Privacy Policy

Introduction

Last Updated: 2nd October 2018

 

Please read this privacy policy (“Privacy Policy”) so that you understand your rights in relation to your personal data, including how your personal data will be collected, used and processed.

 

Tokenise International Limited is a private company limited by shares incorporated in Gibraltar (hereinafter “Tokenise”, “Company,” “we”, or “us”).

 

In providing you with our website www.tokenise.io (our “Website”) to enable you to purchase TISE Tokens (the “TISE Tokens”) or when you otherwise interact with us, we naturally collect information about you.

 

This Privacy Policy sets out what personal data we collect, how we use it, who we might share it with, and your rights with respect to that personal data when you interact with our Website and when you interact with us in relation to the purchase of TISE Tokens.

 

References in this notice to your “personal data” describe information that can be associated with a specific person and can be used to identify that person (including information about your activities, such as information about your use of the Website, including where such information is automatically collected).

 

Please read the following information carefully to understand our practices regarding your personal data. 

 

 

Collection, Processing and Use of Your Information

 

How we collect your personal data

 

The personal data we collect may come from different sources as described below.  Some of it will be provided directly by you and others will be collected from your activity on our Website or when you go through the authorisation process and purchase TISE Tokens.

 

We use different methods to collect your data including:

  • create an account on our Website;
  • enter into the Token Purchase Agreement;
  • apply to purchase the TISE Tokens;
  • fill out any form; and/or
  • request customer support or communicate with us in any manner.

 

Technical information we collect when you access our Website

When you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information is:

  • your IP address;
  • browser type and version;
  • time zone settings and location;
  • browser plug-in types and versions;
  • operating system and platform; and
  • other technology on the devices you use to access our website.

We use this information on the basis of our legitimate interest to provide you with and improve the Website, monitor and analyse trends, usage and activity in connection with our Website

 

Information we collect from you

We may collect the following information as necessary for you to create an account with us, request authorisation to purchase TISE Tokens and purchase TISE Tokenise, or send you marketing communications:

  • Identity Data: includes information about your identity such as your name, address, date of birth, username or similar identifier, title and gender.
  • Identity Verification Data: includes images of your government issued ID, passport, national identity card, utility bill or driving licence.
  • Contact Data: includes where you live and how to contact you including; address, email address and telephone numbers.
  • Profile Data: includes your username and password, your investor status, purchases made by you and any preferences you may have.
  • Financial Data: includes information about your financial position, status and history and payment account details (can include bank, credit, payment or other payment details).
  • Transaction Data: includes details about payments to and from your accounts with us.
  • Blockchain Data: includes blockchain address and public keys.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and Tokenise affiliated entities.

We collect this information where necessary to comply with law (including where necessary to comply with laws relating to anti-money laundering (AML) or ‘know your customer’ (KYC) regulations), provide you the TISE Tokens or otherwise take steps to enter into or perform the Token Purchase Agreement or on the basis of our legitimate interest to be responsive to you and provide you with a functioning Website and the TISE Tokens and provide you with marketing communications so that we can :

  • verify your identify;
  • facilitate and record the purchase of TISE Tokens in accordance with the Token Purchase Agreement in order to perform our contract with you;
  • prevent potentially prohibited or illegal activities, and enforce the Token Purchase Agreement;
  • verify your status and/or confirm information you provided to us in order to authorize you for purchase of the TISE Tokens;
  • distribute and account for TISE Tokens;
  • compare information for accuracy and verify it with third parties;
  • communicate with you about the TISE Tokens; and
  • communicate with you about and our products and services, including the Platform, promotions, events and other news and information we think will be of interest to you (in some circumstances this may be based on your consent).

 

If you do not provide the data necessary for us to comply with legal requirements or in order to provide you the TISE Tokens or otherwise take steps to enter into or perform the Token Purchase Agreement, you may not be able to purchase the TISE Tokens.

 

We do not intentionally collect any sensitive personal information, such as information about your religion, race, ethnicity and/or political views.

 

Information collected from other sources

We also collect data from third parties who during the token application process undertake the KYC and AML checks for us located in the UK.

 

We obtain this information in order to verify the personal data you have provided to us and confirm your identity to comply with relevant AML and KYC regulations.

Location data

We do this so that we can verify your location to ensure compliance with applicable laws including AML and KYC.  This may include the blocking from certain countries where the usage of our Website and/or buying of TISE Tokens is prohibited by that country.

 

Cookies

When you access the Website, we may place small data files called cookies on your computer or other device, with your consent where required by law (unless they are essential to providing the Website). We use these technologies to recognise you as having visited the Website previously, customise, measure and improve the content and layout of our Website, detect fraud and to monitor usage of our Website.

We use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.,) (“cookies”) to enhance your experience using the Website.  Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

In addition to cookies that are strictly necessary to operate the Website, we use the following cookies with your consent when required by law:

  • Functional Cookies. We use these cookies to enhance your experience on our website, for example, to remember what language you speak.
  • Analytical/performance Cookies which are set by us and Google Analytics.  We use these cookies to collect information about your browsing activities over time and across different websites following your use of our Website. They allow us to recognize and count the number of users and to see how users move around the Website when they are using it. This helps us to improve the way the Website works. We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website.  Like many services, Google Analytics uses cookies to track user interactions as in our case, where they are used to collect information about how users use our Website. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors.

