Who we are
Tokenest Technologies Ltd are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. In this policy we will also outline the lawful basis for processing your data, why we wish to collect the data, and what your rights are in regards to the data.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulations the data controller is Tokenest Technologies Ltd registered in Cyprus, Driadon 1, 1st Floor, Office 107, 6041 Larnaca, Cyprus and with registration number HE452649.
Security
We understand the importance of data security, how we collect personal data from you and how it is managed thereafter. All information that you provide to us, or that is collected about you, is stored on our secured servers. We use safeguards such as firewalls and physical access barriers to ensure that your personal data is protected.
Our systems use role based authorisation and authentication where any action made is logged (e.g. to view, edit or delete data of any kind) as an enhanced security measure. Any repayment transactions that take place will be encrypted using secure socket layer (SSL) technology, and all debit card details are encrypted on our system to comply with PCI DSS (Payment Card Industry Data Security Standard) requirements.
The information we may collect from you
We will collect and process the following data about you:
• Your full name, date of birth and address
• Contact details including your mobile telephone number, email address and home telephone number
• Financial information including your income and expenditure, residential status, bank details
• Business details including your business name and all your business details
• The IP Address used to make the application
If you contact us via email, SMS, post, or by phone, we may keep a record of the correspondence or conversation. We may also collect data from third party sources, such as social media, ID&V agencies, third party tracing services and fraud prevention agencies. This data will only be collected and stored if deemed necessary and will not affect your rights.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by accessing the full notice available under the heading “Fair Processing Notice (Fraud Prevention), below.
How we will use the information collected from you
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These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
Legal grounds for processing your information and data retention
The data protection laws allow use of personal data for the purpose of legitimate interests which does not outweigh the interests, rights or freedoms of customers Any data collected from you will be processed lawfully, fairly and in a transparent manner. The lawful basis for processing the following data is legitimate interests:
• Your full name, date of birth, address, IP Address, and all employment details will be processed for fraud prevention purposes and to confirm your identity and source of funds. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Financial information will be processed to assess your source of wealth, which will ensure any transaction we enter into with you is legitimate and above board. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Contact details will be processed for customer contactability, whether that be processing your requests, verifying information that has been inputted or for marketing purposes. A record of this information will be retained for a period of 6 years after the end of our business relationship
• All of the above data may be transferred to a third party, such as a ID&V agency, if we have any concerns about the legitimacy about our relationship
• Your bank details will be processed to deposit payments to you. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Your debit card details will be processed to debit payments and if tokenised will be done so using continuous payment authority. A record of all of this information will be retained for a period of 6 years after the end of our business relationship, although this information will be encrypted
Identity Verification & Fraud Prevention
Before the transfer of any funds from Us to You, we will run an identity and verification check to verify your identity to prevent fraud, terrorist financing and for anti-money laundering purposes.
– We will verify your information with ID&V service providers
– We will check your details against international and local fraud databases, PEPs and Sanction Lists
Data will be processed for the following purposes:
– To prevent fraud, money laundering and / or terrorist financing
– To create an account for you to redeem your NFT with Tokenest in line with our terms and conditions
– To manage accounts once we begin our relationship
– To contact you to discuss any relevant issues (such as verification, AML, marketing, payment)
Disclosure of your information
Any personal data held about you may be disclosed for the following purposes:
• Personal data will be shared with reference agencies to verify your identity, prevent fraud, money laundering and / or terrorist financing and to manage accounts once we begin our relationship
• Personal data may be transferred to law enforcement (such as the police) or other public bodies if there is a legal obligation to do so
• Personal data may be used for marketing and remarketing purposes
Members of staff at Tokenest Technologies Ltd or Our appointed representatives may be passed your data in order to service your account for the above purposes. Data will only be shared with these recipients on the basis that we have a legitimate interest in which to do so.
Personal data may be accessed by members of staff at Tokenest Technologies Ltd or appointed representatives who operate outside of the EU. Any data processed in this manner will be accessed and used via our secure servers to ensure there is no risk to the confidentiality of your personal data, and any activity is logged to ensure security and accountability.
We will not pass on any of your details for marketing purposes, whether internal marketing or externally, unless you actively consent to marketing.
