ICO Syndicate Ltd. is a company incorporated and registered in Belize with registration number 169,739 (“ICO Syndicate“) that develops and operates the ICO Syndicate Services designed for professionals in trading of tokens and cryptocurrency.
ICO Syndicate Ltd.
registration number 169,739
Personal data are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as “Regulation”).
Data subject: A natural person (consumer or self-employed) to whom the personal data relate (hereinafter referred to as “you” or “Member”);
Personal data: Any information about an identified or identifiable Member; an identifiable Member is a natural person who can be identified, directly or indirectly, in particular by reference to a particular identifier, such as name, identification number, location data, network identifier or one or more specific physical, physiological, genetic, psychological, economic, cultural or social identity elements of this individual (hereinafter referred to as “Personal data”, “Data” or “Information”);
Controller: An entity that determines the purpose and means of processing personal data, carries out processing and bears responsibility for such processing. A controller of personal data processed in connection with the operation of the ICO Syndicate website and related services is ICO Syndicate Ltd. (hereinafter referred to as “We” or “ICO Syndicate”);
Processor: An entity that processes personal data for the Controller, by law or under the authority of the Comptroller, based on an agreement on personal data processing (hereinafter referred to as “Business Partner” or “Partner”);
Website: The website available at www.icosyndicate.org (hereinafter referred to as “Website”);
Purpose for Personal Data Processing: A reason why personal data is processed. Such reasons may include, for example, verification whether or not you are eligible to to purchase the Partner ICO’s tokens according to our T&Cs, provision of our services to you, management of Member accounts or sending informational emails (hereinafter referred to as “Purpose”);
Cookies: Short text files saved by your web or mobile browser. Most cookies contain a unique identifier, a so-called cookie ID. This is a string of characters assigned by websites and servers to the browser that saved the cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the performance of websites, evaluate their traffic, and better target marketing activities. If you browse our website, we assume you agree to use these files (hereinafter referred to as “Cookies”);
Services: The services provided by ICO Syndicate to the Members consisting of i) development and operation of ICO Syndicate Information channels ii) distribution of options to purchase the Partner ICO’s tokens in a limited time window either directly from Partner ICO or via smart contract operated by ICO Syndicate or by third partyand related information via the Information channels to the Members and iii) linking to smart contracts for the purchase of Partner ICO tokens (hereinafter referred to as “Services”).
WHAT PERSONAL DATA DO WE PROCESS?
We will process the following personal data, or categories of personal data:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details and photos, and/or education details);
- electronic contacts (e.g. email adress);
- blockchain addresses and transactions;
- information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- personal opinions made known to us (e.g. feedback or responses to surveys).
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
HOW DO WE COLLECT YOUR DATA?
We process data you provide us. Typically, they include:
- your name, address and primary place of residence;
- your email address(es);
- your phone number;
- a photocopy of your ID;
- a photograph of yourself;
- your corporate information (if applicable);
- other personal data (typically, data provided by you in an order form or other documents and in communication with us, including later updates); and
And the data we get automatically as you browse through our website. Typically, they include:
- IP address, cookies, location data of the device used by you.
WHY DO WE PROCESS YOUR PERSONAL DATA?
Your personal data may be processed by us for the following purposes:
- Identity verification (KYC) purposes
- Purpose: We use your personal information to identify you and/or verify your identity in accordance with applicable International Anti Money Laundering regulations. We also use personal information you provided our partners who provide us identity verification services.
- Legal basis: Processing of personal data for know your customer purposes is justified by the fulfilment of legal obligations. We must process this data about you.
- Retention period: We process personal data for know your customer purposes for a period of time set by the applicable law.
- Member account management
- Purpose: The account on the Website the Member may be provided in order to improve the experience of the use of the Services or to use the Services.
- Legal basis: The processing of personal data for the purpose of managing Member accounts is justified by your consent. The provision of personal data is voluntary in such case. However, it would not be possible to register the Member account without agreeing to the processing of an email address. You can withdraw your consent at any time.
- Retention period: The data retention period is determined by the duration of your consent. We will consider your consent to be withdrawn when you do not log in to your account for 4 years.
- Communication with you
- Purpose: We use your data to comunicate with you, to manage your queries, handle ideas and complains. If you decide to use one of instant message services to communicate with us, it is important to keep in mind that the processing of data provided in this way is also governed by the terms of the providers of such services that we cannot influence. The use of these third-party services is therefore at your own risk. Before you make use of these services, we recommend you to read the privacy policies of those third parties.
