Following are the privacy policies of Algorand Foundation and CoinList. Where there is any conflict, Algorand Foundation's policy controls.
Effective Date: May 23, 2019
However, we would like to point out that data transmissions via internet (e.g. e-mail communication) cannot be entirely secure and may have security vulnerabilities. A complete protection of personal details against unauthorised access by third parties is not possible.
IF YOU PROVIDE PERSONAL DATA TO US, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL DATA IN ACCORDANCE WITH THIS POLICY. IF YOU PROVIDE THE PERSONAL DATA OF ANOTHER INDIVIDUAL, IT MEANS THAT YOU HAVE INFORMED HIM/HER OF THE PURPOSES FOR WHICH WE REQUIRE HIS/HER PERSONAL DATA AND HE/SHE HAS CONSENTED TO THE COLLECTION, USE AND DISCLOSURE OF HIS/HER PERSONAL DATA IN ACCORDANCE WITH THIS POLICY.
1.1 Database requests
In order to comply with international sanctions and applicable regulation for securities and to fight money-laundering or the financing of terrorism, we may need to check any personal data provided by you against publicly available databases.
1.2 Contact form
We use Hubspot for contact form management and by submitting forms, you acknowledge and agree that the information you provide will be transferred for processing in accordance with their prevailing terms, conditions and privacy policies. If you send enquiries to us via these forms, your data entered into the contact form, including the stated contact data, are stored for the purpose of dealing with your enquiry and in case of additional enquiries.
The given permission to the storage of the data, the email address as well as the use of such for the purpose of sending the newsletter can be withdrawn at any time via the "Unsubscribe" link within the newsletter.
1.4 Processing of data (customer data and contract data)
We collect, process, use and disclose personal data about the use of our Service (usage data) insofar it is necessary for enabling, improving or updating information on the use of the Service.
In addition, you acknowledge that the purpose of this Service is to provide information about the Foundation, the Service and the Auctions . If you wish to submit or have submitted personal data to us for the purpose of being registered for participation in the Auctions and/or as a potential acquiror of Tokens, you consent to our collection, processing, use and disclosure of such personal data for the purposes of such registration and also the issuance of Tokens for the purposes of the Auctions.
We also reserve the right to monitor, check and process your personal data if necessary to investigate or obtain evidence concerning any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct or to aid in such investigation or evidence gathering by any law enforcement or regulatory authorities.
We may also collect, process, use and disclose personal data where required or permitted by law for any purpose.
1.5 Transmission of data on contract conclusion for services and digital contents
Except as otherwise stated in this Policy above or expressly agreed on, we transmit personal data to third parties only if it is necessary in relation to the Service including transmitting data to the commissioned credit institution in charge with the payment.
1.6 Data processors
For the purposes of the Auctions, we have contracted authorized data Processors to process your personal data on our behalf for the given purposes herein. The personal data you provide may be processed outside Singapore in accordance with applicable data protection law(s).
1.7 Commercial use policy
Only in the event and for the time that you give us your consent, we will use your personal data and/or transmit it to our business partners and affiliates of Algorand Foundation in order for us or our business partners to inform you via e-mail about upcoming opportunities or to market and promote our respective products and services.
You may view, withdraw and (re-)give your declaration of consent at any time by sending an e-mail to the provider of this Service. To withdraw your consent, you may also contact us under the address published in the footer of the e-mail/imprint/legal notice.
1.8 Right of access to and correction of personal data
You have the right to be informed about your personal data in our possession or under our control, their origin and addressee and the purpose of data processing as well as the right to correction of those data at any time. For further questions and questions concerning personal data, feel free to contact us under the address published in the imprint/legal notice or send an email to : [email protected].
1.9 Objection to commercial mails
The providers of this Service or the information, products or services featured on this Website may publish their contact information in the Footer of e-mails/Legal Note/Imprint. The use of such contact information by third parties for the purpose of distributing unsolicited advertisements or other commercial information is prohibited. The operators of this Service reserve the right to take legal measures in case of being sent unsolicited commercial information, e.g. spam mails etc.
