PRIVACY & COOKIE POLICY
Version 1.0
Last updated on: March 2, 2022
This Privacy & Cookie Policy (the “Privacy Policy”) is adopted by Programmable Equity OÜ (KOOS, we, us and our). We are the owner and operarator of KOOS website at www.koos.io (Website) and provide the Software for Token Issuers to issue Tokens to Token Recipients as stated in our Terms of Service.
The Privacy Policy sets out the principles of processing your personal data by KOOS when you use our Services and our Website.
If you have any questions about how we process your personal data or if you wish to submit an application for exercising your rights related to processing your personal data, please contact us through the contact information provided in the section "Contacts" below.
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Unless otherwise defined in the Privacy Policy, the terms such as personal data, data subject, data processing, controller and processor are used in the meaning given to them in Article 4 of the General Data Protection Regulation (2016/679/EU; the “GDPR”). Terms starting with a capital letter are either defined herein or in our Terms of Service.
WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?
Personal data | Provided to us | Our role |
---|---|---|
Contact details | By the Token Issuer(s) which issued you Tokens | Data processor |
Usage data | By you when you use our Website and Services | Data controller |
Identity data | By you on the request of the Token Issuer which issued you Tokens | Data processor |
WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
Purpose of processing | Types of personal data | How have we obtained personal data | Legal basis for processing | Retention period |
---|---|---|---|---|
Enabling the creation of an account with us. | First name, last name and email address and mobile number. | From the Token Issuer if you are a Token Recipient. | Performance of the contract under the Terms of Service with you – GDPR art. 6 (1) (b). After the termination of the contractual relationship with you (under the Terms of Service) - legitimate interest of KOOS– GDPR art. 6 (1) (f). | During the term of the contract with you under the Terms of Service. After the termination of the contract under the Terms of Service - three years based on our legitimate interest until the end of the limitation periods under applicable law. |
Amend, adapt and improve the Website and Services provided to you. | Usage data such as geolocation data, time zone settings, browser type and version, device type, operating system and platform. | Automatically in the course of your use of the Service. | Necessary for our legitimate interests (studying how our Website and Services is being to develop and amend our Website and Services) – GDPR art. 6 (1) (f). After the termination of the contractual relationship with you (under the Terms of Service) - legitimate interest of KOOS– GDPR art. 6 (1) (f). | During the term of the contract with you under the Terms of Service. After the termination of the contract under the Terms of Service - three years based on our legitimate interest until the end of the limitation periods under applicable law. |
Answering your inquires. | Name, e-mail and other personal data that is submitted to us directly by you also if you contact us with a query or question via Website or via any other channel (by sending an e-mail, for example). | Directly from you. | To answer your request and our legitimate interest – GDPR art. 6 (1) (b) and GDPR art. 6 (1) (f). | Until the end of the limitation period of the claim related to which the inquiry is submitted. Generally, such term is three years. |
Provision of marketing content. | E-mail address; statistics concerning your use of the Services and the Website. | Directly from you; statistics concerning your use of the Services and the Website is collected by KOOS. | Your consent - GDPR art. 6 (1) (a). | Until the withdrawal of the consent. |
WHEN DO WE SHARE YOUR PERSONAL DATA?
HOW LONG IS YOUR PERSONAL DATA RETAINED?
HOW DO WE PROTECT YOUR PERSONAL DATA?
To protect your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, we use appropriate technical and organisational measures that comply with applicable laws. These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.
COOKIES
Our Website uses cookies. This section incorporates our cookie policy (the Cookie Policy) that applies when you use our Website.
Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Website and your experience when using our Services. We can use cookies to see which areas and features are popular and to count visits to our Website to recognise you as a returning visitor and to tailor your experience of the Website according to your preferences. We may also use cookies for targeting or advertising purposes.
We use statistics cookies that record information about the way our Website is used, to acquire knowledge on how often our Website is visited, where on our Website our visitors spend the most time, how often they interact with a page or part of a page, this allows us to make the structure, navigation, and content of our Website as user-friendly as possible.
The specific cookies that our Website uses are the following:
Cookie | Description | Duration | Type |
---|---|---|---|
_ga | Registers a unique anonymous ID that is used to generate statistical data on how the visitor uses the website. | 2 years | Statistics cookie |
ga# | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit | 2 years | Statistics cookie |
You can delete or block cookies on Website through your browser settings at any time. However, some cookies might be necessary for the functionality of Website. Therefore, you understand that when blocking or deleting the cookies some features of Website might not function correctly.
For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org.
In case you have any question concerning Cookie Policy, you may contact us via contact details provided below.
YOUR RIGHTS
CONTACTS
If you have any questions about this Privacy & Cookie Policy or if you have any concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail or in writing using the following contact information:
Name | Programmable Equity OÜ |
---|---|
Address | Harju maakond, Viimsi vald, Miiduranna küla, Kristjani tee 4, 74015 |
info@koos.io |