CHAINS ONLINE SERVICES LIMITED
Last revised Date 15th July 2021
We respect and value your privacy as well as the integrity of the information you have provided and/or permitted Us to collect. Thus, We endeavour to follow industry standards to ensure the security and confidentiality of your Personal Information when you use Our Services or access CHAINS Platform.
- Our Relationship with You
- Personal Information that We collect
- How We collect Personal Information
- How We use Personal Information
- How We protect Personal Information
- How long We retain Personal Information
- Sharing your Personal Information
- Third-Party Collection of Personal Information
- Designated Countries and Your Legal Rights
- Rights of the residents of the European Economic Area (EEA)
- Cross-Border Transfer of Personal Information
- How to contact CHAINS
2. Our Relationship with You
CHAINS has the relationship with individuals on its Services as described below:
“User” is an individual providing personal information to Us via Our CHAINS website, forms, social media accounts, or other means. For example, User can engage and complete additional CHAINS social media engagement tasks, entitling their account to be whitelisted for a CHAINS Service or interact with Us on Our social media accounts.
3. Personal Information that We collect
3.1 Information provided by you when connecting with CHAINS
3.1.1 When creating your CHAINS account, you will be asked to provide, and We will collect, information about your identity, location, employment, email address, location, education, as well as any other information provided by you via the Platform.
3.1.2 KYC (Know Your Customer) – in order to be able to use the CHAINS Platform in a manner that results in the transfer or reception of assets (such as cryptocurrency) you must provide Us with your full name, birthday date, nationality, home address, location, government identification number (Identification Card/Passport Number and Date of the Issuance of Identification Card/Passport), telegram username, wallet address, email address, IP address and other information which can be used to distinguish your identity, to access the CHAINS Platform and for the Know Your Customer (“KYC”) Verification purposes. Additionally, you may use single sign – on (also known as “OAuth”) by logging in to Our Services using MetaMask (if necessary). These services will authenticate your identity and provide you the option to share certain information with Us such as your username and email address.
Furthermore, you may be required to upload a picture of yourself, provide additional information when firstly connecting with CHAINS such as linking to your Facebook account, Telegram, LinkedIn, GitHub, Google, or Twitter other social media accounts, and more as per request by CHAINS.
3.2 Information collected by Us as you use Our services
3.2.1 Usage Information
When you engage or use Our Services, We may monitor your information in relation to your usage of CHAINS Services through your device such as your IP address, phone number, the type of device you use to access Our Platform, device information, which websites you visited before accessing Our Services or Platform, browser type, Information about your browser, Date and Time you visit Our Platform, Volume of data transmitted and network operator. This information will either be directly obtained by CHAINS or through third party service providers.
We collect this type of information to ensure that Our interface and/or Platform is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.
3.2.2 Communication Information
You hereby agree that We are entitled to collect and use or process the Personal Information you have provided on Our Platform or generated through your usage of CHAINS Services for the purpose of being able to communicate with you through messages, requests, emails, live chats, file attachments in connection with your transactions on CHAINS, or any other information related to your contact with CHAINS. If you contact Us, We will keep a record of the information shared during the correspondence.
3.2.3 Financial Information
Parts of CHAINS Services are public, including any information disclosed on Our social media accounts, thus you acknowledge that such parts of CHAINS Services may appear on search engines or other publicly available platforms, and may be “crawled”, searched and used by the third parties or other Users and Customers of the Services. Please do not post any information that you do not wish to reveal publicly.
4. How We collect Personal Information
4.1 Information automatically collected by Us
We will collect and process Personal Information automatically provided by you under the following situations.
4.1.1 when you visit and/or firstly connect with CHAINS website;
4.1.2 when you voluntarily complete any user survey or provide feedback to Us via
4.1.3 emails or any other electronic channels including on Our social media accounts;
4.1.4 when you use browser cookies or any other relevant software upon visiting the CHAINS website; and
4.2 Information collected by the third-party
We will collect your Personal Information from the third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but not limited to, public databases, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
4.3 Anonymized and Aggregated Data
5. How We use Personal Information
Your Personal Information will be made available on a need-to-know basis to CHAINS, Our affiliates, and/or within Our group of companies. This will include, but not be limited to, the employees and/or any persons or third parties working for CHAINS who are responsible for using and protecting your Personal Information.
We use and process your Personal Information for the following purposes or in the following ways:
5.1 To provide Our Services
We respect data protection principles, and process personal data only for specified, explicit, and legitimate purposes for which such personal data were provided. We primarily use your Personal information, either collected or delivered, in order to enable your use of CHAINS Services (including, but not limited to, processing transactions), to improve the efficiency of the Services, the process to participate in the CHAINS Services, and to verify your identity.
5.2 To protect users
We use the information collected to protect Our Platforms, Users’ information, and archives. We also use IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (“DDoS”) attacks, and other security risks.
