This document was last updated on 17.05.19
Company name: Medibitcoin Network Ltd.
Project name: MONET Blockchain Project
Company Registration no.: 11268735
Company Address: 960 Capability Green, Suite no. 124, LU1 3PE, Luton, Bedfordshire, UK
1. AGE REQUIREMENTS
We do not knowingly collect personal information from children under 18 years of age. If you are under 18 years old, please do not provide any personal information to us.
2. INFORMATION WE WILL COLLECT FROM YOU:
2.1. information that you provide when registering for our Services which includes: a. name; b. date of birth; c. 2 forms of identification (e.g. passport & utility bill confirming your permanent address); d. your 2 seperate pictures where you are holding your forms of identity, next to your face; (not sure how to take picture)
2.2. information that you publish on your user profile or which you post on communication channels such as forums, communities, or chat areas, designed to enable you to communicate with others boards. Please note that information that you voluntarily make public in your user profile, or which you disclose by posting comments will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions;
2.3. information that you authorise a third party (e.g. a social network such as Twitter) to share with us, such as your email address or other information that may identify you;
2.4. correspondence, or a record of it, if you should contact us;
2.5. surveys that you complete;
2.6. statistical data about your browsing actions and patterns, which does not identify you. This means information about your computer and your use of our Services, including (where available) your IP address, unique mobile device identifier (UDID), International Mobile Equipment ID (IMEI), Android ID, device MAC address, social platform ID, advertising ID for Android platform, ID for advertisers (IDFA) and ID for vendors (IDFV) for iOS platform, OPEN UDID, ODIN, browser information, operating system, timestamps, the pages that you request, applications downloaded, traffic data, location data, weblogs and other communication data, and the resources that you access.
3. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
to ensure that the Service is presented in the most effective manner for you and for your device;
to identify you when you use the Service;
to answer your questions and improve the Service;
to notify you about changes to our Service;
to provide you with updates and other information about special offers and new features of our Service; &
for marketing purposes where you agree to this by not turning off subscribe setting on your device (refer to your device settings) or withdraw your consent, by contacting us.
4. KYC/AML PURPOSE
Whilst purchasing MONET (ORB) Tokens, you would be requested to provide us with your confidential information as explained in section 2.1 of this document. The process of Token purchase is incomplete without providing us requested information. We will use this information to ensure that:
a. establish your identity;
b. to satisfy that the source of the your funds is legitimate;
c. Assess money laundering (AML) risks associated with individual buyer for purposes of monitoring buyer's activities.
For more details how your information will be collected and processed, please see our KYC/AML Policy.
5. HOW WE SHARE YOUR INFORMATION
5.1 We may share your personal information with your consent with third parties in the following circumstances:
5.1.1 for marketing purposes;
5.1.2 to other members of the Medibitcoin Network Pvt.Ltd, our partners and service providers (such as digital wallet providers; influencers; event organisers etc.) and for the purpose of: managing or administering certain aspects of our Service; for analytics purposes; and to help us develop new services;
5.1.3 to protect the rights, property or safety of us or other Service users;
5.1.4 where we are obliged, or permitted, to do so by law.
6. WHERE WE STORE YOUR INFORMATION
6.1 We take appropriate organisational and technical measures to protect the personal information that we hold. We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs.
6.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Service and any transmission is at your own risk.
6.3. User's personal data will be stored as recommended by Her Majesty Revenue & Customs (HMRC) regulatory authority, UK accessed through this link.
7. WHAT ARE USER'S RIGHTS UNDER GDPR 2018
The GDPR provides the following rights for individuals:
7.1. The right to be informed about:
collection and use of personal data;
company’s purposes for processing personal data, data retention periods, and who it will be shared with;
obtain user’s personal data from other sources within a reasonable period and no later than one month.
7.2. The right to access their personal data free of charge within a month;
7.3. The right to rectification of getting inaccurate personal data rectified, or completed if it is incomplete in writing or verbally. The company would respond to the request within one month.
7.4. The right to erasure to have personal data erased can be requested in writing or verbally. The company would respond to the request within one month.
7.5. The right to request the restriction or suppression of their personal data in writing or verbally. The company would respond to the request within one month. This is not an absolute right and only applies in certain circumstances.
7.6. The right to restrict processing to request the restriction or suppression of their personal data in writing or verbally. The company would respond to the request within one month. This is not an absolute right and only applies in certain circumstances.
7.7. The right to data portability to obtain and reuse personal data for own purposes across different services. The right only applies to information an individual has provided to Medibitcoin Network Ltd.
7.8. The right to object to the processing of their personal data in certain circumstances. Users have an absolute right to stop their data being used for direct marketing. In other cases where the right to object applies User may be able to continue processing if company can show that it has a compelling reason for doing so. The right to object to the processing of personal data can be requested in writing or verbally. The company would respond to the request within one month.
7.9. Users have rights in relation to automated decision making and profiling. As a best practice We carry out a Data Protection Impact Assessment (DPIA) to consider and address the risks before we start any new automated decision-making or profiling. To ensure Users are kept informed all the time, we tell our customers about the profiling and automated decision-making we carry out, what information we use to create the profiles and where we get this information from. We also use anonymised data in our profiling activities.
8.3 All of the major browsers offer tips and guidance for managing the cookies available on your browser. There are also lots of different third party browser plugins and extensions available which you can download to make it easier to see and control your cookies.
8.4 You can find out more about internet advertising by visiting the following websites: www.allaboutcookies.org, www.yourchoicesonline.eu, and www.networkadvertising.org. Some of these sites enable you to opt out of online behavioural advertising and other tracking cookies (in addition to the control settings on your browser).
10.1 We may from time to time use third party advertisers or sponsors on our Service. In the event that we do so we will not disclose identifiable information about individuals but we may provide them with aggregated information about our users. We may also use such aggregated information to help advertisers reach the kind of audience they want to target (for example, woman in London). We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ and sponsors’ wishes by displaying their advertisement to that target audience.
11. ACCESS TO INFORMATION
You have the right to access information held about you. Your right of access can be exercised in accordance with the UK Data Protection Inspectorate Law on Legal Protection of Personal Data Protection. Any access request may be subject to a small administrative fee to meet our costs in providing you with details of the information we hold about you. Contact us at: firstname.lastname@example.org for details.
12. KEEPING YOUR ACCOUNT SECURE
12.1 Where we have given you unique link to page which enables you to access certain parts of the Service, you are responsible for keeping this password confidential and you are responsible for any misuse of such information. You must not share your password with anyone.
12.2 You are solely responsible for the security and confidentiality of your account. Please ensure that you do not allow anyone else to access the Service in your name and sign off after you have finished accessing your account.
12.3 You are responsible for all orders, and for the accuracy of all information, sent via the internet using your user ID, security key, password or any other personal identification used to identify you on the Services.
12.4 You will be liable to us for all orders or transactions placed by use of your user ID, personal key or password, even if such use might be wrongful. We will not be liable to you for any loss that you may incur as a result of misuse of your user ID, security key or password, and we accept no liability resulting from its unauthorised use, whether fraudulent or otherwise.
14. FORCE MAJEURE