Effective as of March 22, 2019

This Privacy Policy regulates the processing of your personal data. The Privacy Policy is prepared by a private limited company "Riddletag OÜ" (incorporated in Estonia; Registry code 14653616; Registered office address: Harju maakond, Kuusalu vald, Pudisoo küla, Männimäe, 74626; hereinafter the "​Company​").

By accessing the Company's website or any platform you give the Company consent explicitly to the processing of your personal data and the allocation of cookies files on your electronic device when you use products and services (hereinafter the "​Company Products​").

GENERAL INFORMATION

This Privacy Policy helps you understand how your personal data is stored and processed by the Company.

PROCESSING OF PERSONAL DATA

You may use the Company Products without identifying yourself or revealing any data about yourself. Nevertheless, upon the registration or your involvement in the Company Products, the Company may collect your name, surname, email address, your cryptocurrency wallet physical address, identification information, taxpayer and immigration information, payroll, insurance and banking information, and other information necessary to satisfy the verification and other requirements of the applicable laws (hereinafter the "​Personal Data​"). You may not be registered by the Company and use some of the Company Products without providing a copy of your passport and photograph.

The Company may automatically collect, store and process data. This may include statistical data that does not identify you or identify you indirectly. We also may process your computer data such as your hardware and software version, operating system, computer identifiers, network information, phone number for your identification and improvements of the Company Products.

We also may process log information such as IP address; identification numbers of your computers; location; your actions in our applications; your transactions; system configuration data; metadata; and other actions with the Company Products.

The Company may process certain pieces of information when you interact with the Company's website or other Company's platforms. The Company uses cookies to personalize your use of the website or other platforms and Company Products. The Company may use session cookies to track your current session activity; persistent cookies to understand usage patterns so the Company can improve its website or platforms; third party cookies to provide relevant advertising to you. The Company may also allow third party service providers to place cookies on the Company's website and platforms to perform analytic or marketing functions. You are notified of them and give consent to such processing of your Personal Data. The Company does not control the use of such third-party cookies and the Company shall not be responsible for any actions or policies of such third parties. You may limit or turn off cookies on your device. This will limit our system performance and may cause malfunction of the Company's website and platforms. We shall be not liable to you for such a malfunction.

PURPOSE OF THE USE OF PERSONAL DATA AND OTHER DATA

The Company may use aggregated Personal Data and other data for research and commercial purposes, such as helping the Company improve the Company’s website, platforms, and applications. The Company may use your Personal Data for commercial purposes to offer the Company Products, Company's affiliates’ or third-party products and services. The Company may use your Personal Data to contact you, answer your questions, or share information on services with you. You may refuse to receive this information by notifying us.

The Company may reveal Personal Data about you to unaffiliated third parties:

(1) if you request to transfer your Personal Data to a third party;

(2) if the Personal Data shall be given to complete your transaction;

(3) if the Personal Data shall be provided to comply with the law, to enforce Company's agreements, or to protect the rights, interests, titles, property, or security of the Company, its affiliates or users;

(4) if the disclosure of the Personal Data is done as part of an acquisition, transfer or sale of services or assets;

(5) if the Personal Data is given to Company's agents or service providers to undertake functions on Company's behalf for analyzing data, providing marketing assistance, providing services, processing payments, and other similar activities; or

(6) as otherwise described in the applicable law.

You may opt out of the processing of your Personal Data by contacting the Company via communication channels available on the Company's website or platforms. You shall provide the Company with accurate and actual Personal Data. The Company gives you the ability to amend your data at any time by accessing your account on the Company's site and platforms. If there is no option for particular information you shall contact the Company directly via communication channels available on the Company's website or platforms. The Company may retain Personal Data for a certain period of time in accordance with the applicable law. The Company will hold your Personal Data for the period of time the Company believes is necessary to comply with the applicable law. You may request from the Company the information on what your Personal Data is held and where it is stored or receive a copy of that Personal Data.

TECHNICAL AND SECURITY MEASURES

The Company has appropriate technical and security measures in place in its physical premises and computer systems, databases, and other networks that are reasonably designed to protect from data loss, misuse or alteration.

WE SHALL NOT BE RESPONSIBLE FOR ENSURING THE CONFIDENTIALITY OF NON-PUBLIC INFORMATION THAT YOU PROVIDE US.

There is no 100% secure electronic transmission or storage in the world that is why it is natural that the Company cannot guarantee the absolute security of your Personal Data. You also shall take into account your role in protecting your Personal Data.

You shall notify the Company instantly of any illegal and unauthorized access to your account or a breach of its security. The Company may stop providing services, terminate your account and your access, or remove or edit content in its sole discretion.

LINKS TO THIRD-PARTY WEBSITES

When you use the Company's website, platforms, or Company Products, you may be directed to other websites that are beyond the Company's control. The Company may also allow third-party sites or applications to link to the Company's website and platforms. The Company is not responsible for the privacy policies of third parties or any content linked to any website. The Company recommends you to read and understand the privacy policies and other legal documents of such parties and websites.

INTERNATIONAL TRANSFERS

Personal Data the Company receives may be held on the Company's computers and systems in the European Union, data centers in the European Union and may be processed by the Company's personnel working within the European Union and authorized for such access.

HOW LONG WILL MY DATA BE STORED

We process and store your personal data as long as it is required to fulfill our contractual and legal obligations.

If the data is no longer required to fulfill the contractual or legal obligations, it will be deleted unless the limited further processing is required to preserve evidence within the scope of statutory limitation periods. According to §§ 195ff. of the Civil Code (BGB), these limitation periods can amount to up to 30 years, whereby the regular limitation period is 3 years.

WHAT DATA PROTECTION RIGHTS DO I HAVE

Every user has the right to receive information according to article 15 GDPR, the right to correction according to article 16 GDPR, the right to deletion according to article 17 GDPR, the right to limit processing according to article 18 GDPR, the right to opposition based on article 21 GDPR as well as the right to data transmission based on article 20 GDPR. In the case of the right to information and deletion, the restrictions according to §§ 34 and 35 of GDPR apply.

Furthermore, there is a right to lodge a complaint to a responsible data protection supervisory authority (article 77 GDPR in connection with § 19 GDPR). You can opt out of the granted consent for the processing of your personal data. This also applies to consent withdrawal, which has been granted to us before the applicability of the General Data Protection Regulation, therefore before May 25, 2018. Please remember that the opt-out will only work in the future. Processing that has occurred before the opt-out will not be affected.

AM I OBLIGED TO PROVIDE DATA

Within the scope of our business relationship, you have to provide personal data required for the beginning and execution of the business relationship and the fulfillment of the affiliated contractual obligations; or the personal data we are legally obliged to collect. Without this data, we are normally not able to complete the contract with you or execute it.

Note. We do not use fully automatic decision-making in accordance with article 22 GDPR.

CHANGES TO OUR PRIVACY POLICY

The Company, in its discretion, may from time to time amend this Privacy Policy. The Company recommends you to check the Company's website and platforms frequently to see the current version of the Privacy Policy and its previous versions. The Company may inform you of the changes to the Privacy Policy using the available means of communication.

WHO IS RESPONSIBLE FOR DATA PROCESSING

The responsible position is:

Riddletag OÜ

Harju maakond, Kuusalu vald, Pudisoo küla, Männimäe, 74626

You can reach our data protection officer at:

Riddletag OÜ

Data protection officer:

Yurii Holuzynets

Email address: privacy@riddletag.com