Privacy policy

Last updated: 4 June 2018

 

TokenDesk (TOKENDESK LTD, company number: 10984399, address: 3rd Floor 207 Regent Street, London, England, W1B 3HH) is a controller of the personal data you provide to us.

TokenDesk (“TokenDesk”, “us”, “we”, or “our”) operates the https://www.tokendesk.io/ website (“Website”).

Here we describe how we collect, use and handle your information when you use our Website and services (see provided services in our Terms of use) (“Services”). By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

What information we collect?

We collect and use the following information to provide, improve and protect our Services.

  1. Personal Data

When you use our Services we collect certain personally identifiable information about you (“Personal Data”). In order to use our Services, you need to create an Account:

  • You can register on Website by providing your full name and e-mail address.
  • You can sign in by using your social network account (such as your Facebook or Google account). Through this option, you may choose to have personal information and other content about you available from such social networks.

When you connect to the social network account through the Website, we only collect such information which you allowed the social network(s) to share with third parties (such as your name, email address, list of friends, profile picture, other information available via the applicable social network). You understand and agree that the Website may access, make available and store (if applicable and as permitted by the third party social network) such information so that it is available on and through your Account, until your account is deleted.

By setting your Account to integrate with social networks, including by signing onto TokenDesk by using your social network account, you agree to share information (including Personal Data) between TokenDesk and such social networks, for the purposes provided under this Privacy Policy.

The social network’s use of information made available by TokenDesk is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or TokenDesk.

When your Account is created, you can provide (clarify) such information: full name, e-mail address, phone number, address (including zip code).

When you publish your ICO, we also collect information about your team members (photo, full name, position, and links to personal profiles of the member such as Linkedin and Twitter.

In order to pass Know Your Customer (KYI) requirements, we need to check your identity. In this case we collect such information as your photo (uploaded or captured directly from the device) and your ID or passport photo. KYI procedure is managed by Finpass (please visit https://www.finpass.eu/en for more information).

  1. Usage Data

We may also collect information that your browser sends whenever you visit our Website or when you access the Website by or through a mobile device (“Usage Data”).

This Usage Data may include information such as IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

  1. Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. See our Cookie Policy for more information.

Why such information is collected?

We use Data for various purposes stated in this Privacy Policy, i.e.:

  • To provide and maintain the Services.
  • To notify you about changes to our Services.
  • To allow you to participate in interactive features of our Services when you choose to do so.
  • To provide customer care and support.
  • To provide analysis or valuable information so that we can improve the Services.
  • To monitor the usage of the Services.
  • To detect, prevent and address technical issues.

We collect your e-mail address in order to:

  • Send information, respond to inquiries, and/or other requests or questions;
  • We may also send you additional information related to the Service.

Transfer of Data

We will not sell, rent or lease your Personal Data to third parties. We also will not share your Personal Data with others, without your permission, except for the following purposes:

  1. Others working for us

To collect, store, hold and manage your Personal Data through cloud based or hosting services or a third party or a party affiliated or connected to TokenDesk, as reasonable for business purposes.

We also use certain trusted third parties (for example, providers of customer support and IT services) to help us provide, improve, protect, and promote our Services. These third parties may access information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions.

  1. Law & Order

We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of us or our users; or (d) protect our property rights.

 

We store your information, including Personal Data, on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TokenDesk will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

European requirements

If the European Union (EU) data protection law applies to the processing of your information, please note that you have the right to request from us access to and rectification or erasure of Personal Data or restriction of processing concerning you or to object to processing as well as the right to data portability.

If you are not satisfied with our response or believe we are processing your data not in accordance with the law you have the right to lodge a complaint with a data protection authority.

We process your information for the purposes described in this Privacy Policy, based on the following legal grounds:

  • We may collect your Personal Data for the performance of a contract to which you are the party, i.e. to use our Services (see our Terms of use). The provision of such Personal Data is a contractual requirement and you have to provide it, otherwise you will not be able to use our Services.
  • We may collect your Personal Data when you have given consent to such processing. In this case you have the right to withdraw such consent at any time.
  • We may collect your Personal Data for the compliance with a legal obligation, i.e. anti-money laundering and the countering of financing of terrorism regulations, responding to legal process, etc.
  • We may collect your Personal Data for our legitimate interests and/or those of third parties while applying appropriate safeguards that protect your privacy. This may include: providing, maintaining, and improving our services to meet the needs of our users; marketing to inform users about our services; customizing our services to provide you with a better user experience; detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our service, etc.

If you have questions, you can contact us. You can also contact your local data protection authority if you have concerns regarding your rights under local law.

Retention

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary.

  • Some information is retained until you remove it – this is account related information. We’ll keep this data in your Account until you choose to remove it and/or update it.
  • Some information is retained until your Account is deleted.
  • Some information may be retained for extended time periods (e. ensuring the continuity of our Services, financial record-keeping, security and fraud prevention, etc.).

If you delete your Account, please note: (1) there might be some latency in deleting information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Changes

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

For substantial changes we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If there are any questions regarding this Privacy Policy please contact us.