Welcome to the TokenQuest platform (“we”, “us” or “TokenQuest”). TokenQuest is developing an ecosystem which consists of various innovative developments and applications (“Services”). The TokenQuest platform is accessible on www.tokenquest.org and any other sites or subdomains of TokenQuest (“Site”).

To provide our Services we may collect some of your data some of which may under certain circumstances be considered personal information. We at TokenQuest are committed to fully protecting your privacy and being a responsible and transparent custodian of the information we collect.

Therefore, please find all the necessary information on how we may collect and process your personal data gathered in connection with your use of our Site and our Services in this Privacy Notice.

Notice: Please, read this Privacy Notice carefully and in addition to the Terms and Conditions to understand our practices regarding the information that may be considered personal. If you do not wish for your personal information to be used in the manner described herein, you should not access our Site and all subdomains thereof, utilise our Services, participate in the offering of our tokens or otherwise provide TokenQuest with your information which may be considered personal.

Please ensure that any relevant individuals are made aware of this Privacy Notice prior to providing their information to us or us obtaining their information from another source. In such a case, you or they must first ensure that you or they have the authority and appropriate legal basis to do so.

We do not knowingly collect or ask for data, including personal information, from people under the age of 18. If you are such a person, please do not use our Service or send us your data. Otherwise be informed that we erase such data the moment we learn it is collected from a person under the age of 18.

 

Who processes your data?

The administrator of our Site, provider of the Services and thus controller of your personal information processed in connection for purposes described hereinbelow is TokenQuest.

If you have any questions regarding our privacy policy or data protection, feel free to contact us through our contact form.

We will usually respond to all legitimate enquiries within 30 days. Occasionally it may take us longer if your request is particularly complex or you have made numerous requests. We will notify you and keep you updated.

 

What types of information may be collected?

‘Personal information’ is any information that, either alone or in combination with other data, enables an individual to be directly or indirectly identified (for example, name, email address, contact details, or any unique identifier such as an internet protocol address (‘IP address’), device ID or other online identifier).

We may collect the following basic personal information from you:

  • various information voluntarily provided to us when you communicate with us via e-mail, on social media or other channels, when you register for our updates and when you respond to our communications or requests for information (for example, your name, contact information, title and other personal information about you);
  • your wallet address, any other cryptocurrency wallet address or bank account details and any related transaction details recorded by any blockchain on which our tokens are based or utilised for due provision of our Services to you;
  • your IP address and other online identifiers while using our Site; and Cookies utilised by our Site in a manner described hereinbelow.


Cookies and similar technologies

Similar to other websites, our Site utilises browser cookies (small text files stored on a user’s web browser when you visit a website), web beacons and similar tracking technologies (collectively, Cookies) to collect and store certain information on how you use, access, or interact with our Site. We may, for example, use Cookies to collect information about the type of your device you use to access the Site, your browser type, your IP address or other identifier, your general geographic location as indicated by your IP address, features you access on the Site, whether and how you interact with content available on the Site.

We use Cookies to remember your preferences and settings, to remember information that you may enter online, to generate aggregate statistics about how people use our Services, to help you share content with others and to improve your experience of the Services.

You can choose how Cookies are handled by your device through your browser or through our cookie banner, including refusing or deleting all Cookies. If you choose to receive no Cookies at any time, websites may not function properly and certain services may not be provided. Each browser and device is different, so check the settings menu of the browser or device you are using to learn how to change your advertising settings and Cookie preferences.


Information we may collect from third party sources

We may receive information about you from other sources, including third parties that can lawfully share the information with us and help us update, expand, and analyse our records, prevent or detect fraud or other suspicious activities and process payments. In addition, our Site may also include integrated content or links to content provided by third parties (such as live chat, social media content, plug-ins and applications).

Please be informed that we do not process special categories of personal data (such biometric data, data concerning health, racial or ethnic origin, political opinions, etc.).

We do not use either automated decision-making or profiling in terms of your personal information you provide to us.


How may we use the data we collect?

We may use the information gathered primarily for the following purposes:

  • to provide you with our Services and other services that you request including, as applicable, supplying, and processing your payment for our tokens and any other Services to be provided to you on our Site;
  • to respond to your enquiries or to any problems that may arise (such as difficulties in purchasing our tokens, navigating our Site or accessing certain services or features);
  • to make payments to you;
  • to inform you of important changes or developments to our Services or policies and to provide you with technical, support or administrative notifications.


Fulfilment of legal requirements

We may also use the information we collect:

  • to conduct know-your-client and anti-money laundering and other sanctions checks (or to verify those carried out by third party sources) if we are required to do so by law; and
  • as is necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory, arbitration or government process or requests for information issued by respective government authorities.

Development of our Services

  • to send you marketing communications, and other information or materials that may be of interest to you
  • to maintain our list of contacts for purpose of such communication;
  • to understand how people use our Site, including by generating and analysing statistics and user trends, and to evaluate, administer, maintain and improve our Site and Services;
  • for internal development of new products or services;
  • for our internal business purposes, including data analysis, invoicing and detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement; and
  • to assess the effectiveness of our promotional campaigns and publications.

Protection or enforcement of rights

  • to protect or defend your rights and legitimate interests;
  • to protect our or any third parties’ rights and legitimate interests;
  • to enforce our or any third parties’ claims; and
  • to deal with any other respective dispute, if necessary.

Enhancing our Services with aggregated data

  • we may aggregate personal and other data captured through our Site so that the data is no longer capable of identifying any individual;
  • we reserve the right to use this aggregated information for the purposes of improving and enhancing our services, generating insights, for use in marketing and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be personal information for the purpose of this Privacy Notice.

