PRIVACY POLICY

 

In compliance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter RGPD) we inform you that the personal data provided will be processed by ICOFUNDING, Ltd. (hereinafter ICOFUNDING, VAT: B87890588, address: Plaza de Santa Bárbara 2, 28006 – Madrid – Spain. Should you have any questions about this Privacy Policy you can contact us at at rgpd@icofunding.com or by writing directly to our Data Protection Officer at dpo@icofunding.com

 

Information We Collect & How We Use It

ICOFUNDING doesn’t make money from ads. So we don’t collect data in order to advertise to you. The tracking we do at ICOFUNDING is to make our product work as well as possible. So, to give you the best possible experience in using Medium, we collect information from your interactions with our Services. Some of this information, you actively tell us (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on actions you take while using ICOFUNDING. This information includes records of your interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information (how you got to a particular page).

We use this information to:

  • provide, test, improve, promote and personalize the Services
  • fight spam and other forms of abuse
  • generate aggregate, non-identifying information about how people use the Services

When you create your ICOFUNDING account, and authenticate with a third-party service (like Twitter, Facebook, Apple or Google) we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. We will never publish something through one of your third-party accounts without your express permission.

Information Disclosure

Icofunding won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you to a third-party.

We may transfer your account information with third parties in some circumstances, including: (1) to ICOFUNDING’s Clients (STO launchers) in order to make them comply with several regulations, like Anti-Money Laundering, financial regulation, etc. (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.

If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our services that we believe are improper.

ICOFUNDING will collect the following information provided by the User by completing the contact forms on the Website:

CONTACT form:

For any matter connected with the processing of data of natural persons by ICOFUNDING you may contact the email address rgpd@company.com, or else you may also get in touch with our Data Protection Delegate by way of the following email address dpo@company.com.

ICOFUNDING will collect the following information provided by the data subject:

COMMERCIAL CONTACT

  • Data collected: name, phone, email and comments.
  • Purpose: to deal with requests for information asked by any means about products and services offered by ICOFUNDING, and for the establishment or maintenance of business relationships.
  • Lawful basis: based on the consent given by the data subject, ICOFUNDING is entitled to process the data provided through the contact request, and in accordance with the legitimate interest in the development and maintenance of business relationships.
  • Storage limitation: data will be kept until the moment the data subject requests their cancellation or erasure and once deleted they will be kept available to the public administration, judges and courts for the time-barring of the actions that may apply to the processing of your data.

CURRICULUM OR RECRUITMENT:

to send Curriculum to ICOFUNDING by any means

  • Data collected: professional expertise area, name, surname, telephone, e-mail, CV, cover letter and other personal data related to the Curriculum or professional profile.
  • Purpose: management of the application for the recruitment processes published or for other vacancies according to your professional profile that may arise in the future within the activities of ICOFUNDING.
  • Storage limitation: data will be kept until you are awarded a job or until you request their erasure. They will therefore be kept for the time necessary for the purpose of the processing, and once concluded they may be kept for the time-barring of the actions that may apply to the processing of your data.
  • Lawful basis: consent granted by the candidate. Recipients: data provided and derived from the selection process may be disclosed to:

Third companies identified by the data subject and that may be necessary for the candidates request for references.

PROMOTIONAL OR NEWSLETTER form:

The submission of information, news, notices, reminders and promotions that may be of your interest, related to the activities of ICOFUNDING and its clients.

  • Data collected: email address, first name and surname.
  • Purpose: the registration of those who are interested in the submission of information, news and promotions, and to establish or maintain business relationships.
  • Lawful basis: the provision of data subject’s consent to ICOFUNDING to be registered in promotional services, and the legitimate interest in the development of business relationships.
  • Storage limitation: data will be kept until the moment the data subject requests their cancellation or erasure and once deleted they will be kept available to the public administration, judges and courts for the time-barring of the actions that may apply to the processing of your data.

CLIENT REGISTRATION form:

Made available to register ICOFUNDING CLIENTS.

