Last edited: March 22, 2022
1. Who We Are
ACNFinancial is the largest full-service blockchain technology company in the world. We develop and deliver cutting-edge software and hardware solutions necessary for businesses, governments, organizations, and individuals to securely move assets across the blockchain.
Our expertise ensures successful, easy, fast, secure, and cost-effective connectivity to the blockchain. ACNFinancial is dedicated to advancing the blockchain community. Learn more about our bold leadership in bringing blockchain technology to the world. We have determined our respective responsibilities for compliance with our obligations under applicable privacy legislation for processing your personal data concerning our global processing activities through an arrangement between you and us.
In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal data or to withdraw your consent, or if you have any questions about the processing of your personal data, you can contact ACNFinancial and Investments Group. in accordance with par. 11 ‘How to Contact Us’. ACNFinancial ensures that you can exercise your rights and that your questions will be handled within a reasonable time frame.
2. Types of Information Collected
When you visit our website to read or browse through website material or to download information, we may collect and process the following categories of personal data:
a. Name, address, telephone number, e-mail address and other contact information. You may choose to write to us, or fill out certain forms or online data requests, which provide your name, address, telephone number and/or e-mail address, and related information. We may use this information to respond to your questions and requests. b. Our communication with you.
When you send us an e-mail or otherwise communicate with us online (for example, via social media), we register your communication with us.
When you are a customer of us, we also collect data for the purpose of order processing, pricing, and other information related to your order history.
e. Information in relation to social media. We are active on various social media platforms such as LinkedIn, Facebook and Instagram.
3. Collection of Information
We collect the mentioned above categories of personal data in the following ways: a. We collect data you provide to us.
When you communicate with us via e-mail, online or social media, when you place a purchase order, when you share personal preferences with us, we collect data directly from you.
b. Sometimes, companies we co-operate with also share your data with us. We provide certain services in co-operation with other companies (that our group of companies, which work together in processing your orders). These companies share your personal data with us if necessary for services provided to you. We also share your personal information with these third parties (please see par. 6 ‘Information Sharing’ below).
c. Depending on your social network settings, we may receive information from your social network provider (please see above). For example, when you follow us via social media platforms, such as LinkedIn, we can receive personal data of these platforms related to your profile.
4. Use of Information Collected
The main purposes for which we use your personal information are:
a. To communicate with you. If you send us an e-mail or communicate with us online or via social media, we process your data to respond to you. b. For statistical research.
We use automatic tools (such as cookies) to perform statistical research into general trends regarding the use of this website and the behavior of the website’s visitors to improve this website.
c. For record keeping and to comply with statutory obligations. We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations.
d. To process your order. If you place an order on this website, we work on your data to process your order.
5. Legal Basis
We collect, use and store your personal data to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party, for the execution of an agreement, or on the basis of your consent. If we process your personal data on the basis of your consent, you may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available) or by contacting us (please see par. 9 ‘Your Rights’ below).
If you refuse to provide personal data that we require for the execution of an agreement or compliance with a legal obligation, we may not be able to provide all or parts of the products or services you have requested from us. For example, when you lost the order details of an order you placed in the past and refuse to provide information related to this order, we may not be able to provide you with a copy of the agreement because we are not able to find the order in our systems.
When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may, for example, include security and safety purposes, to improve this website, or to provide better products and offers to you.
For more information on these interests, please see the purposes, for which we process your personal data above. More information on the balancing tests we perform is available upon request. Where we process your personal data for our legitimate interests or the third-party interests, you have the right to object at any time on grounds relating to your particular situation (please see par. 9 ‘Your Rights’ below).
Where we process your personal data for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data were initially collected. More information on this assessment is available upon request (please see par. 9 ‘Your Rights’ below).
6. Information Sharing
Generally, we do not sell or share your personal data with anyone outside the ACNFinancial group. However, we do disclose or share data with the following categories of recipients for the following purposes. a. For the support services we involve.
We use third parties for support services to this website, such as IT suppliers (for example, SalesForce CRM system for processing your orders), social network providers, marketing agencies, credit and charge card companies and anti-fraud screening service providers. All such third parties will be required to adequately safeguard your personal data and only process it by following our instructions.
b. Statistical research. For statistical research we make use of third-party software such as Google Analytics or social media platforms. These platforms also have access to the data they collect. For example, when you accept cookies for this website, we analyze cookie data for statistical research via Google Analytics.
c. Group companies. When you use one of our services, it is possible that we share data with one of our group companies. For example, when you send us an e-mail about a subject that falls under the responsibility of one of our subsidiaries, we will forward your question to the correct subsidiary.
d. Ownership of ACNFinancial changes. If ownership of ACNFinancial changes as a result of a merger, acquisition, transfer, sale of assets, reorganization or bankruptcy your personal data may be transferred to the successor entity. e. Public authorities.
If we are required to by law, we also collect and share your identifying information with public authorities or governmental organizations.
Third-party websites. This website contains links to third-party websites; if you follow these links, you exit our website. While these third-party websites are selected with care, we cannot accept liability for the use of your personal data by these organizations. For more information, please consult the privacy statement of the website you are visiting (if such a statement is provided).
7. Security and Retention
ACNFinancial ensures that your personal data are properly secured by appropriate technical and organizational measures, so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.
8. International Transfer of Your Data
ACNFinancial may transfer your personal data to countries other than your country of residence (including countries outside the European Economic Area). International transferring occurs in the course of providing your services or because our group companies, partners or service providers have operations in countries across the world. The laws of these countries may not afford the same level of protection to your personal data.
In the course of providing your services or because our group companies, partners or service providers have operations in countries across the world, we may transfer your personal data to Georgia, China, Russia, United Arab Emirates, Ukraine, the United Kingdom and United States of America.
The European Commission has determined that certain countries outside the European Union offer an adequate level of data protection (see article 45 General Data Protection Regulation (GDPR)).
ACNFinancial ensures that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, ACNFinancial may use European Commission approved Standard Contractual Clauses as safeguards (see article 46 General Data Protection Regulation (GDPR)). Contact us to obtain a copy.
9. Your Rights
You may contact us (please see par. 11 ‘How to Contact Us’ below) to exercise any of the rights you are granted under applicable data protection laws, which includes (1) the right to access your data, (2) to rectify them, (3) to erase them, (4) to restrict the processing of your data, (5) the right to data portability and (6) the right to object to processing.
1. Right to access You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.
2. Right to rectification You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
3. Right to erasure You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds a place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). The certain cases include situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.
4. Right to restriction of processing You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continue storing your personal data. We will inform you before the restriction is lifted.
5. Right to data portability Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.
6. Right to object. You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground constitutes the legal basis for processing (see par. 5 ‘Legal basis’ above).