Privacy And Cookies Policy
ABOUT THIS NOTICE
Last Edit: 01 May 2018
SpesCoin is committed to protect the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
This notice is separated into the following sections for ease of use. If you have any questions about this notice or how we collect and use personal information about you please contact us https://myspes.org/contact/
- Information about us
- What personal information do we collect and how do we collect it
- Blockchain and personal information
- How and why do we use your information
- Automatic decision making
- Sharing your information
- Where we store the information
- Data security
- How long we keep the data
- Your rights
- Third party websites
1 INFORMATION ABOUT US
- We are the SpesCoin, the secure and stable digital charity currency of the future; exploring the modern world within cryptocurrency to help non-governmental charities and investors reach their goals through worldwide acceptance of SpesCoin as the only charity coin.
- The cryptocurrency that has been developed by SpesCoin is known as “SpesCoin”, or “SPES”.
- If you have any questions, please contact us via https://myspes.org/contact/
2 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
Personal data, or personal information, means any information about an individual who can be identified. It does not include data where an individual cannot be identified (anonymous data). We collect personal information from you in the following ways.
- Form information. This is information about you (such as your name, address, email address, SPES and other cryptocurrency wallet addresses, mobile phone number and alias) that you give us when filling in forms or using our services and digital content whether on our website or elsewhere. This could include, for example, forms which you complete to register for our services, place an order, sign-up for a newsletter or enter a competition.
- Emails and records of other contact. This is information you provide when you contact us (for example by email) or when you respond to correspondence from us. This may include enquiries about our services, follow-up comments or complaints.
- Technical information. This is information about you which is collected via technical means such as your IP address, cookies, webpage counters and other analytics tools.
3 BLOCKCHAIN AND PERSONAL INFORMATION
- The services we provide operate using distributed ledger technology, also known as ‘blockchain’.
- Our cryptocurrency, “SPES”, uses a blockchain which is a public ledger of transactions and when you transact with third parties using SPES, each user of our network independently verifies the validity of your transactions. In doing so the data relating to your transactions, including your public keys, is shared with each user of our network.
- We make online wallets available to you. Each wallet uses a public key, you cannot be directly identified from your public key or wallet address.
- Your transactions are “hashed” in order to “pseudonymise” your personal information. This means that we process (by using the hashing function) your transactions so that the personal data contained within them cannot be attributed to any specific individual without using additional identifying information.
- The act of pseudonymising your personal information makes it very difficult for any third party to identify you from your public key or your transaction history, however this data is still considered to be personal data under data protection laws.
- Each user of the SPES blockchain determines the purposes and means by which transaction information is processed and therefore acts as a data controller in their own right. Each user of SPES’s blockchain is solely responsible for its own compliance with relevant data protection laws.
- Our services facilitate the sending and receiving of SPES between users and cannot function without the data sharing element of blockchain technology. We do not control the ongoing state of SpesCoin’s blockchain or the information stored on it as we are not a party to these transactions.
4 HOW AND WHY DO WE USE YOUR INFORMATION?
Common uses of your information
We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform a contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
- We may also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest although these circumstances are likely to be rare.
Specific examples of ways in which we may use your personal information include:
- Website administration. We may use technical information, information about your visit to our website, cookie data, content and other information gathered about your participation in discussion boards or other functions on our website. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely.
- Website advertising. We, or third party advertisers, may serve adverts on you. Where those adverts are targeted, this may involve using technical information, information about your visit to our website, cookie data and information we (or our third party advertisers) have obtained from third parties. More information is available in our Cookie Notice below. This won’t include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interests in marketing to you.
- Customer Administration. We may use information about you including form information, content and other information you provide to us or which we collect about you as necessary to carry out our contracts with you, and for our legitimate interests in administering your account and any subscriptions or competitions we operate, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Direct Marketing. We may send direct postal or electronic marketing to you using your contact details and information you have provided us. We use this as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers. If you are not acting as a business and have not provided your contact details directly to us in relation to our products or services, we will only send electronic marketing to you if you have consented to that marketing. We will always provide an “opt-out” option on any marketing messages we send you. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing.
Change of purpose
We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 AUTOMATED DECISION MAKING
We automatically monitor use of our services for the purposes of fraud detection.
6 SHARING YOUR INFORMATION
As well as any sharing listed in section 4 (How and why do we use your information?) we may also share your information with third parties, including third-party service providers and other entities in our group. We require third parties to respect the security of your personal information and to treat it in accordance with the law.
Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Blockchain and data sharing
Please see section 3 for further information on the sharing of data over the SPES blockchain.
7 WHERE WE STORE YOUR INFORMATION
- Our core platforms are located in Ireland, Germany and New Zealand. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
- Due to the nature of SPES’s blockchain, any personal data may be stored anywhere around the world at any time. However we are not in control of the information contained on the SPES blockchain: please refer to section 3 for further details.
8 DATA SECURITY
- We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
- We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
9 HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
- If and to the extent that your public key and other wallet information represents personal data, any personal information stored on our blockchain as part of a transaction will remain there indefinitely due to the nature of blockchain technology. As set out in section 3, we do not control the ongoing state of SPES’s blockchain or the information stored there.
- In all other instances, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Details of our typical retention periods for different aspects of your personal information are set out below.
- Contact Information such as your name, email address and telephone number, where this is kept for marketing purposes, we will keep it on an ongoing basis until such time as you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
Content which you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
Technical information which is collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to six months from expiry of the cookie.
10 YOUR RIGHTS
- Data protection law gives you a number of rights when it comes to personal information we keep about you. The key rights are set out below. Under certain circumstances, by law you have the right to:
- Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
- Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in Ireland, this will be the GDPR).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us via https://myspes.org/contact/.
- Marketing Purposes
In addition to the rights set out above, you also have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can exercise the right at any time by contacting us in writing. You can also use the unsubscribe option in our marketing emails to unsubscribe from further marketing emails.
- No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
- What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
12 THIRD PARTY WEBSITES
Our website may, from time to time, contain links to and from the websites of our charities networks and advertisers. If you click on a link to any of these websites, be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
13 CHANGES TO THIS PRIVACY NOTICE
Any changes we may do to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.
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- 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.
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