Privacy Policy

Black Foundation OÜ (hereinafter Black) has created the following Privacy Policy to commute to you clearly and conclusively how Black processes (including collection, use, transferring, storage, deletion, etc.) your personal information. The Privacy Policy informs you of your rights as a data subject. The Privacy Policy is an integral part of the agreements between you and Black.

Black is the controller of your personal data. Black processes personal data in accordance with applicable law, including consistent with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Please read the Privacy Policy carefully prior to submitting the data, use of Black Platform services or concluding contracts with Black.

1.
What kind of personal data does Black collect?
2.
How does Black collect the personal data?
3.
What are the purposes of the processing?
4.
Where we store and process personal data?
5.
How long do we retain your personal data?
6.
To whom and why do we transfer your personal data?
7.
What are your rights as a data subject?

If you cannot find the answers you’re looking for in our Privacy Policy or have any other questions regarding your personal data, please do not hesitate to contact Black using the following contact information:

Name: Black Foundation OÜ
Address: Lõõtsa tn 8
11415 Tallinn
Estonia
E-mail: [email protected]/newsite/version-2

1.
What kind of personal data does Black collect?
  • Basic identification data: First and last name, identification code (or in the absence thereof, date and place of birth), citizenship;
  • Contact data: E-mail address, mobile number;
  • Transaction data: token amount and/or deposit amount, ether wallet address, date of any transfer and a description of the content of the transfer, including the amount, currency used and the account number used for the transfer.
2.
How does Black collect the personal data?

We collect your data when:

  • you request information about our products and services via our webpage https://www.black.insure/newsite/version-2/ (hereinafter Webpage);
  • you subscribe to our mailing lists;
  • you connect with us through social media services (Twitter, LinkedIN, Facebook);
  • you submit information in a public forum linked to Black (Telegram, Reddit, Bitcoin Forum);
  • you sign up for our social media notifications;
3.
What are the purposes of the processing?

Black is offering Black Platform Tokens (BLCK). In order to acquire BLCK, you have to conclude a contract with Black. Therefore, Black processes your personal data for the performance of the contract and in order to take steps prior to entering into a contract. Black will process your identification data, contact data and.

Furthermore, the processing might be necessary for compliance with legal obligations to which Black is subject. For example, Black is required to organise the accounting and financial reporting. Black has obligatory procedures for preventing money laundering and terrorist financing established by legislation, etc.

Black will also process your personal data if the processing is necessary for the purposes of the legitimate interests pursued by Black. In every such case Black will consider whether such interests might be overridden by the interests or fundamental rights and freedoms of the data subject. For example, Black has the legitimate interest to process your data to help with fraud identification and prevention.

Black can process your personal data if you have given consent to the processing of your personal data for one or more specific purposes. For example, Black can send you direct marketing offers if you have expressly given such consent. You have the right to withdraw your consent at any time. However, we remind you that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

4.
Where we store and process personal data?

The Black Platform is constructed using Hyperledger Fabric, a private, permissioned Blockchain Network. Data stored on the Black Platform is partitioned into private “Channels” to protect confidentiality, and control who has access to which data.

5.
How long do we retain your personal data?

Black has both the right and the obligation to retain the personal data collected for a period of time. Black does not retain personal information longer than necessary to achieve the purposes of processing and comply with the obligations of Black. However, Black may retain the personal data for a longer period of time if you have given consent for longer storage and processing of the data.

As a general rule Black will keep your personal information for 5 years after you have disposed of all Tokens.

The information contained in the accounting records will be retained for seven years in accordance with the law.

If Black sends personal information to another controller, the data retention periods will be determined by the recipient of the data.

6.
To whom and why we transfer your personal data?

Black discloses personal information only to the extent and in the form necessary for the fulfilment of the purposes listed in the Privacy Policy.

Black may transfer your personal data to other data controllers or processors. Black may share information with companies that provide support services to Black (e-mail, marketing). Black uses Veriff OÜ as a KYC service provider and BitGo Inc as a wallet service provider. These companies may need information about you in order to perform their functions. Data processors are not authorized to use the shared data for any other purpose.

Black is required to transfer personal data if Black is legally bound by such an obligation. For example, Black might be obligated to disclose personal data to public authorities upon their legitimate request.

7.
What are your rights as a data subject?

You always have the opportunity to opt out of receiving promotional communications any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information about your account.

You have the right to receive information about the personal data processed by Black, including the categories of data processed, the sources of the data, purposes of processing etc. You are also entitled to receive copies and extracts of personal data processed. You have the right to request the correction or updating of data if it turns out that the personal data being processed is inaccurate.

You have the right to obtain from Black the erasure of your personal data. Black will erase your data or implement other measures that result in the data becoming permanently anonymous if:

  • your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw the consent on which the processing is based and there is no other legal ground for the processing;
  • you object to the processing and there are no overriding legitimate grounds for the processing;
  • your personal data have been unlawfully processed;
  • your personal data have to be erased for compliance with a legal obligation to which Black is subject.

Black will fulfil your request within a reasonable time, but no later than one month after receiving the request.

Any revisions to this Privacy Policy will be posted on the Black Website. We recommend to periodically visit our Website to review any changes that may be made to this Privacy Policy. If you continue to use our Website and services, it constitutes your agreement to be bound by this Privacy Policy and any possible changes.

This Privacy Policy was last updated on 31.07.2018.

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