We retain the information we collect for no longer than is reasonably necessary to fulfil the above purposes and to comply with our legal obligations.

What legal grounds do we rely on?

Your personal information as described above is processed by us on a basis of the following legal grounds:

Taking steps prior to entering into a contract and necessity for performance of a contract with you – We may need to collect and use your personal information in order to enter into a contract with you or to perform a contract that you have with us, for example, when you provide personal information to us in order to purchase our tokens, if necessary for such purchase.

In such a case, the provision of your data is necessary in order to enter into a contract and also a contractual requirement as without such data we are not able to enter into a contract with you.

Compliance with legal obligations – We may process your personal information as may be required by respective legal or regulatory obligations that may apply to us.

In this case, the provision of your data is a statutory requirement without which we are not able to comply with our legal obligations.

Our legitimate interests – We may use your personal information for our legitimate interests to improve our Services, thus maintain and develop our business activities as well as to protect and enforce our or third party’s rights, if necessary.

Please be informed that you have the right at any time to object to the processing of your personal information which is based on our or third party’s legitimate interest.

Your consent – We send to you direct marketing e-mails upon your previous consent. Each such e-mail also contains a link that allows you to opt-out from receiving such e-mails, update your contact information or change your preferences at any time.

To withdraw any consent to processing your personal information, please use our electronic form or by clicking on a link provided in every e-mail sent to you to unsubscribe from such marketing electronic communication.

How may we share the information we collect?

We may disclose information:

  • to our current or future affiliated companies, their respective parent companies, subsidiaries or joint ventures, if sharing the data with them is necessary to fulfil the purpose of the data processing. These companies may process such data as a processor on our behalf and we will ensure that such activities are subject to contractual obligations on privacy, security and other matters in accordance with this Privacy Notice;
  • to our partners and third-party service providers that perform certain services to use on our behalf (for example, marketing companies, web-hosting companies, analytics providers and information technology providers). In these circumstances contractual and other technical and security safeguards will be put in place with the partner or service provider, including to ensure that your personal information is processed only in accordance with this Privacy Notice;
  • to law enforcement, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us. In these circumstances, we will take reasonable efforts to notify you before we disclose your information, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances;
  • to service providers, advisors, potential transactional partners, or other third parties in connection with the completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. Upon completion of such a transaction, your personal information will continue to be processed in accordance with this Privacy Notice, except as otherwise agreed by you or permitted by applicable law;
  • to partners, financial institutions or service providers who may request such information in connection with providing services to us, including banking services, and only where we enter into an agreement with such institutions to limit their use and handling of personal information in accordance with this Privacy Notice.

Important note: We do not sell, rent, or otherwise share personal information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your prior separate consent. We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

When you voluntarily make your personal information available online in our environment shared by third parties (for example, on messaging applications, social media, message boards, web logs, or emails), that personal information may be viewed, saved, collected, heard, used and/or shared by third parties outside of TokenQuest. We are not responsible for any unauthorised third party using such information. Please be mindful whenever you share any information in such environments.

Our Site may include integrated content or links to third parties’ content (for example, social media content, plug-ins and applications, video materials, etc.) which are governed by the third parties’ privacy settings and policies, which may differ from this Privacy Notice. This Privacy Notice does not address, and we are not responsible for or able to control, the privacy, security, or other practices of such third parties.

How do we protect your information?

We deploy organisational, technical and physical safeguards designed to protect the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your personal information that they will protect the information with safeguards designed to provide a level of protection equivalent to that adopted by TokenQuest.

We may store the information we collect on our servers both cloud-based or in servers located in countries where we or our service providers have facilities. Therefore, we may transfer information to countries outside of your country of residence which may include countries outside the EU member states.

Please note that if you are the EU citizen and provide us with your personal information, it may then be transferred for the purposes stated herein to third countries outside the EU/EEA under conditions set in this Privacy Notice and you consent to this by using our Site or Services.


What are your rights?

You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Therefore, the marketing e-mails we send to you include the opt-out link for you to unsubscribe from receiving such communication (as well as update your contact information). We will honour your choice and without delay refrain from sending you such e-mails.

Under local law, you may have certain rights regarding processing of your personal information, in particular, you have the right to request: (i) access to your personal information, (ii) rectification or erasure of your personal information, (iii) restriction of processing concerning you, (iv) objection to processing that is based upon our legitimate interests (as already stated above), and (v) data portability to other service providers.

We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with a respective supervisory data protection authority, as applicable, in your jurisdiction.

If you would like to contact us, please use the methods stated above.

Your ability to exercise these rights will depend on a number of factors and, in some instances, we will not be able to comply with your request, for example because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular information we hold on you. Where so entitled to access to your personal information, you will not have to pay a fee unless your request is clearly unfounded, repetitive or excessive (upon which we may charge a reasonable fee or refuse to comply with your request). If you would like to discuss or exercise the rights you may have, you can contact us through the methods stated above.

Please keep us informed if your personal information changes whilst we continue to retain such information. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date.


Final provisions

We may update this Privacy Notice from time to time and we encourage you to periodically review this Privacy Notice. If we make any material changes to this Privacy Notice regarding the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes on the Site or, if we hold your email address, by email.

The use of certain of our Services may also be governed by other applicable terms and policies regarding privacy and the sharing of personal information, which supplement, and should be reviewed alongside, this Privacy Notice.

Unless otherwise defined in this Privacy Notice, terms used have the same meaning as in the Terms and Conditions.

Last Updated Date: 28 Jan 2024