are Cookies? – Cookies are small pieces of data that are stored on your static or mobile device’s website browser, or that may be stored locally on your device when you visit our Website. A cookie file contains an identifier, which is a string of letters and numbers that are sent back each time a browser requests a page from the server. Cookies are divided into session cookies (which expire at the end of the user session – i.e. at the time of closure of your device’s website browser), or persistent cookies (which expire at their designated expiry date, unless deleted prior to such date). Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

8.2. Why do we use cookies – We may use cookies in order to authenticate you, determine if you are logged into our website, maintain the state of your shopping cart as you navigate through Security Token Network, personalize your user experience when logged in our Security Token Network, to help us display relevant advertisements to you, analyze certain behaviors on our website, store your preferences in relations to the use of cookies, and finally use cookies as an element of security, in order to protect your user account from misuse.

8.3. Your cookie preferences – You can manage your cookie preferences manually, by sending us a request on our Customer Support e-mail at (customer support e-mail). Most browsers that are used by Users allow for User to refuse or accept cookie usage, or to delete the cookies from the browser memory. You can obtain up-to-date information about blocking and deleting cookies on certain browsers on the following links:

8.4.  

Please note that with blocking cookies from your Website browser, or deleting clearing your cookies from your device may limit certain services that we provide – for example: if you delete or block the usage of your authentication cookies, you may have to sign in to your User Account manually every time you visit our Website.

9. Miscellaneous

9.1. We may discontinue a part of our Website or the whole Website without prior notice. Any changes or additions we make to our Terms of Service and Privacy Policy will be notified to you via e-mail or directly on our Website.

9.2. The Website’s failure to act in a particular circumstance does not waive the ability to act in respect to the specific circumstance or circumstances similar to it. If any provision of these Terms is rendered invalid by statutory provisions, interpretation of law or its application, rendered unenforceable, it shall not affect the remainder of these terms. The remaining terms shall stay in full force and effect.

10. Credits & Contact Us

This document was created using a template from SEQ Legal (https://seqlegal.com).

You may contact us by emailing our team at: https://token.security/contact-us

11. Disclosure of Services we may Use

11.1. Statistical and Analytics data

#:Name of Service and Website:Policies on Privacy:Services Used (If Applicable) Purpose for processing:Lawful basis for processing:Type of Data
1.

Google

(Google, Inc. – U.S.)

Privacy Policy – Opt OutGoogle AnalyticsTraffic and User behavior informationLegitimate interestService Data
2.

Facebook

(Facebook, Inc.- U.S.)

Privacy PolicyFacebook AnalyticsTraffic and User behavior informationLegitimate InterestService Data

11.2. Marketing, Payment and Invoicing Services

#:Name of Service and Website:Policies on Privacy:Services Used (If Applicable) Purpose for processing:Lawful basis for processing:Type of Data
1.

Google

(Google, Inc. – U.S.)

Privacy Policy – Opt Out

Google AdSense

Google AdWords

Advertisement toolsPerformance of ContractService Data
2.

Facebook

(Facebook, Inc.- U.S.)

Privacy PolicyFacebook Ads Advertisement toolsPerformance of ContractService Data

11.3. Other Third-Party Services

Name of Service and Website:Policies on Privacy:Services Used (If Applicable) Purpose for processing:Lawful basis for processing:Type of Data

YouTube

(Google, Inc. – U.S.)

Privacy Policy

Statistical tools of your Views on Youtube

Storage of your Video Player preferences

Legitimate InterestService Data 
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