Privacy Policy

Last updated: August 6, 2018

BlockFame is committed to protecting the privacy of its users and we therefore ask that you please read our Privacy Policy (“Policy”) before providing us with any information about you or any other person.

This Policy sets out what personal data we collect, how we process it and how long we retain it. This Policy applies to all of our processing activities where we act as a data controller.

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.

In this Policy, “processing” means any operation or set of operations which is performed on personal data (as defined in this Policy) or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

HOW WE COLLECT INFORMATION FROM YOU

We collect information about you when you:

  • visit our website;
  • contact us either through our website or through other direct means of electronic communication;
  • enter into a contract with us;
  • use our services or offerings; and/or
  • enter into any other relationship with us or interact with us for our services.

WHAT TYPE OF INFORMATION IS COLLECTED?

The personal information we collect might include, but is not limited to, 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) and in some instances your cryptographic wallet address.

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.


YOUR INFORMATION AND THE BLOCKCHAIN

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 provide you services through our app, it may be necessary to write certain personal data, such as your cryptographic signatures 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 or other cryptocurrency wallet address, as well as (ii) share the public key relating to your Ethereum or other cryptocurrency wallet address with anyone (including us) rests with you.

Information written on the blockchain

When you use the BlockFame, the following information may be written onto the Ethereum blockchain:

  • the cryptographic wallet address from which you submitted the transaction;
  • the amount of the cryptocurrency which you send as payment;
  • the cryptographic wallet address to which you initiated the transaction;
  • the cryptographic signature of a piece of your identity data such as phone number or date of birth; and/or
  • the cryptographic wallet address of the entity with which you engaged in an identity attestation.

HOW WE USE YOUR PERSONAL INFORMATION

We use personal information about you in connection with the following purposes:

Provision of services and management:
  • to provide you with the information, products and services that you have requested from us;
  • to complete any transaction you are undertaking with us;
  • to perform a contractual obligation we have to you; and/or
  • to meet a legal or regulatory obligation.
Service improvements:
  • to ensure that content from our site is presented in the most effective manner for you;
  • to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to notify you about changes to our service; and/or
  • as part of our efforts to keep our site safe and secure.
Direct Marketing:
  • to provide you with information about other services we offer that are similar to those that you already have or have enquired about; and/or
  • to provide you with other marketing material such as our Newsletter.

If you do not want your personal information to be used for marketing purposes, please contact us on the details below. Alternatively when you receive marketing materials from us you will be able to directly unsubscribe from them.

Automated decision-making

We use automated decision making as part of our services. Automated decision making is used when you elect to use our services in order to verify your identity, documentation, telephone number etc. We use automated decision making for this purpose as it allows us to offer an efficient service.

Certain third parties may also 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.

HOW LONG WE KEEP YOUR INFORMATION FOR

We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this Policy. Records can be held on a variety of media (physical or electronic) and formats.

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.

SHARING YOUR PERSONAL INFORMATION

We may pass your information to our Business Partners, 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 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, via contractual obligations that these requires them to 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.

Transferring your information outside of the European Economic Area

Sometimes our business partners, third party service providers, agents, subcontractors and other associated organisations may be 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’.

We may share your personal data with these third parties outside of the EEA 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. 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).

YOUR INDIVIDUAL RIGHTS

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.

Right Information and access

You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source) and this Policy intends to provide the information. Of course, if you have any further questions you can contact us on the details below.

Right to rectification

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.

The accuracy of your information is important to us. If you do not want us to use your personal information in the manner set out in this Policy, or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your personal information, please contact us at the details below.

Right to erasure (right to be ‘forgotten’)

You have the general right to request the erasure of your personal information in the following circumstances:

  • the personal information is no longer necessary for the purpose for which it was collected;
  • you withdraw your consent to consent based processing and no other legal justification for processing applies;
  • you object to processing for direct marketing purposes;
  • we unlawfully processed your personal information; and
  • erasure is required to comply with a legal obligation that applies to us.

We will proceed to comply with an erasure request without delay unless continued retention is necessary for:

  • exercising the right of freedom of expression and information;
  • complying with a legal obligation under EU or other applicable law;
  • the performance of a task carried out in the public interest;
  • archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
  • the establishment, exercise, or defence of legal claims.

