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Privacy policy

Version 2.0 ︱Last updated 2 August 2019

Updates

We have updated our Privacy Policy to make sure:

• The terms are easier to understand;
• This Policy reflect all the changes made to our products; and
• You know how we improve our products and share data with partners inside and outside GDPR applicable

Privacy policy

This Privacy Policy sets out how we will use, store, share and protect your personal information. In this Policy “Blockpass”, “our”, “we”, or “us” refers to Blockpass IDN Limited of 1701-02 17F FWD Financial Centre, 308 Des Voeux Road, Central Hong Kong (together with our subsidiaries, our holding company, and subsidiaries of our holding company from time to time) and “Platform” means our website at https://www.blockpass.org/ and our software, namely Blockpass App (the “App”). This Policy applies to products and/or services you subscribe to via the website or the App.

In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services on the website or via the App, that relates to an identifiable individual. Please read this Privacy Policy carefully and ensure that you understand it. Your continued use of the products and/or services is deemed as acceptance of our Privacy Policy.

What Does This Policy Cover?

This Privacy Policy applies only to your use of Blockpass App and Blockpass website, including newsletter subscription and any promotion/offers we make available from time to time. It does not extend to any websites that are linked to or from our site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by third party websites you connect to and we advise you to check the privacy policies of any such websites before providing any data to them.

Your Blockpass ID

Stage 1 – Creating your Blockpass digital identity

To create a digital identity with Blockpass all we need is for you to submit your email address.

Stage 2 – Getting verified

To get verified you will need to add your personal information such as name, address, photographic and video ID. To enhance the accuracy of your digital identity you may be required to provide additional data, such as date of birth, copy of ID, citizenship information, country of residence, among others.

All data you submit to Blockpass will remain in the App and it will be sent to us temporarily until it is verified. Under your instructions and consent we will share the data with the verifier. After verification we will not store your information outside the App or keep a copy of your data.

Stage 3 – Registering with third party services

Now that you are verified, you will be able to use your Blockpass ID to register with third party service providers (“merchants”). Different merchants may require different types of information and you have control over your data during onboarding procedures. In order to access the merchant’s services you will consent to us sending the data from the App to the merchant.

You can edit and review your personal information directly in the App. If you choose to cancel your account with us we will delete your information unless we are prevented to do so by law and to prevent fraud and money laundering.

Your personally identifiable information will not be used for any further purposes, nor sold or shared with third parties, except as necessary for the provision of the services to you, to prevent fraud or money laundering and assist law enforcement in accordance with this Privacy Policy.

What Data Do We Collect?

Subject to the above section we collect the following types of information about you:

(a) account and profile information that you provide when you register for an account or sign up for our products or services, for example: Cryptographic hash of identifying information, such as your name and date of birth; Cryptographic hash of contact information, such as your postal address, email address and telephone number. (collectively, “Account Data”);

(b) information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);

(c) communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey, quiz or a questionnaire that we send you (collectively, “Preference Data”);

(d) information about your device or connection, for example Digital identifying information sent by your mobile, computer or access device including but not limited to IP address and web log information;

(e) Blockchain addresses;

(f) information we collect through cookies and other data collection technologies (collectively, “Technical Data”); and

(g) Information about your use of or visit of our App, for example Details of any products or services that we provide to you; Information about how you use the products and services we provide; and records of our communications with you, including any messages you send us. (collectively, “Usage Data”).

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.

Cookies

We use cookies on the website to distinguish you from other users. This helps us to provide you with a good experience when you browse and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.

We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our website or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

We use the following cookies:

• Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into the secure areas of our website.
• 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. 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).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our website.

How Do We Use Your Data?

We may collect and share your data in good faith and when it is reasonably necessary to (a) comply with applicable law or regulations, or to government requests and legal process; (b) enforce our terms and protect our users; and (c) properly provide the services to you.

We use personal information that we collect about you where the law allows us and for the following purposes:

(a) Where we need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our website and App;

(b) Where it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;

(c) Where you’ve given us consent to do so for a specific purpose, for example we may send your data to third parties with your permission; or

(d) Where we need to comply with a legal or regulatory obligation.

If you have given us consent to use your personal information for a specific purpose, you can withdraw your consent at any time by contacting us at [email protected], but please note this will not affect any use of your information that has already taken place.

We do not share your personal information with any company outside our group for marketing purposes, unless with your express specific consent to do so. For visitors to or users of our App who are located in the European Union, we have set out our legal basis for processing your information above.

How and Where Do We Store Your Data?

All information you provide to us is stored on our secure servers.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

We only keep your data for as long as required by local regulatory law, fraud and money laundering requirements. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.

Do We Share Your Data?

The data that we collect from you may be transferred to, and stored at a destination outside Hong Kong. It may also be processed by persons who operate outside Hong Kong.

By submitting your personal information and using our services you agree to our practices which may include the transfer and processing of your data to other countries globally where we have partners and services providers, regardless of where you use our services. We will take reasonable steps to ensure that your data is treated securely in accordance with this Privacy Policy however you acknowledge that the laws and regulations of the country in which your data is processed may be different from those of your own country.

We may share your data to the following parties:

– our staff who need the information to discharge their duties;
– related entities within our corporate group;
– our business partners, agents and service providers, including verifiers;
– payment system operators and financial institutions;
– professional advisers who we engage to provide advice on our business;
– government authorities who ask us to disclose that information, or to other institutions and third parties as required by law.

Third parties we contract with are bound by contracts with confidentiality and non-disclosure clauses and may not use your personal information for any reason other than specified in this Privacy Policy.

We also integrate third party services via our App (Merchant’s services) and in order to use their services you consent to us sharing information with them. Please note that when you use Merchant’s services their own terms and privacy policies will apply.

What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

Your rights

You have the right to:

(a) check whether we hold personal information about you;

(b) access any personal information we hold about you; and

(c) require us to correct any inaccuracy or error in any personal data we hold about you.

Any request may be subject to a small administrative fee to meet our cost in processing your request.

Please contact Us for more details at [email protected]

Changes to our privacy policy

We may amend this Policy from time to time by posting the updated policy on our website. By continuing to use our website and our App after the changes come into effect, you agree to be bound by the revised policy.