Security and Privacy are our priorities.
What types of personal information do we collect?
When you apply for, open, or maintain an account with us, you should be aware that we collect the following types of information:
Information you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, date of birth, country of residence, contact information and any information that is provided through your communications with Tokeny. Some of the information we collect is considered to be sensitive personal data, by accepting the Terms of Service and using Tokeny’s services you explicitly consent to the collection of this data. If you do not consent to this collection please contact our data officers at email@example.com and they will comply with any of your requests to delete, edit, or audit your data. You may also have access to your data by contacting the data officers.
We also collect aggregate and anonymous data that does not identify you specifically, including data collected automatically when you enter our website. This may include cookies, pixel tags, web beacons, browser analysis tools and web server logs. This also includes information from the devices you use to access our Site or mobile platform, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device, among other information. If you would like more information regarding this data please feel free to contact us at firstname.lastname@example.org and we would be more than happy to assist with your questions and requests.
Why Do We Collect Personal Information?
We use and disclose personal information only for the purposes that we disclose to you. We will request your consent before we use or disclose your information for any materially different purpose. We specifically disclose your data to the Offering organizers who use the Tokeny portal in order for you to have the opportunity to participate in the Offerings. In addition, unless specifically described below, consent may be obtained in any legally sufficient method. Please be notified that you may opt-out of our collection process at any time by contacting our data officer though email@example.com. We will respond to opt-out and deletion requests within 48 hours during non-Holiday weekdays. You may also request access to your data records and request changes to your data at anytime by contacting us at firstname.lastname@example.org
We collect, use and disclose personal information to meet the needs of our customers and users to better our business purposes for their benefit, including:
-to provide the products and services you request;
-the day-to-day operation and maintenance of accounts and services;
-collection of amounts outstanding from you;
-to tell you about services or other related products and services offered by us;
-to manage our websites and services;
-to understand our customers and users needs;
-to learn about our markets and design and improve our services and related products;
-to administer and process any request for information or job application;
-to comply with our regulatory and legal obligations, including but not limited to warrants, subpoenas and court orders or to meet government tax reporting requirements;
-to contact you (including by way of e-mail), including:
-in response to your inquiries and comments, and to safeguard your interests;
-to provide you with information about our products and services, or those of others, that you may be interested in;
-to investigate suspicious activities; and
-to protect our rights and property.
We may cooperate with government and law enforcement officials or private parties to enforce and comply with applicable laws and regulations. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: to respond to claims, legal process, subpoenas; to protect our intellectual property, rights and safety and the property, rights and safety of a third party or the public in general; and to stop any activity we consider illegal, unethical or legally actionable activity.
Where do we store personal information?
It is important to note that some or all of your personal information provided to third party service providers may be held in countries other than your own. You acknowledge and understand that your personal information will be subject to the applicable laws of each such jurisdiction, which may not provide for the same protection as your country of residence. If you have questions about our policies and practices with respect to service providers outside your jurisdiction, including the collection, use, disclosure or storage of such personal information by our service providers worldwide, you may contact us at email@example.com.
What Third Parties do we work with?
In order to participate in an Offering, you will have to provide information to pass Know Your Customer(KYC) and Anti-Money Laundering (AML) verifications. Tokeny provides this data to third-party companies such as Onfido to verify all KYC/AML information. When you participate in a company’s Offering your data is shared with the offering company. Be aware that when you participate in an Offering, the Offering company may use a different KYC/AML service than the service Tokeny uses. Tokeny also provides your anonymized data to the company Analytics Solutions in order to do analytics to better operate our company for our users.
When you subscribe to purchase tokens from an Offering that uses our platform, you will be asked to provide financial data and information to verify your status and successfully make financial transactions. Depending on how you wish to purchase tokens you may be required to provide financial data, such as your bank routing number and bank account number, to enable the offering company to utilize your bank account to originate funds transfers and make subsequent investment transfers to you if necessary.
How do we protect the confidentiality and security of personal information?
We maintain reasonable GDPR compliant physical, electronic, and procedural safeguards to protect your personal information. We have a data protection audit and recovery system in place. We track and maintain strict records for all of our data processing activities. We place your account information on the secure portion of our website, using firewalls and other security technology to protect our network and systems from external attacks, and we require you to enter a unique and confirmed email and password to access your account information online. Our servers are enabled with Secure Sockets Layer (SSL) technology to prevent unauthorized parties from viewing the personal information that you provide or access during a secure session (look for the padlock icon on your browser). In addition, if you access information online, we use digital certificate services to authenticate that you are transacting with our website and not the website of an impostor.
Your Data Rights
When you provide data to our site you retain the right to be informed of how your data is used, right of access to your data, right to rectification of your data, right to erasure or your data, right to restrict processing of your data, right to data portability, right to object and right to not be subject to profiling with your data. You also have the right to review, edit or delete your data at anytime.
Retention and Deletion of Data
We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Users with an active account have the ability to request that we delete their data at any time. When a user makes a request to have their account deleted and all data deleted, all Personal Data collected through the platform will be deleted, as required by applicable law.
Controlling Your Data
We want to make it clear to our Users that you have control of your data. If you wish to have your personal data edited, deleted, or audited please contact us anytime at firstname.lastname@example.org and our data collection officers will be able to accommodate your requests.
No Users Under 18 Years of Age
Our website is not targeted to persons under the age of 18 and we do not intentionally collect personal information from persons under the age of 18. Any user that attempts to submit information revealing their age to be under 18 will be blocked and their information deleted.
Updates to This Policy
Tokeny may amend this policy from time to time. The revisions will take effect on the date of publication of the amended policy, as stated. We will notify you through our website or by email of any material changes to the policy. If you do not wish to comply with the updates to this policy then please do not use our website and services.