5.3 To comply with regulations and compliance
For Our legitimate interests, We will use the information in compliance with Our legal obligations, global and local industry standards, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e. to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfil the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent. You hereby expressly authorise CHAINS to disclose any and all information relating to you in CHAINS’s possession to any law enforcement or government officials upon the only request by a valid court order.
5.4 For measurement, research and development purposes-
We actively measure and analyze your information to understand the way you use and interact with Our Services, and Our Platform, and to provide you with a unique and personalized experience. For example, We may allow you to use social media plugins on Our Services (e.g. Facebppl , Twitter, etc.), We keep track of your preferences such as display name, time zone, and so on. This review is continuously conducted by Our operation teams to continuously improve Our Platforms’ performance and to resolve issues with user experience.
In addition, We use such information to monitor trends, and improve Our Services, Our administration, the content and layout of CHAINS website, and to develop new Services for you.
5.5 For communication purposes
5.6 To enforce Our T&Cs, and other relevant agreements
Personal Information is also used to enforce Our T&Cs continuously and actively among, and other agreements relating to the Services on CHAINS Platform . Activities in this regard include, but are not limited to, reviewing, investigating, mitigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, CHAINS shall be entitled to freeze/close/restrict/delete/alter accounts or user activity on the CHAINS website as necessary to comply with regulations or enforce the Terms and Conditions and ensure the security and integrity of the Platform.
5.7 For marketing and advertising
We will share your Personal Information with Our marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising. We may send you marketing communications to alert you about new Services, yet you can opt-out of Our marketing activities at any time.
5.8 For other purposes
6. How We protect Personal Information
CHAINS takes great care to protect the CHAINS’s security as well as your Personal Information from loss, misuse, disclosure, alteration, and destruction. We take reasonable steps to maintain physical, technical, and employ procedural safeguard to ensure the confidentiality, integrity of your Personal Information. The safeguards include the use of firewalls, and data encryption, enforcing physical access controls to Our premise and files, and limiting access to Personal Information only to those employees, agents or third parties who need access to that information to process it for Us.
We also implement certain reasonable security measures to protect your Personal Information from unauthorized access, and such security measures are in compliance with the security practices and procedures as prescribed under the applicable laws.
However, you agree and acknowledge that it is impossible to fully guarantee the security of your Personal Information by implementing the above-mentioned safeguard and measures. It is not absolute protection to your Personal Information and by accessing the Services.
You agree that We will not hold any responsibility for the acts committed by those who gain unauthorized access or abuse your information and services. In addition, We will not hold any responsibility for any act committed by the third-party service providers who are contractually engaged with Us to maintain an appropriate security measure for protecting your Personal Information. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such your wallet address. You hereby agree that We will not be liable for any information leakage and other damage or loss not caused by Our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.
7. How long We retain Personal Information
You are aware that your Personal Information will continue to be stored and retained by Us while you have been using or accessing CHAINS Platform and the Services, and after your use of the Services for a reasonable period of time.
In addition, We may be required by applicable laws and regulatory requirements to retain certain information, including your Personal Information, your identification verification materials, information relevant to AML/KYC/CTF procedures, information related to staking instructions, account agreements, and other agreements between Us and third-parties, account statements, and other records after you stop accessing or participating in CHAINS.
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our Website will use the following types of cookies:
8.1 Strictly Necessary Cookies
These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. We will not need to obtain your consent in order to use these cookies.
8.2 Functionality Cookies
These cookies allow the website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.
8.3 Performance cookies
These cookies collect information about how you use a website, for example, which pages you go to most often, how much time you spend on a page, record difficulties you may experience while using the website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
8.4 Targeting Cookies or Advertising Cookies
These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to the sites’ functionality provided by the other organizations.
You may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of CHAINS Services may not operate properly or become inaccessible, and your online experience may be limited. For Further information please visit our Cookies Policy.
9. Sharing your Personal Information
We will not rent, sell, or disclose your Personal Information to any third parties, except to those who require access to the information to perform their tasks and duties under the binding agreements executed with Us and to share with third parties who have a legitimate purpose for accessing it.
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
- We may disclose Personal Information to the third parties in order to administer or process a transaction, or services you have authorized or requested, or in the context of facilitating the execution of a transaction, or We may disclose Personal Information to third parties that provide supporting services, or analytical information for the purpose of the Service improvement, only where we have a lawful basis to do so or under an agreement or legal requirements for the transfer of Personal Information.
- We will be required to verify your identities by applicable laws and regulatory requirements and rely on third-party services to perform these verifications. Personal Information that you provide to Us during the initial connecting process is passed to these services at KYC Verification process and on an ongoing basis thereafter.