- Legal basis: The processing of personal data for the purpose of communication with you is justified by our legitimate interest in communicating with our Members. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose.
- Retention period: The data retention period depends on the duration of the Member's relationship with us, and then it lasts for a period of 4 years after its termination.
- Sending informational emails
- Purpose: We regularly send emails to our customers and those who have given their consent with information about options to purchase the Partner ICO’s tokens. You can quickly and easily stop receiving these informational emails at any time by using the opt-out link contained in each email.
We always ask you to agree to receive the informational emails whenever your consent is required by the applicable laws. We can use the information you provide to us, as well as information obtained otherwise in relation to our Services - such as how you use the Website or pledging history to personalize our informational emails.
- Legal basis: The processing of personal data for the purpose of sending informational emails is justified by your consent. Providing personal data based on your consent in this case is voluntary, but it would not be possible to send you options to purchase the Partner ICO’s tokens without it. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose.
- Retention period: The data retention period is determined by the duration of your consent. We will consider withdrawing consent or terminating a legitimate interest if you do not open our informational emails for 3 years.
- Direct marketing and creation of personalized content and advertising
- Purpose: A personalized content and advertising creation technologies allow us to show visitors who have already expressed their interest in our Website and Services, our advertisements on partner websites. We strive to show you only the advertisements that you are really interested in, and not advertisements without any connection to you and your interests. Based on your interests, and website behaviour, personalized content and offers can be displayed on our Website and on third-party websites and applications (including social networks). This is especially possible with cookies.
- Legal basis: The processing of personal data for the purpose of direct marketing and creation of personalized content and advertising is justified by your consent or by our legitimate interest in direct marketing. Providing personal data based on your consent in this case is voluntary, but it would not be possible to provide you personalized content and advertisements. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period data is determined by the duration of your consent. The retention period may vary depending on the type of cookies. Some cookies are limited by the duration of the session (so-called relational or session cookies). These are processed while the browser is running, and are automatically removed after shutting down. Other cookies are persistent (persistent cookies). These cookies remain in the browser even when it is turned off until the specified date, or when the user manually deletes them. According to these cookies, the user's computer can be identified when the web browser is restarted and the Internet is browsed.
- Improving quality of our Services and Website
- Purpose: ICO Syndicate always tries to improve the quality of the Services and your better experience. The development of new Services and the improvement of existing ones is done by identifying the needs and wishes of Members through our information channels (our Website Member account, Informational emails, Group chat “ICO Syndicate” on instant messaging software Telegram etc.).
Furthermore, in relation to browsing our Website, we process information about traffic, readings, a number of pages viewed, device from which you come to our Website, and the time spent on the Website. This data helps us identify less accessible or less understandable content on our Website. We collect these data to provide quality content that is user-friendly to you and to develop Website and Services that you are clearly interested in.
If you do not want data to be collected using these technologies, you can use a simple procedure: most browsers offer you the ability to automatically reject many such technologies, or choose whether you accept or reject them.
- Legal basis: The processing of personal data for the purpose of improving quality of our Services and Website is justified by your consent, or by our legitimate interest in direct marketing. Providing personal data on the basis of your consent is optional in such case, but it would not be possible to improve the quality of the Services provided to you, analyse the traffic to our Website and your website behaviour. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period is determined by the duration of your consent. The retention period may vary depending on the type of cookies. Some cookies are limited by the duration of the session (so-called relational or session cookies). These are processed while the browser is running, and are automatically removed after shutting down. Other cookies are persistent (persistent cookies). These cookies remain in the browser even when it is turned off until the specified date, or when the user manually deletes them. According to these cookies, the user's computer can be identified when the web browser is restarted and the Internet is browsed.
- Protection of our rights, property or safety or rights, property or safety of others
- Purpose: We may use information about how you use our Services and Website to prevent or detect frauds, misuse, illegal use, and violation of our T&Cs, and to comply with a decision of the court or other law enforcement bodies, the state administration or the conditions established by the applicable legal regulations.
- Legal basis: Processing of personal data in order to protect our rights, property or safety or the rights, property or safety of others is justified by the fulfilment of legal obligations, or our legitimate interest in the protection of our rights, property or safety or the rights, property or safety of others. The provision of personal data in this case is not a legal or contractual requirement. You are under no obligation to provide us with your personal data for this purpose. However, some data are processed automatically for this purpose when you browse our website.
- Retention period: The data retention period is 4 years upon the termination of our contractual relationships, or 4 years upon their receipt.