 

 

Where we have obtained your consent to cookies, you may withdraw it at any time once you have entered the Website by changing your cookie settings through the link at the bottom of each page of the Website.

 

How we might share your personal data

1.Why we share your personal data:

  • In order to operate the Website and facilitate the purchase of TISE Tokens.
  • If we have a public or legal duty to do so (e.g. to assist with detecting fraud, tax evasion, financial crime prevention, regulatory reporting, litigation or defending legal rights).
  • If we have asked for your permission to share your information for a specified purpose and you have agreed.
  • When we believe that the disclosure of personal information is necessary to report suspected illegal activity or to investigate violations of the Token Purchase Agreement.

 

  • We may also share anonymous and aggregated information, which cannot reasonably be used to identify you.

 

2.Who we share your personal data with:

  • With other Tokenise affiliated entities, in order to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications.
  • With service providers who during the token application process undertake the KYC and AML checks for us located in the UK.

 

  • With law enforcement, government officials or other state bodies in response to a request for information, if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process.

 

  • With companies that we plan to merge with or substantially all or part of our assets are to be acquired by, or where we are financing all or a portion of our business by another company.

 

Links to Third Party Websites

 

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised).

 

If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies. We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

 

Where we store and transfer your personal data

In the case of users located within the European Economic Area (“EEA”), the information that we collect from you may be transferred to and stored in various jurisdictions outside of your country of residence and outside the EEA.

 

All information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the General Data Protection Regulations with respect to the processing of your personal data. The General Data Protection Regulations is the legal instrument that deals with the protection of your data (‘GDPR’).

 

Where your data is transferred to such countries it will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC), which can be found on the EC’s website:

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contractstransfer-personal-data-third-countries_en

 

Where we transfer data to organisations based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see EC’s website page:

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacyshield_en#eu-us-privacy-shield

 

 

Retention of Personal Data

 

We retain your personal data in order to establish, exercise or defend legal claims, or as otherwise required by law, in which event we will retain your data for as long as necessary for that purpose, as needed to provide services to our users of our Website and purchasers of TISE Tokens. We will otherwise not retain any personal data.

 

We are required to keep certain data for minimum periods, namely:

  • we must retain Transaction Data for a minimum of six years after the date of the transaction;
  • we must retain certain Account Information, for a minimum of six years after your agreement with us has ended.

 

The majority of personal data we hold will be deleted 6 years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes.

 

Marketing

 

We do not sell, rent or lease your personal data and/or customer lists to third parties without your consent.

 

Security – How we Keep Your Personal Data Safe

 

We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to Tokenise from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure.

 

Children – Notice to Parents

 

Our Website is not designed or targeted toward users who might be under the age of 18 years old.

 

To parents or guardians: We need help to guard your children’s privacy. We encourage you to talk to your children about safe and responsible use of their and your personal information while using Internet.

 

Our web-resources and web-resources of our affiliates, licensees, agents etc. in the part they use under our license or assignment does not publish any data that is targeted to children.   We advise you to refrain your children from using web-resources, mentioned in this paragraph and ask them not to use them.

 

Your Rights

 

In certain circumstances you have rights in relation to the personal data we hold about you. We set out below an outline of those rights and how to exercise them. Please note that we will require you to verify your identity before responding to any requests to exercise your rights.

 

To exercise any of your rights, please email [email protected]  Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

 

  • Access: You have the right to receive a copy of the personal data we hold about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

 

  • Portability: You have the right to receive a subset of the personal data you provide us if we process it on the bases of our contract with you or with your consent and a right to request that we transfer such personal data to another party. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party.

 

  • Correction: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

  • Erasure: This enables you to ask us to delete or remove personal data in certain circumstances. You have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

 

  • Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in the following circumstances:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful, but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it

 

  • Objection: You have the right to object to our processing of data about you on the basis of legitimate interest, including profiling and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we can retain it in accordance with law, e.g. we need to process it in relation to legal claims.

 

  • Objection to Marketing: At any time, you have the right to object to our processing of data about you in order to send you promotions and marketing and we will stop processing the data for that purpose.

 

  • Withdrawal of Consent: Where you have provided your consent to us for any processing, you can withdraw consent at any time.

 

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Please contact us:

By phone: 0207 558 8800

By email: [email protected]

Or write to: 7th Floor, Hyde House, London NW9 6LH

 

Changes to This Notice

 

We may amend this policy at any time by posting a revised version on our Website.  The revised version will be effective at the time we post it. In addition, if the revised version includes any substantial changes to the manner in which your personal information will be processed, we will provide you with prior notice by posting notification of the change on the “Privacy Policy” area of our website.

 

We encourage you to periodically check this page for the latest information on our Privacy Policy.

 

Contact us

 

The responsibility for your personal data is with Kession Capital Limited of which Tokenise is a trading name, Kession is your data controller.

 

If you have questions concerning this Privacy Policy, or you notice any bugs, errors or violations please feel free to send us an email at [email protected].

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