PRIVACY POLICY

Your privacy is important to Ø Crypto Union so we’ve developed a privacy policy that covers how we collect, use, disclose, transfer, and store your personal information.

Note that by visiting the present website, you are accepting the practices described in this privacy policy.

Ø brings together a society of members, all of whom share the same financial goals and values, pooling together their crypto assets through securitized tokens, and in doing so, becoming co-owners of the cooperative.

As the world’s first crypto union, Ø utilizes blockchain technology to offer efficiency, security and transparency by way of its social structure. By extension, Ø ensures that all generated and surplus resources will be utilized in the financial interest of its members. Ø is eclipsing the traditional way of banking.

Ø Crypto Union undertakes to process personal data in compliance with applicable laws and regulations (including the General Data Protection Regulation (EU) 2016/679 ("GDPR")), this privacy policy and, where applicable, user’s consent. This privacy policy explains to users how their personal data is used and protected by Ø Crypto Union. This privacy policy only applies to personal data communicated by users to Ø Crypto Union.

Ø Crypto Union reserves the right to modify the privacy policy. In case of substantial modification of the privacy policy, Ø Crypto Union will post a notice on the hosting page of the website at least thirty (30) days prior to the implementation of these modifications. By continuing to use the website following the implementation of these modifications, you agree with the modified privacy policy.

Ø Crypto Union encourages users to regularly read this privacy policy, in order to have a complete understanding of Ø Crypto Union’s practices concerning personal data.
Now, in June 2018, the company have undergone a dramatic rebranding in order to appeal to a broader market audience and achieve bigger ambitions than originally set out. Following the gestation period, Ø aims to become the first of its kind, a true crypto union. With a team of over 20 dedicated men and women, from a host of varied backgrounds, the team have lofty aspirations for the future.

1/ What personal data do we collect and why do we collect it?

During our contractual relationship, we will collect and process personal data about you. This data may vary depending on the nature of the product or service subscribed. We collect and process your personal data only when strictly necessary for the purposes described below.

When entering into a relationship, and then subscribing to any new product or service (account, credit, ancillary services, etc.), we collect the data necessary for this operation directly from you.

These data are necessary:

→ to enable us to fulfil our legal and regulatory obligations, such as the obligation to know our client ("KYC"), our tax obligations or obligations relating to the prevention of money laundering and terrorist financing ("AML");

→ to know you, advise you and offer you products and services that meet your needs;

→ for the subscription of the product or service concerned;

→ for its functioning.

As such, you provide us with personal data relating:

→ to your identity (your ID number, nationality, name, address, telephone number, email address, date of birth);

→ to your family situation;

→ to your professional life (socio-professional category, field of activity);

→ to your economic, tax, property and financial situation.

You also provide us with your contact details, in particular your e-mail address and mobile phone number, so that we can send you information as part of the service provision, to make notifications such as those relating to the management of your contracts and dematerialised documents, but also if you accept it for sending commercial requests (e-mail, SMS, MMS).

Some personal data may be collected for regulatory or contractual purposes, or as a condition for concluding a contract. If necessary, you will be informed of the consequences of a refusal to disclose. For instance, refusing to provide us with information relating to your financial situation would not allow us to review your credit application.

2/ How do we collect your personal data?

We may collect your personal information when you:
• Register for Ø Crypto Union products and services
• Provide us with information when entering into a relationship
• Sign up for alerts or newsletters
• Contact us with a question or request for help
• Visit the Ø Crypto Union website
• Download, use and update ØPay mobile applications
• Participate in any rewards and promotions or surveys

3/ Use of cookies

When you register for one of our services, Ø Crypto Union sets a cookie, a small bit of code stored on your computer's hard drive that enables you to manage your subscriptions and online profile. By setting this cookie, Ø Crypto Union will remember you the next time you visit and won't have to bother you by asking questions you have already answered (like address information).

You are always free to decline cookies if your browser permits, although in that case you may not be able to use certain features on the site and may be required to re-enter information more frequently to use certain services on the website.

4/ How we use your personal data?