- Accounting and tax purposes
- Purpose: We also need to process your personal data because we are obliged to do so according to the appropriate accounting and tax legislation.
- Legal basis: Processing of personal data for accounting and tax purposes is justified by the fulfilment of legal obligations. We must process this data about you.
- Retention period: We process personal data for accounting and tax purposes for a period of time set by the applicable law (e.g. accounting data are processed for 10 years).
WHO HAS ACCESS TO YOUR PERSONAL DATA?
Your personal data are primarily made available to our employees who need the data to provide you with our Services.
In addition to our employees, we need to pass on your personal data to various business partners that enable us to function and help us deliver better, more accurate and more personalized Services. The partners that we entrust your personal data with are very carefully selected. We only work with those who are able to provide such technical and organizational security of your personal data so as to prevent unauthorized or accidental access to your data or their misuse. All of these partners are authorized to process your data solely on the basis of a personal data processing agreement in which they undertake the obligation of confidentiality. The data provided must not be used for any other purpose than for which we have made the data available to them.
The following categories of our partners (recipients) can have access to your personal data:
- Partners that assist us with identity verification (KYC)
- Partners we assist with identity verification (KYC)
- Partners whom we provide the data to analyse the visit rate of our website, your website behaviour, and business conversions
- We strive to make your experience of using our website as enjoyable as possible. That is why we work with partners who conduct visit rate and your behaviour analyses on our website. Thanks to these partners, we have information about which part of our website is unclear, where you are looking for the information you are looking for and whether you find it, which offers on our website you have clicked, etc. Based on this information, we regularly improve our website.
- Partners who provide us with services that ensure the technical service of a particular service, and technology operators we use for our services
- In order for ICO Syndicate to function properly and provide you with the Services, we need to work with a wide range of partners who provide us with services, ensure the technical operation of a particular service, or operate the technologies we use for our Services. Typically, they include these categories of partners:
- providers of information and communication services and hosting, including but not limited to cloud storage,
- providers of security and integrity of our services and websites,
- providers of analytical services,
- providers of accounting and tax consultancy,
- support service providers for customer support,
- payment service providers (payment card providers),
- social network operators,
- legal service providers, lawyers,
- providers of printing and postal services, including but not limited to couriers,
- partners working with us in loyalty programs, during the organisation of conferences, seminars and other events.
- Our direct marketing partners and our partners and technical solution providers thanks to which we can show you personalized content and advertising
- In order to present and promote our services, we use marketing agencies to which we provide some data that we need for accurate targeting of our ads.
- In order to get the best experience while visiting our website, we will provide you with relevant information, recommend services, and send reminders of orders left in your shopping cart. All of these services are based on your previous purchases, on which items you click on our website and which information you have given us.
- In order to ensure that our ads will be shown to a relevant audience, we share your personal data, including email addresses, with providers of technical solutions to help us show you personalized content and advertising.
do we transfer your personal data outside the EU?
If we transfer personal data of our customers for processing to a third country (outside the European Economic Area, including countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organization, we do so only provided that the third country or international organizations provide an adequate level of protection, or where the recipient of the personal data provides appropriate safeguards for their protection and where the enforceable rights of data subjects and the effective legal protection of data subjects are available in the country of destination.
The European Commission has so far recognized an adequate level of protection in the following countries: Andorra, Argentina, Canada (trade organizations), the Faroe Islands, Guernsey, Israel, the Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the USA (limited to the Privacy Shield framework).
how do we process your personal data?
The personal data are processed manually and by automated means. For all processing activities, we maintain proper records in compliance with applicable laws.
WHAT ARE YOUR RIGHTS?
When you exercise your rights, please contact us through our contact details listed in the introduction of this policy. We reserve the right to verify the identity of the applicant for the rights in question in an appropriate manner. If requests are repeated and are clearly unreasonable or inappropriate, we may charge you a reasonable fee or refuse to accept the request.
- Right of access to personal data
- If you want to know if we process your personal data, you have the right to obtain from us the information about whether your personal data are processed and, if so, you also have the right to access your personal data. In case of a repeated request, we are entitled, based on our administrative costs, to charge a reasonable fee for a copy of the personal data provided.
- Right to correct inaccurate and complete incomplete personal data
- If you believe we are processing inaccurate or untrue data about you, you have the right to request their correction. You also have the right to complete any incomplete data. We will do the correction or update without undue delay, always with respect to our technical possibilities.
