INX Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Our Business name: INX Limited.
Our place of incorporation and company number: Gibraltar, 116544.
Our Registered address: 1.02 World Trade Center, Gibraltar, GX11 1AA.
Our Data Protection Officer: Adam Sutherland.
Email address: email@example.com.
Postal Address: Regus - Gibraltar WTC,
6 Bayside Road,
Gibraltar, GX11 1AA
We are currently unregulated however in respect of Data Privacy we are subject to the supervision of the Gibraltar Regulatory Authority.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
Under the GDPR, you have the following rights, which we will always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Gibraltar Regulatory Authority.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Gibraltar Regulatory Authority.
Information you give us. This is information about you that you give us by filling in forms on our website or otherwise in writing with us, or by corresponding with us by phone or e-mail. It includes information you provide when you register with us and information you provide to our third-party partners, agent, representatives or nominees, or when you subscribe to purchase tokens and when you report a problem with our site. The information you give us may include some or all of the following personal data (this may vary according to your relationship with us):
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
● Transactional information. We collect information about any transaction you may complete on our site, including the amount of funds or tokens associated with a trade, the types of trades executed any relevant information relating to such trades.
● Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and public keys;
● Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you may have viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We may work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
Information you give us and we collect about you
We may also use information:
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Automated Decision-Making and Profiling
We use the following automated systems for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will be kept to comply with our legal obligation as the INX token issuer.
Where we have a legitimate legal reason, we may also store information for longer than described above – for example, where we are under a binding legal order not to destroy information.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, a number of important measures are taken, including the following:
We may share your personal data with other companies in our group. This includes our subsidiaries.
We contracted with Tokensoft to supply the Purchasing Portal’s onboarding and offering flows, which vary based on investor type and jurisdiction (including the blacklisting of certain jurisdictions that are ineligible for investing in the offering) to you on our behalf and provide identity verification services through ONFIDO. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within Gibraltar and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Adam Sutherland):
Email address: firstname.lastname@example.org.
Postal Address: Regus - Gibraltar WTC,
6 Bayside Road,
Gibraltar, GX11 1AA
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
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