Fair Processing Notice (Fraud Prevention)
GENERAL
1. Before we complete a transaction with you, that is to say prior to funds being received from you or sent to you,, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
2. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
3. Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, your business details and device identifiers including your IP address.
4. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
5. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
6. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
AUTOMATED DECISIONS
7. As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behavior to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details above.
CONSEQUENCES OF PROCESSING
8. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or to employ you, or we may stop providing existing services to you.
9. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
DATA TRANSFERS
10. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
YOUR RIGHTS
11. Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data be erased or corrected; request access to your personal data.
12. For more information or to exercise your data protection rights, please contact us using the contact details above.
Complaints regarding use of your personal data
If you are unhappy with the manner that we handle your personal data you can make a complaint directly to us. A copy of our full complaints procedure can be located here, although you can find the contact details to raise a complaint outlined below:
Email: complaints@get-tokenest.com
Post: Driadon 1, 1st Floor, 6041 Larnaca, Cyprus
Third Party Links
Our site may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies, and we do not accept any responsibility or liability for these policies.
Please check these policies before you submit any personal data to these websites and please note that we are not responsible for the services or representations of third parties.
Your rights
Under the General Data Protection Regulations you have the following rights regarding the processing of your data:
Right to be informed: We aim to be completely transparent in the manner that we process your data. This privacy policy and our pre-contract information are written to provide a full overview of how we use your data. If you wish to query any aspect of this notice, or you have any questions not addressed in this notice, please email our dedicated mailbox info@get-tokenest.com
Right to restrict processing: If you believe that any of the personal data that we hold on you, have processed about you, or will process about you is unlawful you can request that we restrict processing while we look at the points you have raised.
You can request for the data to be restricted by emailing info@get-tokenest.com. Please include the personal data that you want to be restricted, why you want this data restricted and details that allow us to locate your data (such as full name, reference number etc.) Alternatively you can request to restrict use of your data by writing to us Driadon 1, 1st Floor, 6041 Larnaca, Cyprus.
If we refuse your request you will be informed of the reason why, and you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.
Right to rectification: If you believe that any of the personal data that we hold on you, or have processed about you (such as identity and fraud agency data) is inaccurate you have the right to request that we correct the information.
You can request for the data to be rectified by emailing info@get-tokenest.com. Please include the specific information that you are disputing, alongside details that allow us to locate your data (such as full name, reference number etc.) Alternatively you can request data rectification by writing to us Driadon 1, 1st Floor, 6041 Larnaca, Cyprus.
If we refuse your request you will be informed of the reason why, and you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.
Right to object: You have the right to object to the manner that we are processing your data if you do not believe we have legitimate grounds to engage in the processing activity.
You can object to the data being processed by emailing info@get-tokenest.com. Please include the specific reason you are objecting to us processing your data, alongside details that allow us to locate your data (such as full name, reference number etc.) Alternatively you can object to use of your data by writing to us Driadon 1, 1st Floor, 6041 Larnaca, Cyprus.
If we refuse your request you will be informed of the reason why, and you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.
Right to access: Please refer back to the section entitled “ACCESS TO YOUR INFORMATION” which explains your rights to obtain personal data.
The following rights will not be applicable if you opt to proceed with creating an account that results in the transfer of funds from or to you::
Right to erasure: In certain circumstances where personal data is processed you will be able to request that your information is erased.
Due to the legitimate interests involved in our processing of your personal data (such as fraud prevention and anti-money laundering) we will be unable to erase any data permanently unless there is an exceptional circumstance in which to do so that overrides the legitimate interests for processing.
You can contact us by emailing info@get-tokenest.com if you wish to obtain more information regarding the right to erasure. If you are unsatisfied with our explanation you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.
Right to data portability: Due to the legitimate interests involved in our processing of your personal data we will be unable to transfer your data as outlined by the General Data Protection Regulation.
You can contact us by emailing info@get-tokenest.com if you wish to obtain more information regarding the right to data portability, and why it does not apply in this instance. If you are unsatisfied with our explanation you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.
Contact us
For any additional queries regarding this notice or how we intend to use your data please contact us using the details below:
Email: info@get-tokenest.com
Post: Driadon 1, 1st Floor, Office 107, 6041 Larnaca, Cyprus