The Foundation (or, “we”, “us” or “our”) is a Singapore based public company limited by guarantee having its registered address at 1 George Street, #10-01, One George Street, Singapore (049145). Its mandate is to ensure open access to the Algorand blockchain technology, mint and launch the Algo Tokens (“Tokens”), provide long-term governance, community and ecosystem, and be a custodian of funds raised (the “Services”).
This Policy is meant to inform you, which Personal Data we collect, store, process, use and/or disclose, for which purposes and on which legal basis. We further inform you about your rights to protect your Personal Data.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. Your continued use of our Services or website constitutes your agreement to be bound by this Policy, as amended or updated from time to time.
2.1 Consent to international transfer in countries with lower level of data protection
If you do not wish your Personal Data to be transferred to third countries outside the EU/EEA, please do not tick the consent box and do not send any Personal Data to the Foundation.
Please note that the Foundation collects your Personal Data directly from the country where you are based and may store it on servers outside EU/EEA, which may be operated by third party service providers. The Foundation needs to involve the third party service providers due to their legitimate interests in having a secure and sufficient data storage system. The Foundation chooses the respective third party service providers with due care and pays attention that such service providers respect the applicable privacy laws, are aware of the importance of protection of personal data and implement “state-of-the-art” technical and organizational measures. Therefore, your potential interests in not transferring your personal data do not outbalance the legitimate interest of Algorand Foundation.
WITHDRAWAL OF CONSENT
In the rare circumstances where we ask for your consent to process your Personal Data, any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of Processing based on consent before its withdrawal. After your withdrawal we will stop to Process your Personal Data, including storage. This paragraph is only relevant for Processing that is entirely voluntary – it does not apply for Processing that is necessary or obligatory in any way. To withdraw your consent, please send us an e-mail to [email protected] or send a letter to Algorand Foundation Ltd, 1 George Street, #10-01, One George Street, Singapore (049145).
2.2 Which Personal Data we process
For the purposes of providing the Services and the conducting of the Auctions, the categories of Personal Data about you that we or our authorized third party data Processors may Process include:
2.3 How we collect your Personal Data
We may collect Personal Data about you from the following sources:
2.4 Creation of Personal Data
In the course of your interaction on the Algorand blockchain platform, we may also create Personal Data about you, such as records of your interactions with us and details of your transaction history.
2.5 For which purposes we use your Personal Data
We use your Personal Data to provide, maintain and improve our Services, to grant you access to Algorand blockchain and enable you the use of the Tokens. For marketing purposes, we use your Personal Data only if and as long as we have received your explicit prior consent and in accordance with respectively applicable additional legal requirements in your jurisdiction. We do not sell your Personal Data to third parties.
In addition, you acknowledge that the purpose of our Service is to provide information about the Project and the Auctions . If you submit Personal Data to us or our authorized Processors for the purposes of participation in the Auctions and/or as a potential acquiror of the Tokens, we will collect, process and disclose such personal data for the purposes of registration for the Auctions and also the issuance, distribution, use and circulation of or exchange for the Tokens.
2.6 Lawful basis for Processing Personal Data
In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
When we are involving third party Processors into the performance of our services and contractual obligations and such involvement requires the sharing of Personal Data, we have entered with our third party Processors into data processing agreements according to Art. 28 of the European General Data Protection Regulation (“GDPR”) and, as far as required, further appropriate safeguards according to Art. 46 – 49 GDPR. The list of third party Processors to which we disclose your Personal Data can be requested by e-mail to [email protected]
Specifically we can already name the following Processors:
Our data processor CoinList Services LLC, 850 Montgomery Street, Suite 350, San Francisco, CA 94133 (“CoinList”), is processing personal data on our behalf including for customer identification, anti-money-laundry, accreditation, and contribution purposes.
Categories of third parties “Non-Processors” to whom we may disclose your Personal Data.
We may also disclose your Personal Data to third parties who are not Processors in terms of Art. 28 of the GDPR. The categories of such Non-Processors are:
2.7 Processing your Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
2.8 Consequences if we may not collect your Personal Data
We need your Personal Data to provide our Services to you and/or perform our contractual obligations towards you. Without providing such Personal Data, we may not be able to provide you the services you are intending to receive.
