GDPR - EU Regulation 2016/679 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.
Personal data - Any information relating to an identified or identifiable natural person; 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.
Consent - Freely given, specific, informed and unambiguous indication of the data subject's wishes by which data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to the data subject.
Data subject - An identified or identifiable natural person whose personal data is processed.
Processing - 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, structuring, storage, adaptation or alteration, retrieval, recording, organization, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
What Personal Data we may process
If you send us a notification through the “Contact” section of our website - We may process your first name, last name, name of the company you represent (if any), e-mail address, phone number, and information provided by you in the text section.
If you visit and/or use our website - Certain information may be collected automatically, such as the Internet protocol (IP) address of your computer, Ethereum address, name of the domain and host from which you access the Internet, the browser software and operating system of your computer, wallet type, and the Internet address of the website from which you linked directly to our website.
If you contact us via phone or we have audio or video call communication with you - We may process your voice, video and the information provided during the entire phone call.
If you contact us via our email - We may process your email address and any data that you submit while communicating.
If you are a user of any of our services/products - We may also collect data for the purpose of agreement performance, pricing, your age, full name, address, email, and other information related to your agreement history.
2. Source of Personal Data we process
Generally, the personal data we process is obtained directly from you. However, there are situations in which we may also be in possession of your personal data through other legitimate means, such as executing an agreement to which you are not a party:
If you are designated as an authorized person or business contact for our partners;
If we provide you with our services;
If you are our employee;
If you allow recruitment platforms to share your CV or resume with us;
Depending on your social network settings, we may receive information from your social network. For example, when you follow us via social media platforms, such as LinkedIn and Facebook, we can receive personal data from these social media platforms related to your profile.
3. For how long we keep your Personal Data
We keep your personal data for the period necessary for the specific purpose listed below or in so far as such is necessary for compliance with statutory obligations and for solving any disputes. We will delete your personal information as soon as it is no longer needed for the specific purpose.
We are required to retain business and commercial documentation and other tax-relevant documents in order to fulfill our commercial and tax law archiving obligations. Retention periods are determined by applicable laws.
4. Purposes of the Processing
Your personal data are processed by us for legitimate purposes, according to the legal regulations in force, as follows:
To process, confirm and fulfil your request, including confirming payment, and updating you on the status of your request/order/agreement;
For User support and general assistance;
To manage communications systems and IT systems, conducting audit reports, managing database security and all IT systems;
To draft tax and financial documents and collect payment amounts;
To issue product/service invoices, return invoices and payment orders;
To read and answer your messages and to resolve complaints received from you through the “Contact” section of our website, social media, email or via any other mean of communication;
Conducting recruitment/selection activities for filling vacancies and managing recruitment/contest files during the various stages of the procedure;
Streamlining the services made available to the clients and constantly improving the quality of the services offered, in particular through the recording of calls or web services and products by inviting you to complete our surveys;
Representation of Company in courts and before public authorities;
Performing statistical research into general trends regarding the use of this website and the behavior of the website’s visitors to improve our website;
For record keeping and to comply with statutory obligations, we collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations.
5. Legal Basis of Processing
We collect, use and store your personal data to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party, for the execution of an agreement, or on the basis of your consent.
When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may, for example, include security and safety purposes, to improve our website, or to provide better services and offers to you.
Where we process your personal data for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data were initially collected.
The specific legal basis of processing your personal data are:
Making steps at your request before concluding an agreement (Article 6 (1) (b), of the GDPR);
The fulfillment of legal obligations by us (Article 6 (1) (c) of GDPR);
The legitimate interest of us (Article 6 (1) (f) of the GDPR), such as: the organization of the entire Company activity for the purpose of carrying out the activity; Scheduling of IT applications; solving complaints and requests received from clients or other interested persons; initiating and conducting litigation by courts of law and (possibly) other public authorities;
Your consent to processing, when expressly granted, freely and unconditionally, in specific situations such as, for example, marketing processing (Article 6 (1) (a) of the GDPR).
6. Distribution of Personal Data
Generally, we do not sell or share your personal data with anyone outside Company. However, we may disclose or share data with the following categories of recipients for the following purposes:
Support services - We may use third parties for support services to our website, such as social network providers, marketing agencies and IT suppliers. All such third parties may require to protect your personal data and only process it as per our instructions.
Third-party websites - Our website may contain links to third-party websites; if you follow these links, you exit our website. While these third-party websites are selected with care, we cannot accept liability for the use of your personal data by these third parties.
Public authorities - If we are required to by law, court order or any other order of public authorities, we may share your personal data with public authorities or governmental organizations.
Sharing with affiliate companies and ownership change of Company - We may share your personal data with our affiliate company if this is necessary for the purposes listed above. If ownership of Company changes as a result of a merger, acquisition, transfer, sale of assets, reorganization or bankruptcy your personal data may be transferred to the successor entity.
Researches - For research purposes we may use third party software such as Plausible Analytics.
7. Personal Data transfers to third countries
Company may transfer your personal data to countries other than your country of residence, including but not limited to countries outside the European Economic Area. International transferring occurs in the course of providing your services. Partners or service providers have operations in countries across the world. The laws of these countries may not afford the same level of protection to your personal data.
Company ensures that proper and required protection is in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, Company may use European Commission approved Standard Contractual Clauses as safeguards.
8. Data security
Company ensures that your personal data are properly secured by appropriate technical and organizational measures, so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss. However, no security system is impenetrable and Company cannot guarantee the security of the systems. In the event that any information is compromised as a result of a breach of security, Company will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
9. Your rights
You may contact us (please see par. 11 “How to contact us” below) to exercise any of the rights you are granted under applicable data protection laws, which includes the following:
Right to access - You may ask us whether or not we process any of your personal data and, if so, receive access to that personal data in the form of a copy. When complying with an access request, we will also provide you with additional information necessary for you to exercise the essence of this right.
Right to rectification - You may have your personal data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
Right to restriction of Processing - You may obtain a restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing storing your personal data. We will inform you before the restriction is lifted.
Right to erasure - You may have your personal data erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds a place in certain cases, prescribed by law and listed under article 17 of the GDPR. Due to the way we maintain certain services, it may take some time before backup copies are erased.
Right to data portability - You may request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.
Right to object - You may object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground constitutes the legal basis for processing (par. 6 “Legal Basis of Processing” above).
Under conditions, we are entitled to deny or restrict your rights as described above. In any case, we will carefully assess whether such an exemption applies and inform you accordingly.
We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal data in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.
10. How to contact us
If you have any questions or concerns, or need to exercise your rights listed above, you can contact us via email, phone or regular mail directed to:
Address: 12 Fuller Dr West Hartford, CT, 06117 USA
If you have unresolved concerns, you also have the right to contact the data protection authorities.