Section 1 – SCOPE OF POLICY
1.1 This policy together with the General Terms of Service and our Business Terms of Service and our Business Terms (as applicable) apply to your use of:
- a) our website at https://immvr.se (the “Site”) including, without limitation,
- b) the “ICO Dashboard” at https://ico.immvr.se/user/login available to ImmVRse ICO Dashboard Users pursuant to the Business Terms;
- c) any of the services accessible through the DApp or the Site (the “Services”).
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
The parent company of ImmVRse, VRtualise Ltd are the data controller responsible for your personal data and we are registered data controller with the Information Commissioner’s Office, reference number ZA246772.
Data Protection Officer
We have appointed a data protection officer (“DPO”). Our DPO has a number of important responsibilities including:
- Monitoring ImmVRse’s compliance with the GDPR and other data protection laws;
- Raising awareness of data protection issues, training ImmVRse team members and conducting internal audits; and
- Cooperating with supervisory authorities such as the ICO on our behalf.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us.
As a resident of UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Age of Consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependent to use this site. As our ICO investor, we will only accept people who are deemed as an adult (18 and over) in UK jurisdiction.
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private.
- Never sell your data to a third party.
- Allow you to manage and review your marketing choices at any time.
- Separate email lists based on preferences and interests.
Section 2 – COOKIES
Section 3 – INFORMATION WE COLLECT ABOUT YOU
3.1 We will collect and process the following data about you:
- a) Information you give us “Submitted Information”: This is information you give us about you by filling in forms on the site. We will not add you to our mailing list if you are only contacting with us and not signed up to receive updates. If you contact us, we will keep a record of that correspondence.
We are planning to conduct our ICO in coming months, therefore we are collecting information for two reasons:
- People who are interested to participate in the ICO
- Users who are interested to participate in the early alpha testing program
- Readers who are interested to receive updates from ImmVRse
Case 1 – Interested to participate in the ICO:
The participants are required to register an account with the ImmVRse Dashboard. The information you give us may include your name, address, date of birth, e-mail address, phone number, the device’s phone number, username, password and other registration information, financial, details of your wallet address, e.g. Ethereum or bitcoin address, or bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
a) Information we collect about you and your device. Each time you visit the Dashboard or our Site we will automatically collect the following information:
- technical information, including automatically receive your computer’s internet protocol (IP) address to provide us with information that helps us learn about your browser and operating system, except when you are on VPN.
- information about your visit, including the full uniform resource locators (alternatively known as browser URL), clickstream to, through and from our site (including date and time), services 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), methods used to browse away from the page, device information, most of which are used to process data using Google Analytics;
- transaction information including date, time, amount, currencies used including cryptocurrencies; and not limited to exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
b) Information to help us deliver our service to you. We work closely with third parties to help us deliver our Service to you. These third parties are business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and third-party developers. To validate Know Your Customer (KYC), the registered participants are required to submit their IDs to claim their purchased tokens. Our legal team may cross check and verify information; thus we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your transaction with ImmVRse.
Section 4- USERS OF YOUR INFORMATION
4.1 Below is a summary of the key types of data that we make use of as part of the ImmVRse Services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:
(a) Submitted Information: We will use this information:
- to carry out our obligations arising from participating in the ICO, which you enter with us through the ICO Dashboard, or to provide you with the information, products and services e.g. ImmVRse DApp that you request from us;
- to provide you with information about ImmVRse DApp when you agree to sign up for Alpha Trial;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
- to notify you about changes to our service;
(b) ICO Dashboard and Site Information: We will use this information:
- to administer our Site and the ICO Dashboard for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Site and ICO Dashboard safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them;
- to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
- to comply with our regulatory obligations.
(c) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
- to help us better understand you so that we may make decisions about how we manage your ImmVRse Account;
- to process applications for products and services available through us including making decisions about whether to agree to approve any applications; and
- for the purposes set out above (depending on the types of information we receive).
4.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
For example, in order to verify suspicious identity, in rare cases we may use credit reference agencies to carry out searches on you to comply with KYC and Anti-money Laundering (AML) regulations in the UK. The use of credit reference agencies and fraud prevention agencies is not limited to such agencies based in the United Kingdom and includes such agencies overseas. Any such search under this section may leave a footprint on your credit file. You acknowledge that we may carry out such credit search in the knowledge that it may leave a footprint on your credit history. If you would like details of the credit reference and fraud prevention agencies from which we have obtained or may obtain information about you, please contact us. You can withdraw your consent to be credit searched at any time by contacting a member of our support team.