- We may share your information with law enforcement, and government officials when We are compelled to do so by a subpoena, a valid court order to prevent financial loss, to report suspected illegal activity or to investigate violations of any of Our T&Cs or any other applicable policies.
10. Third-Party Collection of Personal Information
Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
Processing by Online Payment Processors
11. Designated Countries Privacy Right and Your Legal Rights
This provision applies to Users of the Services that are located in the European Economic Area, United Kingdom and/or Switzerland (herein collectively referred as “Designated Countries”) at the time of Data or Personal Information being collected. We may ask for your information regarding your nationality, your location, which country you are in when you use Our Services or Platform, or We may rely on your IP address. We cannot apply this provision to Users who do not provide information about the location or obfuscates location information so as not to appear located in the Designated Countries.
We use and process your Personal Information based on a valid lawful basis of the EU General Data Protection Regulation (“GDPR”) and any equivalent regulations (collectively referred as “Data Protection Laws”). The lawful basis for processing your Personal Information includes (i) your consent, (ii) performance of a contract, (iii) a legitimate interest, (iv) a compliance with legal obligations, (v) protection your vital interest, and (vi) public task.
Under certain circumstances when you use Our Services, you have the rights under the Data Protection Laws in relation to your Personal Information. These rights include the followings:
- Right to be informed
You reserve the right to be informed about the collection, use, and process of your Personal Information.
11.2 Right of access
You reserve the right to make a request for a copy of the Personal Information We hold about you and specific information regarding Our processing of this information.
11.3 Right to rectify
You reserve the right to request Us to update, correct, or complete your Personal Information that you believe to be outdated, inaccurate, or incomplete. You will rectify at any time by informing Us via our contact channels.
11.4 Right to erasure (“Right to be Forgotten”)
You may request to have your Personal Information deleted from Our record where (i) your Information is no longer necessary to be used for the Services or on the Platform, (ii) Information was collected in relation to processing that you previously consented to, but later withdrew such consent, or (iii) you Information was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for Our processing.
11.5 Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We will provide you, or third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented Us to use.
11.6 Right to restrict processing
You may request Us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
- to establish the accuracy of the Personal Information;
- when the processing is considered unlawful, but you do not wish to have your Personal Information erased;
- where We no longer need to process your Personal Information, but the information must be retained for legal reasons; and
- where you have objected to Our processing your Personal Information, but We need to determine whether Our legitimate interest overrides your objection.
11.7 Right to object
You may object to Our reliance on Our legitimate interests as the basis of Our processing of your Personal Information that impacts your rights. You may also object to Our process of your Personal Information for direct marketing purposes.
11.8 Right to withdraw consent (“Opt-out”)
You reserve the right to withdraw your consent at any time where We are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of Our processing of your Personal Information prior to withdrawing.
If you wish to exercise these rights as aforementioned, please inform and contact Us via Our Platform, including CHAINS website or send a request to [∙] firstname.lastname@example.org
Please also be noted that there are some limitations when you wish to exercise any one of these individual rights. We may limit your individual rights in the following situations:
- Where denial of access is required by laws;
- When granting access would have a negative impact on others’ privacy;
- In order to protect Our rights and properties;
- Where the request is burdensome.
12. Cross Border Transfer of Personal Information
As a part of your use of and to ensure better and seamless delivery of the Services to you, We may store, process, analyse, transfer your Personal Information in location globally, including countries other than your home jurisdiction, and/or locations outside the Designated Countries where there may have data protections with less protection than the EU GDPR or the equivalent data protection laws.
Our Service and Platform contain the transmission of your Personal Information to or to be transferred to or to be processed outside of the country where you are located or outside the Designated Countries, it is not suggestible if your Personal Information is restrictive.
However, if you wish to continue using Our Services outside the Designated Countries and your home locations, We will ensure that We will transfer your Personal Information only to country that has the required contractual provisions for transferring Personal Information in place with the third parties to which your Information is transferred, or to country where is approved by the EU authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information. In this manner, you hereby expressly consent to this transfer, and agree that We will not be responsible for any additional T&Cs, policies or any other guidelines implemented by any party receiving the information.
13.1 Our Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of country or jurisdiction where you are using Our Services or Platform. If you are not over 18 or of the legal age of your country, you will not provide any Personal Information to Us, or to engage in Our services. We reserve the right to access and verify any Personal Information collected from you. If We are aware that you are under 18 or under the legal age who already shared your Personal Information with Us, We will then discard such information and block your access to CHAINS Platform immediately.
13.2 We cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information will not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials.
Furthermore, We may provide you with the “just-in-time” disclosures or additional information about Our data collection process, purposes for processing, or other information with respect to collection of your personal information. The purpose of the just-in-time notification is to supplement or clarify Our privacy practice or provide you with additional choices about how We process your personal information.
15. How to contact CHAINS