PRIVACY NOTICE

This privacy notice (the “Privacy Notice”) explains the manner in which us and our Affiliates (the “Issuer Group”) collect, process and maintain personal data about You.

The Issuer Group is committed to processing personal data in accordance with applicable law. In its use of personal data, certain members of the Issuer Group will be characterised under applicable law as a data controller, whilst certain of the Issuer Group’s service providers, Affiliates and delegates may act as data processors under applicable law. For the purposes of this Privacy Notice, we, us or our means each member of the Issuer Group in its capacity (as relevant) as data controller of the personal data and You or Your means the Tokenholder or relevant individual affiliated or connected with the Tokenholder receiving this Privacy Notice. 

If You are a nominee Tokenholder or a corporate entity, this Privacy Notice will be relevant for those individuals connected to You and You should transmit this document to such individuals for their awareness and consideration.

Personal data: By virtue of acquiring Tokens, the Issuer Group and certain other service providers and their respective Affiliates and delegates (the “Authorised Entities”) may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. We may combine personal data that You provide to us with personal data that we collect from or about You. This may include personal data collected in an online or offline context including from credit reference agencies and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data.

Why is Your personal data processed: The storage, processing and use of personal data by the Issuer Group will take place for lawful purposes, including:

1. to comply with any applicable legal, tax or regulatory obligations on the Issuer Group or another Authorised Entity under any applicable laws and regulations; 
2. to perform a contract to which You are a party or for taking pre-contractual steps at Your request; 
3. to operate the Issuer Group, including managing and administering the Tokens and the business of the Issuer Group on an on-going basis which enables the Issuer Group and its Tokenholders to satisfy their contractual duties and obligations to each other;
   
   

   Examples of personal data include: name, title, date of birth, age, gender, nationality, picture, national identification number, usernames, email address, residential address, postal address, telephone / mobile / fax number, family structure, siblings, offspring, source of wealth, personal assets, bank account numbers and income details, tax identification number, financial and investment qualification, shareholder reference number, payment details and other details of products and services purchased, power of attorney information, job titles, employment history, employer details, personal data contained in emails, data regarding preferences in connection with marketing communications, personal data obtained pursuant to standard criminal record checks, and data obtained further to the Company's standard anti-money laundering and client due diligence checks.

4. to verify the identity of the Issuer Group to third parties for any purpose which the Issuer Group considers necessary or desirable; 
5. to assist the Issuer Group in the improvement and optimisation of advertising (including through marketing material and content) its services;
6. for risk management and risk control purposes relating to the Issuer Group;
7. to pursue the Issuer Group’s or a third party’s legitimate interests: (i) for direct marketing purposes; or (ii) to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity, and share this data with legal, compliance, risk and managerial staff to assess suspicious activities; and/or
8. where You otherwise consent to the processing of personal data for any other specific purpose.

As a data controller, we will only use Your personal data for the purposes for which we collected it as set out in this Privacy Notice. If we need to use Your personal data for an unrelated purpose, we will contact You. In certain circumstances, we may share Your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory. 

We may transfer Your personal data outside of the British Virgin Islands, as permitted under applicable law. We will not sell Your personal data.

Your rights: You may have certain rights under applicable law, including:

1. the right to be informed as to how we collect and use Your personal data; 
2. the right to access Your personal data;
3. the right to require us to stop direct marketing;
4. the right to have inaccurate or incomplete personal data corrected;
5. the right to withdraw Your consent and require us to stop processing or restrict the processing, or not begin the processing, of Your personal data; 
6. the right to be notified of a data breach (unless the breach is unlikely to be prejudicial); and
7. the right to require us to delete Your personal data in some limited circumstances. 

Please note that if You do not wish to provide us with requested personal data or subsequently withdraw Your consent, You may not be able to hold or otherwise deal with the Tokens or remain as a holder of the Tokens as it will affect our ability to provide our services to You as a Tokenholder.

Retention of Personal Data: The personal data shall not be held by the Issuer Group for longer than necessary with regard to the purposes of the data processing.

Changes to Privacy Notice: We encourage You to regularly review this and any updated Privacy Notice to ensure that You are always aware of how personal data is collected, used, stored and disclosed.

Contact Us: Please contact the Issuer Group if You have any questions about this Privacy Notice, the personal data we hold about You or to discuss Your rights under applicable law.