Last updated: July 26th, 2023
Tokenovate Privacy Policy
Understanding, managing and caring for data is important for Tokenovate. This Privacy Policy explains how Tokenovate handles your personal data that you provide to us when you visit our websites (“Sites”) and when you contact us.
If you use Tokenovate’s products or services, further information may also be provided in your contract with us. If you use the services of an organisation that is itself a customer of Tokenovate, please raise any data protection queries with them directly.
Your Data
Your “Data” means any information about you which can help personally identify you, including, without limitation, your name, address, telephone number, email address, financial details, comments, and other information from which you can be identified and which you may disclose to us or otherwise via the Sites at any time.
When do we collect your Data?
When you contact us; in monitoring your communications sent via and during use of the Sites to ensure and check compliance with our Terms of Use or otherwise as required by law; and when you disclose your Data to us or otherwise through the Sites at any other point. We may also collect such information when you contact us in person (for example, at conferences, workshops, seminars and other events), via telephone or social media. When you send us an email, that address will be recorded automatically for purposes of replying to your email. Tokenovate provides services to corporate entities, and as such assumes all information you provide to Tokenovate is to be as a representative of a corporate entity, i.e. a “legal person”.
How we use your Data
We use the Data we collect for the following purposes:
- To monitor, develop and improve the Sites and your experience; to process and deal with any complaints or enquiries made by you;
- To investigate any suspected breach of our Terms of Use made by or otherwise relating to you and to monitor compliance including by way of checking postings to the Sites, retaining forum or chat room exchanges and using keyword triggers to investigate usage that may be inappropriate;
- To send you and keep you updated with information about existing and new services and special offers from us; and
- To send you information about related products or services of selected third parties that may be of interest to you.
- Carry out any other purpose for which the Data was explicitly collected.
Some of this Data may also be shared with our product or service providers or sub-contractors, in order for us to deliver our services.
We use Data for the above purposes where it’s necessary in our legitimate interest to do so, where we have a legal obligation or where you’ve provided your consent
To opt-out of receiving any information pursuant to these latter two cases, you can use the facility contained in any such communication or email us at support@tokenovate.com stating the method used to contact you and whom you do not wish to receive further communications from.
Will we pass on your Data to third parties?
We may pass anonymised statistical information about the Sites user base, sales patterns, traffic volumes and related matters to reputable third parties but these details will not include information personally identifying you. We may disclose your Data to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of our Terms of Use of or otherwise where required by law. We do not pass or sell your Data to third persons for any other purpose than those set out above. Where marketing as described above in “How we use your Data” is conducted by us on behalf of third parties, they do not have any access to your Data unless you yourself choose to contact them.
Data Retention
Your Data will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by applicable law). However, we will not retain any of your Data beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Data Security
Tokenovate is committed to seeking to safeguard all Data that you provide to us; seeking to ensure that it remains confidential and secure; and taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure, and loss or corruption by computer viruses and other sources of harm. We limit access to personal information to those staff members, joint venture partners, subsidiary companies and third parties who need to know that information for the purposes set out in this Privacy Policy.
Cookies
Cookies are small pieces of information stored by your browser on your computer’s hard drive. We use cookies to allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited, to determine the most popular areas of the Sites and generally in order to monitor usage of the Sites. Most web browsers automatically accept cookies, though you do not have to. We do not control the use of cookies by third parties. If you wish to disable cookies, you can do so by adjusting your browser settings; however, please note that by disabling cookies you may not be able to register with or use all features of the Sites.
Cookies Settings
For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau.
Other links
Please be aware that the Sites may link to other web Sites that may be accessed by you. We are not responsible for the data policies, content or security of the Sites. We do not have any control over the use to which third parties may put your Data where you choose to purchase products or services or otherwise to contact them via the Sites.
Transfer Outside the EEA
Individuals in the European Union should be aware that Tokenovate may transfer your personal data to a third party in countries outside the EU/EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to our outsourced service providers located abroad. In these circumstances, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please see the “Data Security” section in this Privacy Policy or contact Tokenovate’s Data Protection Officer (details set out below) for further information about the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.
Children
We do not knowingly collect personal information from children under age sixteen. Children under the age of sixteen are not permitted to use the Sites. We will delete any information later determined to have been collected from an underage user.
Tracking
The Sites do not respond to “do not track” settings in browsers.
Grounds for Processing in the EU/EEA
If you are in the European Union and/or European Economic Area, to process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include: (1) your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes; (2) our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your data to send you our electronic newsletter and product updates if you represent a corporate entity (unless you have unsubscribed); (3) our compliance with a legal obligation to which we are subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or (4) if you are a customer, or are representing a customer, because processing your personal data is necessary for the performance of a contract.
Your EU/EEA Data Protection Rights
Please contact us at support@tokenovate.com any time to exercise any of your data protection rights. Data protection law applicable to individuals in the European Union and/or European Economic Area provides individuals with certain rights, including the right to access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:
- Right to obtain a copy of your personal information. You may have the right to obtain a copy of the personal information we hold about you.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy. We will respond to your request to correct or supplement your personal information within a reasonable time period and, in any event, within any time period specified in relevant laws.
- Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
- Right to object to processing. You may, as permitted by law, request that we stop processing your personal information. You also have the right to ask us not to process your personal data for marketing purposes.
- Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority in the relevant country directly. In the UK, this is the Information Commissioner’s Office at https://ico.org.uk.
California Privacy Rights
Cal. Civ. Code § 1798.83 (2006) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@tokenovate.com or write to us at Tokenovate Limited, C/O Max Accountants Ketton Suite, The King Centre, Main Road, Barleythorpe, Rutland, England, LE15 7WD.
Contact Us
If you have any comments or queries in connection with our Privacy Policy, please contact our Data Protection Officer by email at dpo@tokenovate.com, or write to us at Tokenovate Limited, C/O Max Accountants Ketton Suite, The King Centre, Main Road, Barleythorpe, Rutland, England, LE15 7WD.
Tokenovate Limited is a company registered under the laws of England and Wales, whose company number is 14042289 whose ICO Registration No. is ZB509326 and whose registered office is: C/O Max Accountants, Ketton Suite, The King Centre, Main Road, Barleythorpe, Rutland, England, LE15 7WD.
Changes
We may periodically update this Privacy Policy. The most current version of the Privacy Policy will govern our use of your information and will always be available at https://www.tokenovate.com/privacy. By using the Sites, you acknowledge your agreement to the terms of this Privacy Policy. We will notify you about material changes in the way we treat your Data by sending a notice to the email address specified in your account or by placing a prominent notice on our website.