WHAT IS YOUR PERSONAL DATA
Personal data is any information that relates to a living individual who can be identified from that information either by the information alone or together with any other information likely to come into (or already in) our possession. The obtaining, storing and use of personal data is governed by the General Data Protection Regulation 2016/679.
WHO ARE WE
We are Hashstacs Pte. Ltd. (“STACS”). Our venture STACS is a Hybrid Ledger Technology Tailored for Global Tokenised Securities. The STACS Network is a scalable ledger network layer that seamlessly stacks on top of existing financial institutions and enables the tokenisation of complete financial industry with zero inertia.
This privacy notice explains how we collect and process your personal data through and on this website (www.stacs.io).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data, please contact us at [email protected].
You have the right to make a complaint at any time to the appropriate EU supervisory authority in your place of residence (if applicable).
UPDATING YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This 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 notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT
We may collect, receive, use, store and transfer the following kinds of personal data about you :
- Identity Data including information about your identity such as name, address, date of birth, username or
similar identifier, title, gender.
- Contact Data including where you live and how to contact you including: address, email address and telephone numbers.
- Technical Data including details about the devices and technology you use including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform and other technology on the devices you use to access our website or services.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We use different methods to collect data about you including through:
- Information you give us:
- when you communicate with us whether by phone, post, email, online or by other means;
- when you use our websites or device applications;
- in emails, letters and other correspondence;
- give us feedback; and
- when you request marketing to be sent to you by us or selected third parties.
WHY WE COLLECT YOUR PERSONAL INFORMATION
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so lawfully.
|Purpose||Type of Data||Lawful basis for processing|
|To communicate with you over phone or email.||(a) Identity|
(c) Marketing and Communications
|(a)+(b) the performance of a contract with you if you have an active account on our website|
(a)+(b) A legitimate interest to answer your communication if you do not have an account on our website
( c) Consent in relation to Marketing and Communications
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(c) Marketing and Communications
|(a) Performance of a contract with you once you have partaken in the events|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)(c) Consent in relation to marketing communications
|To improve our website and products / services (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with our regulatory obligations and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To give you, or allow selected third parties to give you, information about goods and services we think you may be interested in.||(a) Identity|
(c) Marketing and Communications
|(a) Consent in relation to marketing communications|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business,to inform our marketing strategy to develop new products/services and grow our business)
WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH
As part of providing you with our services and running our business, we may disclose your personal information to:
- Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries as reasonably necessary for the purposes, and on the legal bases, detailed in this policy;
- Our agents, advisors and business partners who we use to help manage our services, improve services and resolve issues such as legal disputes;
- Government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law
- Any party linked with you or your business’s products or services;
- Organisations we introduce you to for marketing purposes; and
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
- We may disclose your personal information to the above mentioned third parties:
- If we are under a duty to disclose or share your personal data in order to comply with a specific legal obligation; and
- To enable us to run our website and offer our services to you.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH
Usually all information you provide to us will be stored or transferred outside of the European Economic Area (EEA). However, your personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC), which can by found on the EC’s website:
Binding corporate rules in accordance with Article 47 of the GDPR. Further information can by found on the EC’s website:
Where we transfer data to organisations based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see EC’s website page:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
KEEPING AND DELETING YOUR PERSONAL INFORMATION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
- 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 and to check that we are lawfully processing it.
- 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.
- 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 enables you to object 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 and freedoms.
- 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.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
- Withdraw consent. This allows you to withdraw your 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights you will need to contact us using the contact details above. In the case of exercising your right to access, you will also need to provide appropriate evidence of your identity.
NO FEE USUALLY REQUIRED
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 these circumstances.
WHAT WE MAY NEED FROM YOU
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.
We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations. The latest version of this policy will always be available on our website and we encourage to review it regularly. Any material changes may also be notified to customers by other means (such as email).