Privacy policy
At TRAZABLE we know that you care about your personal data and you want to know how we will treat it. That is why we are going to explain below, in a clear and transparent way, in our Privacy Policy, how and when we obtain, share and protect your personal data. We will also explain how to exercise your rights in relation to it.
Please note that anonymised information or purely statistical data used by TRAZABLE will not be considered personal data.
WHO ARE WE?
BLOCKCHAIN TRACEABILITY, S.L. with C.I.F. B-40547507 and address at Avd/Amado Granell Mesado 65, 46013 Valencia, by virtue of the deed granted on 14 December 2018, before the Notary of Valencia, D. Alfonso Pascual De Miguel in the Mercantile Register of Valencia in Volume 9589, Folio 188, Page V-152580. Inscription 1ª (hereinafter “TRAZABLE”).
By reading and accepting this Privacy Policy, the user (the “User” or “Users”) is informed of the circumstances under which their personal data will be processed.
In addition, if it is the necessary legal basis for the processing of your data, your free, informed, specific and unequivocal consent will be requested so that the personal data you provide through the website https://trazable.io (hereinafter, the “Website”) and the application (hereinafter, the “Application”) or any forms dependent on the Website and the Application, are processed by TRAZABLE, as well as the data derived from your browsing and any other data that you may provide in the future.
The data requested in the forms of the Website and the Application are, in general, mandatory (unless otherwise specified in the required field) to fulfill the purposes for which they are being collected.
Therefore, if they are not provided or are not provided correctly, they cannot be fulfilled, without prejudice to the fact that you may freely view the content of the Website and the Application, except for specific content or certain functionalities of the Website and the Application, limited to registered Users.
Please read this Privacy Policy carefully before using TRAZABLE.
What personal data does TRAZABLE access about me?
If you register on the Website to purchase TRAZABLE tokens, we will process the following information about you:
- Identification data: full name, full identity document, date of birth (age), gender and image.
- Contact and communication data: telephone number, email address and postal address, country of residence.
IP address - Bank details: such as bank name, account name, account holder(s), currency, IBAN.
- Browsing data: the Website and Application servers may automatically detect your IP address, domain name, unique device identifier, browser fingerprint, device fingerprint and cookie IDs where you have set this in your browser.
- Data we collect from third parties: we may collect data from third parties such as personal data or information on international anti-money laundering and terrorist financing lists.
If you do not register, but simply browse the Website, we will process the following information about you:
- Contact and communication data: email address
- Browsing data: the Website and Application servers may automatically detect your IP address, domain name, unique device identifier, browser fingerprint, device fingerprint and cookie IDs where you have set this in your browser.
Where does the data we process about you come from?
- From the User: This is the data that you provide to us by filling in forms on the Website and/or the Application, or through any interaction that you carry out with TRAZABLE.
- From the cookies inserted on the Website and/or the Application and from the use of similar technologies (see the corresponding section in this Privacy Policy and the Cookies Policy).
- From third parties: such as business partners with which TRAZABLE has signed a collaboration contract, third parties that provide a service to TRAZABLE for the effective provision of the service, or data obtained from international lists for the prevention of money laundering.
What are the purposes and legal bases for the processing of User data?
We may only process your personal data if we have an adequate legal basis for doing so. We may process your personal data for any or all of the purposes specified below and on the legal bases indicated:
| PURPOSES OF THE PROCESSING | LEGAL BASIS |
|---|---|
|
Registration and use of the Website to manage the registration, access and required use of the Website and the Application (contact details, bank details). Responding to questions raised by Users related to the platform or the public offering of tokens. Use of the products and services, interactions with the Website and the Application. Send you notifications related to the provision of the service or use of the Website and/or the Application. |
Formalize the contract between the parties and legitimate interest in providing users access to TRAZABLE services and the management of their products and services. |
| Dirección IP | TRAZABLE’s legitimate interest in diagnosing problems with the servers and efficiently administering the Website. |
| Marketing purposes, sending commercial communications about TRAZABLE products. Improvement of products and services and sending promotions. |
Legitimate interest in advertising and improving our products and services, unless the user expresses his/her wish not to receive commercial communications (in the case of registered Users). Consent of the User (in the case of non-registered Users). |
| Processing of your image to verify your identity and prevent fraud and money laundering. | Legal obligation to comply with applicable regulations. |
|
Legal obligation to comply with applicable regulations. |
User consent |
With which recipients will the User’s data be shared?
They can access the personal data of TRAZABLE Users:
- Authorized staff of TRAZABLE.
- Collaborators who provide services on behalf of TRAZABLE in order to manage the provision of services. In this case, such access to data on behalf of third parties will be regulated in the corresponding data processing contract in compliance with applicable regulations.
- Authorities: we may share certain strictly necessary information with authorities such as the police, tax agencies or other authorities, if required by law.
Is my data transferred outside the European Union?
There are no plans to transfer your personal data outside the European Union. However, should this circumstance change, you will be informed through this privacy policy and transfers to third countries not considered safe will be done by protecting your data through the signing of Standard Contractual Clauses approved by the European Commission between the data exporter and the data importer.
How long will TRAZABLE keep the data?
Your personal data will be kept for the time strictly necessary for the purposes of the processing for which they have been provided, and, in any case, following the principle of data minimization provided for in the applicable regulations.
If you are a TRAZABLE user, your data will be kept for the duration of your business relationship with TRAZABLE and from the moment you exercise your right to cancel your data or cancel your account, your data will be kept blocked for a period of five years in order to meet the legal responsibilities that may arise from the services provided and ten years in the case of conservation of personal data in compliance with the rules of prevention of money laundering.
How can I exercise my rights?
You can (i) send a letter to TRAZABLE, to the address indicated in the header of this Policy, (ii) access your User area in the Application or the Website; or (iii) send an email to the address [email protected], attaching a photocopy of your identity document, at any time and free of charge, to:
- Revoke the consents given.
- Obtain confirmation as to whether your personal data is being processed at TRAZABLE.
- Access your personal data.
- Rectify inaccurate or incomplete data.
- Request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
- Obtain from TRAZABLE the limitation of data processing when any of the conditions set out in the data protection regulations are met.
- Request the portability of the data provided in those cases provided for in the regulations. Contact the DPO of TRAZABLE at the following address: [email protected] If you consider that the above rights have not been properly addressed by TRAZABLE you can file a complaint with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 – Madrid.
Changes to the Privacy Policy
Our Privacy Policy may be updated due to changes and legal requirements, as well as due to improvements and changes included in the way we offer and provide our services and utilities of the application. Therefore, we recommend that you visit and access our Privacy Policy periodically, in order to have access to the latest changes that may have been incorporated.
In the event that such changes relate to the consent provided by the User, we will send you a separate and independent notification to collect it again.
If you have any questions or concerns about our Privacy Policy or wish to exercise any rights or actions relating to your personal data, please contact us at the following email address: [email protected].
Privacy and blockchain
Public blockchains operate like ledgers, intended to immutably record transactions in networks of computer systems. Many of these public blockchains allow forensic analysis that can lead to de-anonymisation and inadvertent disclosure of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks that are not controlled or operated by TRAZABLE, we cannot delete, modify or alter personal data on such networks.