4.3 If we decide to engage advertisers to promote our initial coin offering, products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users. In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
Purposes for which we will use your personal data
4.5 We have set out below, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. Here’s a detailed description of “what we use your information for – our legitimate reasons”:
- Carry out our obligations arising from ICO transactions you enter into with us – to fulfil our legitimate legal duties
- Combat against fraud – to comply with regulations that apply to us in the United Kingdom
- Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you – understand you better to suggest the ads that are relevant to you
- Administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer – developing existing product for better efficiency.
Section 5- MARKETING
5.1 We want to make it clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
PROMOTIONAL OFFERS FROM US
5.2 We may use your personal data (such as your Submitted Information, or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
5.3 You will receive marketing communications from us if you have signed up to and/or utilise the ImmVRse ICO or ImmVRse services and, in each case, you have not opted out of receiving marketing notifications.
5.4 We will obtain your express opt-in consent before we share your personal data with any company outside of ImmVRse for marketing or promotional purposes.
Section 6- DISCLOSURE OF YOUR INFORMATION
DATA PROCESSING PARTNERS
6.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by ImmVRse.
6.2 We send personal data to the following sets of data processors in order to perform the ImmVRse Services:
- Fraud prevention agencies – This is in order to comply with Anti-money laundering (AML) regulation in the UK, verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
- Cloud storage providers – hosted on 20i Inc. They provide us with the online platform that allows us to sell our services to you. Your data is stored through 20i’s high-speed SSD data storage and databases. They store your data on a secure server behind a web application firewall;
- Cloud Data and DDoS protection – Cyber crime prevention software, namely Cloudflare Inc., that provides protection against cyber threats, e.g. Distributed Denial of Services (DDoS) or a brute force attack;
- Banking and ICO services partners – Financial services providers, including ICO Dashboard built by the company “TokenGet”, located in Bulgaria. As a company located in the EU, TokenGet are following GDPR compliance. TokenGet is also helping us provide the ImmVRse Services including banking intermediaries and international payments services providers;
- Advertisers and analytics providers – Google Analytics and similar connected accounts e.g. Google AdWords. If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymity of personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users in some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience;
- Search Engine Marketing – We also use analytics and search engine providers that assist us in the improvement and optimisation of our site;
6.3 We may also disclose your personal information in the following circumstances:
- If ImmVRse 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 or regulatory obligation or request.
- In order to:
- enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
- protect the rights, property or safety of ImmVRse, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
THIRD PARTY SERVICES PARTNERS
6.5 From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside of ImmVRse for these purposes.
6.6 You can withdraw your consent at any time after giving your explicit opt-in consent by contacting our support team and letting us know.
Section 7 – STORAGE & CYBER SECURITY
7.2 All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology, certificate provided by Cloudflare Inc. or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Our cyber security partner Entersoft-Segasec will work alongside ImmVRse to protect it’s users to prevent cyber attacks.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
Section 8 – RETAINING YOUR INFORMATION
8.1 ImmVRse is obligated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) to retain personal data about you and your ImmVRse ICO Transactions for a period of five years. We use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 5 years after the termination of our business relationship. If you are not a part of ImmVRse ICO or ImmVRse DApp alpha trial, and signed up via website only to receive updates, you can unsubscribe anytime to terminate contractual relationship with ImmVRse. In such cases, we will remove your information (primarily email address) from our database.
Section 9 – YOUR LEGAL RIGHTS
9.1 You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request“).This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team.
- Request correction of the personal data that we hold about you.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team.
- Request erasure of your personal data.This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data.This is in situations 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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the ImmVRse Services and it is likely we will have to terminate your account.
- Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the ImmVRse Services). In this case, we may have to cancel your use of the ImmVRse Services but we will notify you if this is the case at the time.
- Request the transfer of your personal data to you or to a third party.We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the ImmVRse Services to you. We will advise you if this is the case at the time you withdraw your consent.
NO FEE USUALLY REQUIRED
9.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in circumstances where we may feel that your requests are excessive.
WHAT WE MAY NEED FROM YOU
9.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
9.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
IF YOU FAIL TO PROVIDE PERSONAL DATA
9.5 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the ImmVRse Services). In this case, we may have to cancel your use of the ImmVRse Services but we will notify you if this is the case at the time.
10.3 If you have a concern about the way we handle your personal information, you have a right to lodge a complaint. For further information, please contact our Data Protection Officer at [email protected]
For more information on the process, please visit the website of the Information Commissioner’s Office regarding raising concerns.