Version 1.1 – 15 October 2018
2. What information does IPSX collect?
We collect Personal Data and Anonymous Data, as described below.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, photographs, company name, and password when you use our Site.
- We may also collect other Personal Data provided by third party identity verification services or via social networking websites. We do not control these third-party websites and we encourage you to read the privacy notice of every website you visit.
- If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
- Certain services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- We also collect other types of Personal Data that you provide to us voluntarily when seeking support services, such as email, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
- We may collect other data, including but not limited to, referral URLs, your location, blockchain analytics information related to blockchain addresses you provide.
Some information is collected automatically by our servers:
- Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol address, domain name, and/or a date/time stamp for your visit.
- As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data.
- We recommend, however, that you do not deactivate our cookies. Keep in mind that if you block, turn off or reject our cookies, our Site will not display correctly or you will no longer be able to use some of the services we offer. In this case, we cannot be held liable for any consequences related to the reduced functionality of our services arising from our inability to store or consult the cookies required for its functioning and which you have declined or deactivated.
- We retain information on your behalf, such as transactional data and other session data linked to your Account.
Children merit specific protection with regard to their Personal Data, as they may be less aware of the risks. The Site is for use by adult persons who have the capacity to conclude a contract under the legislation of the country in which they are located.
If you are under 18, you cannot use our Services. We do not knowingly solicit or collect information from or promote or market our Services to anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we shall delete it immediately. If you believe that we have mistakenly collected a child’s Personal Data, please notify us by using the contact details provided hereunder.
3. How does IPSX use the information it collects?
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you and perform identity verification through a service provider;
- provide improved administration of our Site and Services;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
- identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
- notify you about important changes to our Terms; and
- where applicable, comply with the legal provisions in force
All data collected automatically will be used to administer or improve our services.
- We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
We may create Anonymous Data records from Personal Data by irreversibly excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyse request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
IPSX does not sell User data to any third party.
We may from time to time use your personal data in order to send you marketing materials about products or services provided by IPSX that we think you may be interested in but we shall always give you the opportunity to easily opt-out of any such communications. You can opt-out of receiving marketing communications from us by contacting us at firstname.lastname@example.org or, in respect of emails, by clicking unsubscribe on the relevant email.
5. How does IPSX share my personal information?
- You acknowledge and accept that in order to use the Services, when you seek to enter into contractual relations with another User (IP Provider / IP Requester), it is necessary for us and the relevant User to process some of your Personal Data (for example, for billing purposes, your identification information).
- It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of IPSX, our users, or the public.
- We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of Accounts; to provide technical support; to verify your identity; and/or to provide other services to you. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
IPSX may contain links to other third party websites which are regulated by their own privacy policies which we strongly advise you to read. IPSX is not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Site.
6. How can you update your information?
You can update your information by accessing the “Profile” section of your Account or by contacting us at email@example.com and making a request.
We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account you can access the “Settings” section of your Account and follow the “Delete Account” procedure or contact us at firstname.lastname@example.org and make a request. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
7. Storage period of your Personal Data
We will store your data only for as long as necessary to fulfil the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.
We implement reasonable technical and organizational security measures to ensure security and confidentiality in processing your Personal Data.
To this end, we take all necessary precautions given the nature of the Personal Data and the risks related to its processing, in order to maintain data security and in particular to prevent distortion, damage or unauthorized third-party access (authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.). We also request that our third-party service providers use commercially reasonable security measures to protect your information from unauthorized access or use.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:
Request access. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request".
Request correction. 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 need to add or change any information, you can log into your Account and make the change in your settings. If it does not look like you can make the change on your own, please send us an email at email@example.com.
Request erasure. 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 applicable law.
You understand and accept that when sharing your device’s IP address or as a company sharing a full range of unused IPs in order to receive real-time IPSX utility tokens, all connections may be logged in the blockchain.
What constitutes “erasure” is still open to debate. Some data protection authorities have found that irreversible encryption constitutes erasure. In a blockchain environment, erasure is technically impossible because the system is designed to prevent it. However, IPSX using also the blockchain technology will contain mechanisms governing access rights. Therefore, IPSX will ensure to revoke all access rights, thereby making the content invisible to others, albeit not erased.
Your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request.
Object to processing. You have the right to object to the processing of your Personal Data 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. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:(i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to delete it; (iii) 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 (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request to transfer. If you ask us, we will provide 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.
Withdrawal of consent. This applies 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.
Lodge a complaint to the competent supervisory authority. If you have a privacy-related complaint against us, you may seek further recourse by contacting the local relevant data protection authority.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org. We may need to request specific information from you to help us confirm your identity and ensure your rights 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
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
10. Contacting us