We may use your information for:

→ Performing the agreement for the products and services subscribed

• Provide the products and services subscribed
• Process information for the execution of the contract, or for the execution of pre-contractual measures
• Process information for the management of our relationship in particular the maintenance of your accounts

→ Provisioning & administration of services

• Process your orders and activate or deactivate services
• Enable us to process bills and payments
• Respond to enquiries and requests from you or people you have authorized
• Inform you about service upgrades, updates, advice and/or recommendations
• Provision to you of services through ØPay application

→ Market research, network & service enhancement

• Conduct market research and customer satisfaction surveys to improve our customer service; develop new products, as well as personalise the services we offer you
• Perform market analysis

→ Sharing of rewards and benefits

• Offer rewards and promotions, and share promotional benefits and loyalty programs which you may qualify for
• Determining your eligibility for rewards and promotions
• Provide updates, offers, invitations to events and deliver relevant advertising, including through voice and SMS with your prior consent or if otherwise permitted under local laws and regulations

→ Security and risk management

• Inform you of service and security issues
• Prevent and detect fraud or other crimes and recover debts
• Conduct internal audits
• Ensure the safety and security of our properties and systems
• Conduct checks against money laundering, terrorism financing and related risks

→ Legal & regulatory requirements

• Meet legal, regulatory and other requirements including providing assistance to law enforcement, judicial and other government agencies
• Conduct anti-money laundering, suppression of terrorism financing and related checks

We will not use your personal data for purposes other than what we have informed you, or which are permitted under local laws and regulations.

We will not offer, publish or share your personal data with third parties for commercial purposes, without seeking your explicit permission.

5/ How long do we keep your personal data?

Once the purposes of data processing have been achieved, and taking into account any legal or regulatory obligations to retain certain data, we delete or anonymise your data.

Depending on the purpose, the services or contracts subscribed to, and legal obligations, your personal data will be kept for a variable period of time.

For example, those used in commercial prospecting are not processed beyond three years after the end of the contractual relationship or last contact.

6/ Who are the receivers of your personal data and their location?

We share your personal data in the following cases:

→ when provided for in this privacy policy;
→ when necessary to provide you with the products and services purchased;
→ when you consent to such sharing.

Your personal data are only transmitted for relevant purposes to natural or legal persons who have a legitimate right to process them:

→ Authorized employees within the limits of their duties and missions;

→ Business partners and vendors we work with to deliver services you have registered for (e. g. credit cards, wallets, etc.);

→ Industry regulators and other government organisations, as required by local laws and regulations;

→ Financial institutions for purposes related to your account linked to Ø Crypto Union products and services;

→ Research institutions for market analysis purposes.

We will ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.

Depending on the purpose, the services or contracts subscribed to, and legal obligations, your personal data will be kept for a variable period of time.

For example, those used in commercial prospecting are not processed beyond three years after the end of the contractual relationship or last contact.

7/ How we ensure the security of your personal data?

We take the necessary technical and organisational measures, given the nature of the personal data and the risks presented by the processing, to preserve the security of your data, and in particular to prevent it from being corrupted, damaged or accessed by unauthorised third parties or to prevent any misuse of it.

In accordance with our commitments, we choose our subcontractors and service providers carefully and impose them:

→ a level of protection of personal data equivalent to ours;

→ access to and use of personal data or information strictly necessary for the services they are required to provide;

→ strict compliance with applicable laws and regulations on confidentiality;

→ banking secrecy and personal data;

→ implementation of all appropriate measures to ensure the protection of personal data that they may be required to process:
• Safeguards to prevent security breaches in our network and database systems
• Limits on access to information in our systems and the systems of our business partners and vendors
• Strict verification processes to prevent unauthorised access to information

→ definition of the technical and organisational measures necessary to ensure data security.

8/ What are your rights and how to exercise them?

You have a number of rights in relation to the information that we hold about you.

These rights include:

→ the right to access information we hold about you and to obtain information about how we process it;

→ in some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;

→ the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;

→ the right to request that we rectify your information if it’s inaccurate or incomplete;

→ in some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;

→ the right to object to, and to request that we restrict, our processing of your information in some circumstances;

→ the right to define general or specific guidelines for the storage, deletion and communication of your personal data after your death, which can be registered with a digital trusted third party. These directives may designate a person responsible for their execution, failing which your heirs will be designated.

You can exercise your rights by contacting us using the details set out below.

In accordance with our commitments, we choose our subcontractors and service providers carefully and impose them:

→ a level of protection of personal data equivalent to ours;

→ access to and use of personal data or information strictly necessary for the services they are required to provide;

→ strict compliance with applicable laws and regulations on confidentiality;

→ banking secrecy and personal data;

→ implementation of all appropriate measures to ensure the protection of personal data that they may be required to process:
• Safeguards to prevent security breaches in our network and database systems
• Limits on access to information in our systems and the systems of our business partners and vendors
• Strict verification processes to prevent unauthorised access to information

→ definition of the technical and organisational measures necessary to ensure data security.

Contacts

You can exercise your rights and send any request for information concerning your personal data:

→ By letter: Ø Crypto Union – 150 State St #1, Salt Lake City, UT 84111, USA

→ By email: [email protected]