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Privacy policyPrivacy

Attestant’s privacy policy

ATTESTANT PRIVACY POLICY

This privacy policy will inform you as to how we look after your personal data when you visit our website or use our platform (regardless of where you visit/use it from) or sign up to our mailing list and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. Important information and who we are

  2. Your information

  3. How we use your personal data

  4. Disclosures of your personal data

  5. International transfers

  6. Data security

  7. Data retention

  8. Your legal rights

  9. Glossary


1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Attestant collects and processes your personal data through your use of this website or our platform, including any data you may provide through this website or our platform when you sign up to our mailings or to use our service.

This website is not intended for children and we do not knowingly collect data relating to children or minors under 18.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Attestant is the controller and responsible for your personal data (collectively referred to as “Attestant”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Attestant Limited

Email address: compliance@attestant.io

Postal address: 7 Albert Buildings, 49 Queen Victoria Street, London, EC4N 4SA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on November 2020. Copies of historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. Your information

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect or obtain different kinds of personal data about you in different ways:

(a). Information you give us

(i). When you apply to subscribe to our services, you will provide us with information concerning yourself such as your full name, date of birth, username, marital status and title. We call this Identity Data. You can view a full description of Identity Data in the Glossary at paragraph 9 below. Some of this Identity Data, such as the KYC/AML information is sent to us on your behalf by a third party (see under paragraph 2(b) below;

(ii)). When you open an account on our platform you will also provide us with your billing address, email address and telephone number. We call this Contact Data;

(iii). When you communicate with us, in person, by email, phone, through our website or by any other means through which you choose to communicate with us, we will process the information contained in that communication. We call this Communications Data;

(iv). When you inform us of your marketing preferences or how you would like to receive information from us, we call this we call this Marketing Data.

(b). Information we receive from other sources

(i). When you open an account on our platform, we will receive certain KYC/AML data from a third party which you have authorised. This includes ID verification information, photo ID (selfie) and other background information. This is included in the category Identity Data. We may also check online databases such as Companies House and the Electoral Register;

(ii). When we process a transaction through our platform to which you are a party, we will see your Validator Data (see Glossary);

(iii). When we check whether payments have been made/received in connection with the services provided through the platform, we may see information relating to your bank account and payment card details. We call this Financial Data;

(iv). When we review your use of the services for invoicing purposes, we will see details of how much you have used the services and other details of services you have purchased. We call this Transaction Data. In this connection we will also use your Validator Data;

(v). When we carry out mailing services, we may receive your email address (Contact Data) for this purpose;

(vi). As you interact with our website, we will automatically collect Technical Data using cookies and other similar technologies (see our cookie policy for more information) (see the Glossary below) for more detail about the types of information collected) about your equipment, browsing actions and patterns.

In carrying out KYC and AML checks and a periodic review of that information we may collect Special Categories of Personal Data about you in so far as this identifies you as a politically exposed person. In this connection we may also collect information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services via our platform). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time and may terminate the user agreement we have with you in accordance with its terms.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Where you consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message or to receive emails providing details of your validator’s performance. You have the right to withdraw consent to marketing at any time by contacting us.

You may also need to provide consent for our service providers to carry out certain KYC and AML checks on you and transfer this information to us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To subscribe to our services
  1. Identity
  2. Contact
Performance of a contract with you
To create an account on our platform
  1. Identity (in particular KYC/AML information)
  2. Contact
  1. Performance of a contract with you
  2. Necessary for our legitimate interests and those of third parties (to reduce the risk of fraud, money laundering and other criminal activities)
  3. Consent
To process your transactions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Associated administration and record keeping
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Communications
  6. Marketing
  7. Validator Data
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Notifying you about changes to our services
(c) Meeting with you (remotely or in person) to discuss your requirements and gain background information
  1. Identity
  2. Contact
  3. Marketing
  4. Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to carry out customer due diligence and learn about customer requirements to develop our marketing strategy and grow our business)
To administer and protect our business and our platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To use data analytics to improve our platform, services, marketing, customer relationships and experiences
  1. Technical
  2. Transaction
Necessary for our legitimate interests (to define types of customers for our services, to keep our platform updated and relevant, to develop our business and to inform our marketing strategy)
To send you information about us and our services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Communications
  5. Marketing
Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you opt-in to receiving marketing communications from us, we will send communications concerning us and our services to your nominated email address.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for carrying out transactions through our platform.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Service providers acting as processors:

    • those who provide hosting, IT and system administration services, based in the UK, EU, US, Australia and Canada
    • those who provide mailing services, based in the US
    • those who provide software applications that we use in connection with our services, such as accounting system, marketing database, internal document storage, based in the EU, New Zealand, US and Australia.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom in certain circumstances.

  • Identity verification service providers, credit reference, fraud prevention and financial crime agencies or otherwise as required by law or in connection with an investigation.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Many of the third parties described above are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. This is applicable for those service providers who may process your data in New Zealand and Canada.
  • Where we use certain service providers, based in the US or Australia we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard contractual clauses for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

You can request a complete list of our processors by contacting us at any time.

6. 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.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes and AML purposes.

In some circumstances you can ask us to delete your data: see “8. Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Your legal rights section in the Glossary to find out more about the following:

  • Request access to your personal data
  • Request correction
  • Request erasure
  • Object to processing
  • Request restriction of processing
  • Request the transfer
  • Withdraw consent at any time

If you wish to exercise any of the rights above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

DATA

Identity Data includes first name, maiden name, last name, username or similar identifier (including email address), marital status, title, employer, date of birth and gender and KYC/AML information and documentation, photo ID (selfie) and other background information which you may provide to us.

Communications Data includes the information contained in communications with you.

Contact Data includes billing address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you, how much you have used the services offered via the platform (for invoicing purposes) and other details of services you have purchased.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Marketing Data includes your preferences in receiving marketing from us and your communication preferences.

Validator Data means the validator ID generated by the Ethereum blockchain in connection with your use of the services offered through our platform.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at info@attestant.io

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