Last updated: 09 May 2021
Who we are and how you can contact us
Definity Dao Inc (“we” or “DEFINITY”) respect and value the data protection rights and privacy of individuals whose personal data we process.
In our role as service provider to the organization that you represent, we are primarily a data processor for the purposes of the processing of your personal data, however in limited circumstances we will be a separate data controller of the personal data that you provide us with.
For more details, or if you have any questions, you can contact us at firstname.lastname@example.org.
How and why we use your personal data
We use your personal data for the activities and reasons set out below:
- to verify your identity, and complete know your customer (KYC) due diligence and anti-money laundering (AML) screening checks;
- to provide and support our services to the organization you represent;
- to issue invoices, resolve fee disputes and other associated billing services;
- to comply with our legal obligations;
- to comply with our regulatory obligations;
- to better understand our customers and the way they use and interact with our websites and platforms (the “Sites”) and our services;
- to implement any personal settings you request;
- to enhance security, prevent fraud or market abuse, monitor and verify identity or service access, combat spam or other malware or security risks;
- to deliver targeted marketing and service update notices;
- to facilitate events we participate in and communicate with you about those;
- to enforce our agreements with third parties; and
- to protect our business and to enforce and exercise our rights.
What personal data we collect
In order to conduct the activities set out above, we collect certain personal data from you, and others. In some circumstances, we are required to collect this information by law. We collect the following personal data:
- When the organization that you represent becomes a customer or counterparty and/or you become a user of our services, we may collect the following types of information: your name, gender, date of birth, government-issued identification and/or number, photo identification, address, phone, fax, email, country of residence, nationality, place of birth, country of birth and occupation.
- For certain services, we may require additional information if required under applicable law or to meet our regulatory obligations, including under MIFID II, the Dodd-Frank Act and equivalent regulation of other jurisdictions. The types of information may include your identification (including any information you may share about members of your family including information we may gather about you or your dependents and family), personal circumstances (financial or non-financial), CV, criminal convictions, bank account details, proof of address (e.g., utility bills) and your registration details with any competent authority.
- Whenever you contact us or respond to our communications (e.g., in email, telephone, or writing), we receive your contact information and any other personal data you choose to provide us. DEFINITY will use such information to fulfil your requests or to provide services.
- We collect personal data when you use or request information about our services, subscribe to marketing communications, request support, complete surveys, or sign up for and/or attend events DEFINITY participates in.
Where we obtain and collect your personal data from
As explained in section 3 above, we collect personal data from you, as well as from others.
- We collect personal data that you give us: directly by filling in forms, using our services and contacting us, and that we learn about you from our business interactions, communications and dealings with you.
- We collect personal data automatically: when we receive and store certain types of information automatically, such as whenever you interact with the Sites or use the services:
- this personal data does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (e.g., Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
- we automatically receive and record personal data from your web-browser/DEFINITY application, including: how you came to and used the services and Sites; your IP address; GPS location; device type and unique device identification numbers; device event information (e.g., crashes and system activity); broad geographic location (e.g., country or city-level location); and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your web-browser.
- we may also collect information about how your device has interacted with our Sites, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at the Sites via an external link, such as a link appearing on third party Sites.
- We collect personal data from others: when we obtain information about you from third party sources as permitted by applicable law, such as from public databases, joint marketing partners, and social media platforms:
- Public Databases, Credit Bureaus & ID Verification Partners: in order to comply with our legal obligations, such as AML laws, and to prevent and detect fraud and market abuse, we obtain personal data from public databases and ID verification partners for the purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such personal data includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant personal data. In some cases, we may process additional personal data to ensure our services are not used fraudulently or for other illicit activities.
- Resellers, Joint Marketing Partners, and Social Media Platforms: we collect personal data about your publicly available social media profile, interests or preferences, and page-view information from third parties.
- We process such personal data to promote and optimize our services.
Who we share your personal data with
We disclose your personal data for the purposes set out above:
- to other members of DEFINITY including employees, directors;
- to service providers who host our Sites or other information technology systems or otherwise hold or process your personal data on our behalf, under strict conditions of confidentiality and security;
- to business partners, professional advisors, suppliers and sub-contractors for the performance of any contract we enter into with them or the organization that you represent;
- to organizations and individuals involved in events that DEFINITY participates in;
- to your colleagues within the organization that you represent; and
- in exceptional circumstances:
- to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory;
- to third parties as part of a reorganization, sale, merger or joint venture of any other part of DEFINITY; and
- where we are required by law to disclose.
Please note that third parties you interact with, including your employer, may have their own privacy policies, and DEFINITY is not responsible for their operations, including, but not limited to, their personal data practices. Personal data collected by third parties, which may include contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
Retention of your personal data
DEFINITY will retain your personal data for as long as is necessary for the purposes of our business relationship with you, to perform our contractual obligations to you and, if longer, as required for legal and regulatory purposes.
We have established internal policies for the deletion of personal data in accordance with our legal and regulatory obligations.
Your rights in respect of personal data
In the limited circumstances where we act as data controller, EU citizens have certain data protection rights, including:
- the right to access your personal data;
- the right to restrict the use of your personal data;
- the right to have incomplete or inaccurate data corrected;
- the right to ask us to stop processing your personal data; and
- the right to require us to delete your personal data in some limited circumstances.
From 25 May 2018, you also have the right in some circumstances to request for us to “port” your personal data in a portable, re-usable format to other organizations (where this is possible).
Whilst DEFINITY takes appropriate technical and organizational measures to safeguard the personal information that you provide, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that the security of any personal information that you transfer over the Internet to DEFINITY cannot be guaranteed.
How to contact us
We welcome questions, comments and requests regarding this data privacy notice and our processing of your personal data. You can contact us at: email@example.com.
You can also complain about our processing of your personal data to the relevant data protection authority.
DEFINITY is registered with the BVI Information Commissioner’s Office under registration number 2060581.