imusify OÜ, a company duly established under the laws of Federal Republic of Germany, with a registered seat on the address Viru Väljak 2, 10111, Tallinn, Estonia, (“imusify”) (hereinafter, collectively, »imusify«, "we", “us” or “our”) is committed to protecting and respecting your privacy and maintaining the highest standards, required by the Regulation (EU) 2016/679 (the “GDPR”).
We may collect and process the following data about you:
We require users who participate in the imusify Token Sale and acquire any imusify Tokens during the Sale to give us certain personal identification and contact information. Depending on the scope of whitelisting and compliance with Know-Your-Customer (“KYC”) and Anti-Money-Laundering (“AML”) regulations and procedures (as specified in the Terms and Conditions for Participating in the imusify Token Sale – “Terms”), you may be asked to provide the following personal identifiable information: your personal name and family name, citizenship, address of the permanent residence, date and place of birth, citizenship, copy of utility bill, copy of governmentally issued ID (personal document; including information about its type, number, date of issue and expiration date), your personal photograph holding such ID document; e-mail address, telephone number, your NEP5 standard compatible wallet address from which you will send NEO to imusify NEO Wallet and your NEP5 standard compatible wallet address to which you wish to receive imusify tokens. You will need to be physically present and identify yourself to us by using your ID. Should you purchase imusify tokens on behalf of a legal entity you represent, you will be required to provide us with the following information: Legal entity’s name, registered office, business address, registration number, name of the representative, country of registration, tax ID number, e-mail address, excerpt from the business register which is not more than three months old. The legal entity’s representative will need to be physically present and identify himself to us and provide his personal information listed in the previous paragraph.
If you have a reason to believe that someone has provided us with your personal information, or wish to discontinue your participation in the imusify TokenSale, and you would like to request that your personal information be removed from our database, please contact us at [email protected] Notwithstanding the foregoing, we will hold the above information for as long as is necessary in order to provide you with the service on the Website, deal with any specific issues that you may raise or otherwise as is required by the applicable law (including, but not limited to KYC and AML regulations).
With regard to each of your visits to the Website and participation in the Sale:
Quantity of purchased imusify Tokens, date and hour of purchase, and identification number (address) of NEO wallet;
Information about your visits, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time);
Products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
Technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
any other information with regard to the participation in the Sale we might receive from any other sources.
We may receive information about you from publicly available sources. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
You understand and agree that information as outlined above inSections 1(Information you give us) and2(Information we collect about you) may be collected with the help of (and may be stored and processed) by our KYC specialized service providers, in particularBASIS ID, operating as DATA DEPOT ASIA PTE. LTD., a Singapore limited company (company number 201713091C) having its registered address at Block79 @ Launchpad 79 Ayer Rajah Crescent, 05#08 Singapore, 139955 (the “Service Provider”).
We use information held about you in the following ways:
to enable your participation in the imusify Token Sale;
to provide you with information about other services that you request or that we offer which are similar to those that you have already purchased/provided or enquired about;
to notify you about changes to our services;
to ensure that content from the Website is presented in the most effective manner for you and for your computer;
to comply with applicable KYC/AML regulations or any other applicable laws;
to prevent fraud and other prohibited or illegal activities;
to protect the rights and safety of our affiliated entities and third parties, as well as our own;
to monitor compliance with our Terms and Conditions for Participating in the imusify Token Sale;
to ensure you receive information relevant to you;
to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep the Sale and the Website safe and secure.
if imusify or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
to keep you up-to-date on the latest service announcements, updates, special offers or other information that we think you’d like to hear, either from us, our business partners or third parties.
in order to enforce or apply our Terms and any other relevant agreements;
or to protect the rights, property, or safety of imsuify, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
In addition to the above cases, we may disclose your personal information also to any affiliated company of imusify, participating in whatever capacity (for example, as agent, representative, or seller of the Tokens) in the Sale or performing any services during or for the purposes of the Sale (including, but not limited to: IT company specialized in the performance of the KYC/AML procedure during the Sale), to the extent such disclosure is necessary for its provision of such services or its engagement in the Sale.
We will not otherwise provide your personal data to a third party without obtaining your prior consent.
Upon request, we will provide you with information about whether we hold or process any of your personal information, whether on behalf of a third party or otherwise. To request this information, please contact us at [email protected]
If your personally identifiable information changes, or if you no longer desire to participate in the Sale, you may correct, update, discontinue the participation in the Sale or delete it by making the change on our member information page or by emailing our Support at [email protected] We will respond to your request to access within 30 days.
We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We use a third party platform host, who hosts the forms on our site, they do not have any access to the personal information that you submit on our website.
The data that we collect will be stored on the cloud with the hosting infrastructure based in the European Economic Area ("EEA").
The communication internally between our servers (e.g. between application server and database) is handled via secure socket layer (“SSL”) to provide AE-256 encryption and all information between our servers and your browser is handled via SSL (up to 256-bit encryption, depending upon your browser), providing an industry-standard level of protection for data in-transit.
You should always make sure that your browser can validate the Website’s certificate.
All encrypted data is signed using a message authentication code (MAC) so that the underlying value cannot be modified once encrypted.
We also implement an advanced security method based on dynamic data and encoded session identifications in a secure server environment using preventive, detective and corrective technology and processes to safeguard information from attackers. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data.
The security of your personal information is important to us. When you enter sensitive information in our registration or order forms, we encrypt that information using transport layer security (TLS) technology. We also encrypt any information entered within the platform once users log into their accounts. If you have any questions about security on our Website, you can contact us at [email protected]
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.
Your passwords are stored on our servers in encrypted form using a one-way hashing algorithm.
Please be reminded that you must protect any passwords or other credentials associated with your account for the participation in the Sale, and take full responsibility for any use of the account under your password. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to the Website, although we will do our best to protect your personal data. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
In the case of a personal data breach, we shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, of the General Data Protection Regulation of the European Union unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. In such case we will also notify you without undue delay and, where feasible, not later than 72 hours after having become aware of the breach, and suggest any actions to be taken to secure your personal information (change your username and password, etc.).
You may ask us not to process your personal data for a particular purpose, or to access such information, by contacting us at [email protected] Please note, however, that you shall remain liable for any fees or costs incurred at the time of the withdrawal of your consent to process your personal data. Furthermore, such request may result in you being unable further participate in the Sale.
You may ask us to receive your personal information, which you have provided to us, in a structured, commonly used and machine-readable format and shall have the right to transmit such information to another controller. You may submit such request by contacting us at [email protected] Please note that the processing of such request may take up to 14 days to complete.
The Website may, from time to time, contain links to other third party websites.
If you follow a link to any of these websites, please note that these websites have their own privacy policies (including, as the case may be, landing pages of other IMUSIFY products or services) and that we do not accept any responsibility or liability in respect of these policies.
Please check these policies before you submit any personal data to these websites.
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. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
These are used to recognise you when you return to the 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 find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Cookie Name||Cookie Type||What is it for?||Duration||Domain|
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We offer you a means to choose how we may use the information you provide. If, at any time after registering for participation in the Sale, you change your mind about receiving certain email communications from us or about sharing personal information with third parties, send us a request to opt-out from receiving promotional emails or from having your personal information shared with third parties. Send your request to [email protected]
Date of Last Revision: May 24, 2018