  • Data collected: name, surname, telephone, address, ID card or document, email personal characteristics, financial information and Ethereum addresses.
  • Purpose: to register those users who are going to launch an STO.
  • Legitimate Base: consent provided by the user.
  • Storage limitation these personal data will only be kept for as long as it is necessary for the purposes for which it is processed, and then data might be kept blocked and maintained during six years at the disposal of Public Administration and Justice Administration in order to determine any liability arising from the processing.

SERVICES PROVIDERS

Individuals and legal persons we process data proceeding from our partners to properly manage the relationship between companies.

  • Data collected: name, surname, telephone, address, ID card or document, email, employment details, financial information.
  • Purpose: management of business relationships with legal persons who are providing with products or services.
  • Legitimate Base: consent given by the suppliers.
  • Storage limitation these personal data will only be kept for as long as it is necessary for the purposes for which it is processed, and then data might be kept blocked and maintained during six years at the disposal of Public Administration and Justice Administration in order to determine any liability arising from the processing.

BUYERS Form:

It enables to register data from Users that want to gain Access to the Ethereum addresses that enable them to make an investment on the projects selected by ICOFUNDING.

  • Data collected: name, surname, email and password.
  • Purpose: management of Users who are willing to invest on the projects recommended by ICOFUNDING.
  • Legitimate Base: consent provided by the user.
  • Storage limitation: these personal data will only be kept for as long as it is necessary for the purposes for which it is processed, and then data might be kept blocked and maintained during six years at the disposal of Public Administration and Justice Administration in order to determine any liability arising from the processing.

IDENTIFICATION PROCESS form:

Made available to run ICOGUNDING CLIENTS KYC & identity verification services for investors and meet AML regulations.

  • Data collected: name, surname, telephone, address, ID card or document, email personal characteristics, academic, professional and financial information, facial image.
  • Purpose: go through ICOFUNDING CLIENTS KYC & identity verification services for investors and meet comply with AML and KYC regulation.
  • Legitimate Base: consent provided by the user.
  • Storage limitation: these personal data shall only be kept for as long as it is necessary for the purposes for which it is processed, and then data might be kept blocked and maintained during ten years at the disposal of Public Administration and Justice Administration in order to determine any liability arising from the processing.

CORPORATE SOCIAL NETWORKS registration and monitoring:

Management of personal data supplied at the time to become a follower. ICOFUNDING corporate social networks accounts are the following:

The disclosure of data to third parties is envisaged for the provision of third-party services by data processors with which ICOFUNDING has signed the corresponding data processing contract and has verified that they are providing sufficient guarantees to implement proper technical and organizational measures which are meeting the requirements of the GDPR, guaranteeing the protection of data subjects rights.

The User has recognized his/her rights of access, rectification or erasure, restriction, objection and portability. Likewise, the User shall have the right to withdraw his or her consent for the processing by ICOFUNDING at any time. Also, you have the right to lodge a complaint with a supervisory authority.

The User may exercise his or her rights at any time by sending a communication, attaching a document that proves his/her identity and expressly indicating the right he/she wishes to exercise to ICOFUNDING headquarters before mentioned or by sending an email to info@icofunding.com.

ICOFUNDING has adopted the necessary technical and organisational measures to guarantee the safety and integrity of the data, and to avoid its modification, loss, processing or any unauthorised access to the same. The User expressly accepts the content of the legal notice that regulates the provision of services.

Data collected from the forms on this Website are those strictly necessary to meet your request, which you voluntarily communicate us. The refusal to provide data marked as mandatory shall impede the provision of the services requested. Likewise, data may be provided voluntarily with the aim of providing the services offered in the best possible way.

The USER agrees that in case of third party’s data disclosure, he/she undertakes to inform the data subject about the terms indicated in the preceding paragraphs.

The user undertakes to notify as soon as possible any modification and rectification of his/her personal data for ICOFUNDING to keep its processing activities records updated at all times.

By virtue of ICOFUNDING’s legitimate interest, your data may be used to send you commercial correspondence, including via electronic means related to the services promoted by ICOFUNDING. You may object to the processing of your personal data for such commercial communications purpose by sending an email to info@icofunding.com

Last update JANUARY 22nd, 2020.