Last Updated: 24th May 2018
This Policy sets out what Personal Data we collect, how we process it and how long we retain it. This Policy is applies to all of our processing activities where we act as a data controller.
In this policy, “we”, “us” and “our” refers to Cedex Limited a company incorporated in Gibraltar with its registered address at 23 Portland House, Glacis Road, Gibraltar and incorporation number 116565. For more information about us, see the Contact Us section of this policy.
In this Policy , “personal data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
If you are viewing this policy online, you can click on the below links to jump to the relevant section:
We collect information about you when you:
The personal information we collect might include your:
Name; address; email address; telephone number; date of birth; nationality; IP address; the type of device through which you browse our website or use our services or app ( including the operating system; your location; time date and duration of your visit to our website; and previous visits to our website).
We may also ask you to provide evidence of your identity such as asking for a copy of your passport, driving licence, proof of residence or income. We are required to ask for this information to comply with anti-money laundering (AML) legislation such as the Proceeds of Crime Act 2015, to ensure we safeguard against and report any suspicious activity.
Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
Accordingly, by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), the right to rectification of your data or your rights to object or restrict processing, of your personal data. Data on the blockchain cannot generally be erased or changed, although some smart contracts may be able to revoke certain access rights, and some content may be made invisible to others, however it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens you have purchased) it may be necessary to write certain personal data, such as your Ethereum/ bitcoin or other cryptocurrency wallet address, onto the blockchain; this is done through a smart contract and requires you to execute such transactions using your wallet’s private key.
In most cases ultimate decisions to (i) transact on the blockchain using your Ethereum/Bitcoin or other cryptocurrency wallet address, as well as (ii) share the public key relating to your Ethereum/Bitcoin or other cryptocurrency wallet address with anyone (including us) rests with you.
IF YOU WANT TO ENSURE YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US.
IN PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE.
When you enter into a contract with us for the purchase of cryptographic tokens the following information is written onto the Ethereum blockchain:
We use personal information about you in connection with the following purposes:
If you do not want your personal information to be used for marketing purposes, please contact us on the above details.
We do not use automated-decision making methods (including profiling), save that we may risk profile our clients in compliance with applicable anti-money laundering legislation. This means decisions are not made by robots or computers, and therefore not ‘automated’. However, certain third parties may use certain automated decision-making tools or software. We are not responsible for the privacy practices of others and will take reasonable steps to bring such automated decision-making to your attention, but you are encouraged to become familiar with the privacy practices of any third parties you enter into any agreements with.
In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services. These are:
Pixels tags- Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails, and this information helps us and our partners provide you with a more tailored experience.
Device Identifiers- A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.
We use the following third party services
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
You may prevent Google Analytics from using cookies when you visit our website at any time by means of a corresponding adjustment to the settings of your web browser.
You also have the option of objecting to the collection of personal data by Google Analytics from our website by downloading and installing a browser add-on which can be found under the link https://tools.google.com/dlpage/gaoptout
Google Analytics, it purpose and function is further explained under the following Link https://www.google.com/analytics/
We use Facebook pixels to analyse and optimize the use of our website and our marketing. Facebook gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website, and for marketing purposes.
Facebook’s Data policy is available at: https://www.facebook.com/about/privacy/update. The relevant cookies are: “Facebook Pixel Code”
You may prevent Facebook from using cookies when you visit our website at any time by means of a corresponding adjustment to the settings of your Facebook account.
Further information and the applicable data protection provisions of Facebook please visit https://www.facebook.com/business/gdpr and https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr.
Facebook Pixel, it purpose and function is further explained under the following Link https://www.facebook.com/business/learn/facebook-ads-pixel
Social Media Links
We link to our social media profiles. Those services might also collect Personal Data. Please refer to their privacy policies for more information.
When you visit our site, you are able to opt-out of the use of all cookies which are not strictly necessary. If you Opt-out you may continue to browse our website but certain functionality may not be available due to technological constraints as some features of our website relies on cookies to operate correctly.
Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. Typically, personal data which is collected pursuant to our legal obligations (such as AML) are retained for 5 years. Where personal data is collected pursuant to a contract or prior to the creation of a contract, these are retained for 6 years after the termination of the contract pursuant to our legitimate interests in defending any legal claims which may be brought against us.
However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.
All personal data is retained in accordance with our internal Retention and Deletion Policy.
We may pass your information to our Business Partners, administration centres, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing our services to you.
In order to comply with our legal obligations in respect of AML, we use a third-party service provider to collect and process some of your personal data. This third-party service provider is located within the EEA and is bound by strict legal and contractual obligations to protect your personal data.
In addition, when we use any other third party service providers, we will disclose only the personal information that is necessary to deliver the service required and we will ensure, that they keep your information secure and not to use it for their own direct marketing purposes.
In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
We may share your personal data with third party companies (including companies which are related to Cedex) where we have a legal basis for doing so such as to provide you with our services or because we ourselves use service providers outside the of EEA in order to operate our business. These companies are located outside of the European Economic Area (EEA) the EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.
If we transfer your information outside of the EEA to third parties we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).
However, when interacting with the blockchain, as explained above in this Policy, the blockchain is a global decentralized public network and accordingly any personal data written onto the blockchain may be transferred and stored across the globe.
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.
You have the general right to request the erasure of your personal information in the following circumstances:
However, when interacting with the blockchain we may not be able to ensure that your personal data is deleted. This is because the blockchain is a public decentralized network and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances we will only be able to ensure that all personal data that is held by us is permanently deleted.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
You have a right to restrict processing of your personal information, such as where:
You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the services we can provide and we will explain this to you if you decide to exercise this right.
However, when interacting with the blockchain, as it is a public decentralized network, we will likely not be able to prevent external parties from processing any personal data which has been written onto the blockchain. In these circumstances we will use our reasonable endeavours to ensure that all processing of personal data held by us is restricted, notwithstanding this, your right to restrict to processing may not be able to be fully enforced.
Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
You have a choice about whether or not you wish to receive information from us.
We will not contact you for marketing purposes unless:
You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.
You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details.
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Data Protection Commissioner under the Data Protection Act, which is presently the Gibraltar Regulatory Authority (GRA). You may contact the GRA on the below details:
Gibraltar Data Protection Commissioner
Gibraltar Regulatory Authority
2nd Floor, Eurotowers 4
1 Europort Road
Phone: (+350) 200 74636
Fax: (+350) 200 72166
You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may make changes to this Policy from time to time. Where we do so, we will notify those who have a business relationship with us or who are subscribed to our emailing lists directly of the changes, and change the ‘Last updated’ date above. We encourage you to review the Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Policy, you should discontinue your use of this website.
Any questions regarding our Policy or your rights as a Data Subject should be sent to:
Cedex Holdings Limited
Suite 23 Portland House, Glacis Road, Gibraltar, GX11 1AA
Questions can also be sent by email to: firstname.lastname@example.org