Right to restrict processing and right to object to processing

You have a right to restrict processing of your personal information, such as where:

  • you contest the accuracy of the personal information;
  • where processing is unlawful you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed personal information; and/or
  • we no longer need to process your personal information but need to retain your information for the establishment, exercise, or defence of legal claims.

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.

Right to data portability

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.

Right to freedom from automated decision-making

Where 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.

Right to object to direct marketing (‘opting out’)

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 have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above); and/or
  • you have otherwise given your prior consent (such as when you download one of our guides)

You can change your marketing preferences at any time by contacting us on the below 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.

Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.


Right to request access

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 details below.

Right to withdraw consent

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 below details.

Raising a complaint about how we have handled your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out below and we will then investigate the matter.

Right to lodge a complaint with a relevant supervisory authority

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 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 your rights has taken place, if that is based in the EEA.

ADDITIONAL INFORMATION

Data Security

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.

Hyperlinks

We may provide hyperlinks from this website to websites of other organisations or associated companies. Please note that we will not be liable for the contents of linked websites or any transactions carried out with organisations operating those websites. The privacy policies of others may differ significantly from our Policy. Therefore, we encourage you to read the privacy statement/policy of each and every website that collects personal data.

Review of this Policy

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.

Terms of Service

Last updated: August 6, 2018

1. Terms

By accessing the website, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on BlockFame's website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

  1. modify or copy the materials;
  2. use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
  3. attempt to decompile or reverse engineer any software contained on BlockFame's website;
  4. remove any copyright or other proprietary notations from the materials; or
  5. transfer the materials to another person or "mirror" the materials on any other server.

This license shall automatically terminate if you violate any of these restrictions and may be terminated by BlockFame at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

  1. The materials on BlockFame's website are provided on an 'as is' basis. BlockFame makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.
  2. Further, BlockFame does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall BlockFame or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on BlockFame's website, even if BlockFame or a BlockFame authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Accuracy of Materials

The materials appearing on BlockFame website could include technical, typographical, or photographic errors. BlockFame does not warrant that any of the materials on its website are accurate, complete or current. BlockFame may make changes to the materials contained on its website at any time without notice. However BlockFame does not make any commitment to update the materials.

6. Links

BlockFame has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by BlockFame of the site. Use of any such linked website is at the user's own risk.

7. Modifications

BlockFame may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service.

8. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of Gibraltar and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.

Cookie Policy

Last updated: August 6, 2018

We, together with variety of the third party services listed below use, deploy the use of cookies and other similar technologies.

Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. They allow the website to remember your actions and preferences over a period of time, so you don't have to keep re-entering them whenever you visit one of our websites or browse from one page to another. They also enable us to track and monitor activity on our website to improve our services (for marketing and functionality purposes) as well as allowing you to interact with social media services.

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 that can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and advertisements delivered.

A cookie can be classified by its lifespan and the domain to which it belongs; a cookie is either a:

  • session cookie - which is erased when the user closes the browser; or
  • persistent cookie - which is saved to the hard drive and remains on the user's computer/device for a pre-defined period of time.

As for the domain to which it belongs, cookies are either:

  • first-party cookies - which are set by the web server of the visited page and share the same domain (i.e. set by us); or
  • third-party cookies - stored by a different domain to the visited page's domain.


WHAT COOKIES DO WE USE AND WHY?

Cookies are also sometimes classified by reference to their purpose. We use the following cookies for the following purposes:

  • Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow us to comply with legal obligations.
  • Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it, as well as dates and times they visit. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences for example, your choice of language or region.
  • Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed, as well as time spent on our website, and the websites visited just before and just after our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

In general, we use cookies and other technologies (such as web server logs) on our website to enhance your experience and to collect information about how our website is used. We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. The information also helps us to understand which parts of this website are most popular and generally to assess user behaviour and characteristics to measure interest in and use of the various areas of our website. This then allows us to improve our website and the way we market our business. This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website's capacity and efficiency.

We may also use the information collected from cookies and other technologies to service our ads on social media platform and for other marketing purposes.