About this Notice
This privacy notice (“Notice”) explains how and why Vesting Labs Ltd. with company number 14695174 and registered office address at 101 New Cavendish Street, 1st Floor South, London, United Kingdom, W1W 6XH, and its associated companies (also referred to as “TokenOps”, “Company”, “we”, “our” and “us”) uses personal data about those individuals that either use or access our website https://tokenops.xyz/ (the “Website”) or use our services as may be described on the Website from time to time (the “Services”) (in each case, referred to as “you”).
You should read this Notice, so that you know what we are doing with your personal data. Please also read any other privacy notices that we make available to you, that might apply to our use of your personal data in specific circumstances outside the scope of this Notice, which primarily concerns our processing of your personal data in relation to or in connection with the Website and other Services.
Please note our Services are not intended for use by individuals under 18 years of age.
Who we are and our contact details
2.1.
We are Vesting Labs Ltd. with company number 14695174 and registered office address at 101 New Cavendish Street, 1st Floor South, London, United Kingdom, W1W 6XH. We own and manage the Website and software used in the Services and are the controller.
2.2.
Our contact for data protection purposes is privacy@tokenops.xyz
Our data protection responsibilities
In this Notice we refer to the following terms, which have the following meanings:
“Personal data” is any information that relates to an identifiable natural person. Your name, address and contact details are all examples of your personal data, if they identify you.
The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.
The Company is a so-called "controller" of your personal data. This means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws.
What types of personal data do we collect and where do we get it from?
We collect your personal data from various sources. The table below sets out the different types of personal data that we collect and the sources we collect it from. Typically, you provide us with personal data directly when you communicate with us (including via the Website), or when you use our Services. We also obtain some personal data from other sources, and create some personal data ourselves, as set out in the table.
Please be aware that we cannot communicate with you or perform the Services without your personal data. Where we don’t need your personal data, we will make this clear, for instance we will explain if any forms you are required to complete are optional or contain sections that can be left blank.
If any of the personal data you have given to us changes, such as your contact details, please inform us without delay so that this can be updated.
What do we do with your personal data, and why?
We process your personal data for engagement with us or use of the Services, and the management and administration of our business.
We are required by law to always have a so-called “lawful basis” (i.e. a reason or justification) for processing your personal data. The table below sets out the purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
Please note that where we have indicated in the table that our processing of your personal data is either:
(a)
necessary for us to comply with a legal obligation; or
(b)
necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it.
Contact Information
Website Information
Services Information
All categories
We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use it to conduct research and analysis, including to produce statistical research and reports. For example, to help us understand the spread of our customers.
Who do we share your personal data with, and why?
Sometimes we need to disclose your personal data to other people.
From time to time we may ask third parties to carry out certain business functions for us, such as IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will seek to ensure that they have appropriate security standards in place to protect your personal data. Examples of these third-party service providers include service providers and/or sub-contractors, which include IT systems software and maintenance, back up, and server hosting providers.
In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right, for example where:
(a)
we buy, sell or transfer our business (or part of it) in connection with a share or asset sale or outsourcing, we may disclose or transfer your personal data to the prospective seller, buyer or transferor and their advisors; and
(b)
we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others.
We have set out below a list of the categories of recipients with whom we are likely to share your personal data:
(a)
IT support, cloud platform and data hosting providers;
(b)
consultants and professional advisors including legal advisors and accountants;
(c)
courts, court-appointed persons/entities, receivers and liquidators; and
(d)
governmental departments and statutory and/or regulatory bodies.
Where in the world is your personal data transferred to?
We may transfer your personal data to external recipients that are established in jurisdictions other than your own.
Please be aware that the data protection laws in some jurisdictions may not provide the same level of protection to your personal data as is provided to it under the laws in your jurisdiction.
We will always seek to ensure that adequate protections are put in place when transferring your personal data from within to outside the UK or European Economic Area. For more information regarding the transfers undertaken by us and the protections put in place, please contact us using the details set out at the end of this Notice.
We have set out below a list of the categories of recipients with whom we are likely to share your personal data:
How do we keep your personal data secure?
We will take specific steps (as required by applicable data protection laws) to ensure we take appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
How long do we keep your personal data for?
We will only retain your personal data during the use of the Services or, if longer, for no longer than is necessary for the purposes for which we are processing your personal data. This will depend on a number of factors, including:
(a)
any laws or regulations that we are required to follow;
(b)
whether we are in a legal or other type of dispute with each other or any third party;
(c)
the type of information that we hold about you; and
(d)
whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
. How do we communicate with you?
We will use your personal data to communicate with you:
in relation to any use of our Services;
to administer our relationship with you;
to respond to any questions or complaints that you may have; and
to invite you to take part in market research or request feedback on our products and services.
From time to time and with your consent (where required), we will provide you with information about news which may be of interest to you.
Where you have subscribed to our online newsletter, we will also provide a copy by email.
Please note that you may opt-out of receiving the newsletter and any other marketing materials that we send you, by unsubscribing or contacting us at any time through the Website or by emailing at contact@tokenops.xyz.
What are your privacy rights and how can you exercise them?
Where our processing of your personal data is based on your consent (please see the tables above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.
Where our processing of your personal data is based on the legitimate interests (please see the tables above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
Laws in certain jurisdictions may provide individuals with rights relating to personal data, such as those listed below. We will honour these rights to the extent required by law. You have the right to (subject to applicable laws and certain limitations):
(a)
access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
(b)
require us to correct any inaccuracies in your personal data without undue delay;
(c)
require us to erase your personal data;
(d)
require us to restrict processing of your personal data;
(e)
receive the personal data which you have provided to us, in a machine-readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (please see the tables above) and where the processing is automated; and
(f)
object to a decision that we make which is based solely on automated processing of your personal data (however, we do not currently conduct any such decision making).
If you wish to exercise any of these rights, please contact us at privacy@tokenops.xyz in the first instance. We will aim to respond to all legitimate requests within one month of receipt.
You may also have the right to lodge a complaint with the relevant data protection regulator (for example for the Information Commissioner’s Office in the UK (www.ico.org.uk).
12. Updates to this Notice
We may update this Notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice. We also encourage you to check this Notice on a regular basis.
13. Where can you find out more?
We may update this Notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice. We also encourage you to check this Notice on a regular basis.
14. General
This Notice should be read together with our cookie notice available at https://tokenops.xyz/cookie-notice