- Right to have the data erased
- If your personal data are no longer needed for the purposes for which they were collected or otherwise processed, or if you find out that they have been processed unlawfully, you have the right to request that they are erased.
- Right to restrict the processing of personal data
- If you are not interested in complete erasure, but only in a temporary restriction of the processing of your personal data, you may request us to restrict the processing of your personal data.
- Right to data portability
- In case you want us to pass on your personal data to third parties, you can exercise your right to data portability. If any rights and freedoms of third parties could be adversely affected by such exercise of your right, we will be unable to comply with your request.
- Right to object
- You have the right at any time to object to the processing of personal data that is processed for the purpose of performing a task carried out in the public interest or in the exercise of public authority or for the purpose of protecting our legitimate interests. If we do not prove that there is a serious legitimate reason for the processing that outweighs your interests or rights and freedoms, we will terminate the processing based on your objection without undue delay.
- Right to withdraw consent at any time
- If the processing of your data is based on your consent, you have the right to revoke your consent at any time.
- Right to information on automated decision-making, including profiling
- You are not the subject of any decision based solely on automated processing, including profiling, which would have legal effects for you or would have a significant impact on you in a similar way.
- Right to file a complaint with the Office for Personal Data Protection
- You have the right to file a complaint with the supervisory authority, which is the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, SI-1000 Ljubljana, Phone: ++386 1 230 97 30
HOW DO WE PROCESS COOKIES?
Cookies are used by most websites and servers to provide a whole range of basic Internet services. If you shop online, cookies are used by online shops to store the items you have previously added to your shopping cart. Cookies also allow our website to store your preferences (such as language or login) and use them during your next visit. Using cookies, one can also collect statistics on user activities, such as the number of unique visitors of the website per month, which are very valuable to the operator as they provide better, more user-friendly services.
Cookies can be divided by validity into:
- Session cookies that remain stored in your browser only until you close your browser,
- Persistent cookies that remain in your browser for a long time until their lifetime expires or until you manually delete them (cookie storage time in your browser depends on cookie settings and browser settings).
And by function into:
- Essential that are necessary for the functionality of our website,
- Preferential that allow our website to remember the information that changes how the website behaves or what it looks like (e.g. the preferred language or region you are in); these cookies are not strictly necessary for the functioning of our website, but increase the functionality and practicality of its use,
- Analytical that help us analyse your experience on our website (so-called User Experience) and thanks to which we understand how you use our website,
- Remarketing which we use to properly target and personalize content and ads,
We also use third-party cookies that track multiple websites in order to provide you with personalized content and advertising on third-party websites and other sales channels.
Through conversion cookies on our website, we measure the number of orders that were sent after the customer came to our website by clicking on the ads on our advertiser's website or linking them through a link on their partner's website. This is how we perform a performance analysis of our individual sales channels, based on the financial statement between us and our advertising partners. You cannot be identified through such conversion cookies, so they are not personal data. Our advertising partner will only receive information of the total number of users who clicked on the ad or placed an order with us.
WHERE CAN YOU LEARN MORE ABOUT COOKIES AND PRIVACY ON THE INTERNET?
You may change your browser settings so that it removes cookies or prevents them from being stored on your computer or mobile device without your explicit consent. For information about cookies setting, see the relevant browser help section. How it works on the most commonly used browsers can be found here:
Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html
You can also visit http://www.youronlinechoices.com/ (English), www.allaboutcookies.org (English) or www.aboutads.info/choices (English), where you can learn about the possibilities of refusing certain targeted advertising activities offered by some third parties with whom we work. You will have to visit the websites of individual browsers and the devices to which your disagreement should relate. Because the tools for expressing disagreement may depend on cookies, you may have to visit these sites again and reset preferences if you delete the cookies.
DO WE PROCESS PERSONAL DATA OF CHILDREN?
Our website and services are not intended for children under the age of 16. Therefore, we do not deliberately collect their personal data. If we find that we have inadvertently obtained personal data of children under the age of 16, we will take steps to erase these data as quickly as possible, except when we are legally bound to keep them.
FINAL PROVISIONS AND APPLICABLE LAWS
We reserve the right to change, modify, add, or remove portions of this Policy for any reason at any time by posting the amended Policy on the Website. In such a case the Member is obliged to read the amended Policy or immediately cease accessing or using the Services.
This Policy will be governed by and construed and enforced in accordance with the laws of the Belize, without regard to conflict of law rules or principles that would cause the application of the laws of any other jurisdiction.