2.9 Consent and withdrawal
Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of Processing based on consent before its withdrawal. After your withdrawal we will stop to Process your Personal Data, including storage. This paragraph is only relevant for Processing that is entirely voluntary – it does not apply for Processing that is necessary or obligatory in any way.
To withdraw your consent, please send us an e-mail to [email protected] or a letter to Algorand Foundation Ltd, 1 George Street, #10-01, One George Street, Singapore (049145).
2.11 Marketing Activities
In case you consented to receiving information / newsletters from us, we may transfer your Personal Data to our business partners in order for us or our business partners to inform you via e-mail about upcoming opportunities and promote our respective products and services.
2.12 Links to Business Partner and Co-Branded Sites
Certain links contained on Algorand Foundation web sites may direct you to co-branded web sites maintained by Algorand Foundation or to companies which Algorand Foundation has established business relationships. When you submit information to one of these co-branded sites or partner companies, you may be submitting it to both Algorand Foundation and these business partners. Under no circumstances may Algorand Foundation be held responsible for the privacy practices of these business partners and we therefore strongly encourage you to read their respective privacy policies as they may differ from ours.
2.13 When we erase your Personal Data
We erase your Personal Data automatically when they are no longer required for the purposes listed above. We also erase your Personal Data according to your request and if further storage is neither required nor permitted by applicable laws.
2.14 Your rights related to data privacy
You have the right to request access to and rectification or erasure of your Personal Data, or restriction of their Processing. Furthermore, you have the right to object Processing as well as to request data portability. If you are in the EU you have the right to file a complaint to the responsible European Data Protection Authority.
2.15 Our contact information, Data Controller
If you have a direct business relationship with us, we are Data Controller according to Art. 4 para. 7 GDPR. For any requests you can contact us as follows:
1 George Street, #10-01, One George Street, Singapore (049145)
Our data privacy officer is John Bridgewater and you can contact us as follows: [email protected]
LAST UPDATED: May 21, 2019
We collect any information you provide to us when you use the Service. You may provide us with information in various ways on the Service.
Registration : If you register with us or one of our customers as an Investor, you are required to provide us with your name and email address and to designate a password. In order to participate in certain token sales as an Investor, we also require certain information to confirm your status as an accredited investor. For example, Investors hoping to participate in a token sale in an individual capacity, and not on behalf of a corporation or trust, must provide their full name, social security number, phone number, address, date of birth, and proof of required assets (such as an asset appraisal) or income (such as tax filings or pay stubs). More information regarding investor accreditation is available here. We may also require Investors to complete a short questionnaire regarding their interest in specific types of token sales.
Token Developers will provide us with information about their project and token offering, certain of which will be provided to potential Investors to assist in making an investment decision.
Financial Information : Investors may invest in token sales using traditional currency and/or cryptocurrency. To facilitate these transactions we will collect necessary financial information, such as your bank's routing number and your account number.
Communications : If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team, we will receive your email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.
When you use our Service, we may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Service, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service.
We may use the information we collect:
We may disclose information that we collect through the Service to third parties in the following circumstances:
In addition, we may use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but theses analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. For example, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at https://www.google.com/policies/privacy/partners.
We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose, unless we are prohibited from doing so under applicable law.
We use certain physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. In addition, we offer our users two-factor authentication which is designed to protect their account.
You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. From time to time, we send marketing e-mail messages to our users. If you no longer want to receive such emails from us on a going forward basis, you may opt-out via the "unsubscribe" link provided in each such email.
The Service are not directed to individuals under the age of eighteen (18), and we request that they not provide personal information through the Service.
CoinList uses servers hosted in the United States. Please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. By using the Service you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
We may make changes to this Policy. The "Last Updated" date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you through the Service or by sending you an email or other communication. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices. Your use of the Service following these changes means that you accept the revised Policy.
Companies choose how they share your personal information. Under federal law, that means personally identifiable information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read the U.S. Consumer Privacy Notice, available here, carefully to understand what we do.
If you have any questions about this Policy, please contact us at [email protected].