Privacy Policy
Last Updated: August 21, 2018

This Privacy Policy explains how VTOS FOUNDATION S.A. de C.V. (“VTOS”, “us” or “we), an incorporated company with variable capital, established in MEXICO under the Registration number-VFO180306SW3, having its registered office at Antioquia 307, San Pedro Garza García, Nuevo León, Mexico; postal code 66274, uses personal and other types of information we collect from our clients (“you”) when you visit our website vtos.io (the “site”). This policy does not apply to the practices of companies not owned or controlled by VTOS or to people whom VTOS does not employ or manage. If you do not agree with our practices, please do not use our site.

Types of information we collect

  • Personal Information: We collect personal information you provide to us. We define personal information as information that allows someone to identify or contact you, including, for example, your name and email address (“personal information”). If you reside outside the United States, you understand that your personal information may be processed in countries (including the United States) where laws regarding processing personal information may be less stringent than in your country. We may collect the following types of information:

    • Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
    • Formal Identification Information: Tax/ other ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
    • Employment Information: Office location, job title, and/or description of role.
    • Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
    • Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.

  • Aggregate and Anonymous Data: Aggregate and anonymous data is information that does not identify you specifically, including data collected automatically when you enter our Site(“Non-Personal Data”). This may include cookies, pixel tags, web beacons, browser analysis tools and web server logs. This may also include information from the devices you use to access our Site or mobile platform, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Site. If such information is supplied by your browser, we may also collect information about a website you were visiting before you came to our Site and any website you visit after you leave our Site. Non-Personal Data also includes some data collected by location services.

How We Use Personal Information and Non-Personal Data

We use Personal Information and Non-Personal Data to:

  • Build, operate and improve our site;
  • Inform you about the progress of our ICO and the development of our platform;
  • Perform user analytics;
  • Provide customer support and communications;
  • Manage our everyday business needs such as Site administration, analytics, fraud prevention, or to comply with the law.

How We Use Personal Information and Non-Personal Data

Except as provided herein, we will not display on the site, or otherwise disclose your personal information to any third parties unless it is necessary to provide the services, when required by law, or if we have good faith belief that such action is reasonably necessary to: (a) comply with current judicial proceedings, a court order or legal process served on us; (b) protect and defend our rights, property and interests, including by enforcing our agreements and policies;(c) respond to claims that any submitted content violates the rights of third parties; (d) respond to your requests for customer service; (e) protect the rights, property or personal safety of VTOS, its members and the public; (f) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; or (g) with your consent to share the information.

We may share Non-Personal Data with analytics companies to learn information about how our users interact with the site. This enables us to optimize our Site and improve our efforts. See also “Third Party Analytics” below.

We will never sell your Personal Information or Non-Personal Data.

Your choices

You can unfollow us or opt-out of receiving our emails by contacting us at [email protected] We will retain your information only for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security of Personal Information

We employ generally accepted industry standards to protect your personal information and we continuously strive to protect your information and privacy as much as we can. Unfortunately, no data transmission over Wi-Fi or the Internet can be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online.

To maintain KYC-principles

We have acquired the professional services of a third party (Sum&Substance, https://sumsub.com) to verify your identity by comparing the personal information you provided against third-party databases and public records. Any transfer of personal data shall be made under user’s consent.

Third Party Analytics

This privacy policy only addresses the use and disclosure of information by VTOS. We may use analytics services to help us analyze the information we have collected from you. These analytics services may use cookies, web beacons and other devices and technologies to track traffic data. Data that they collect typically includes, but is not limited to, your IP address, your ISP, the browser you use to visit our Site. This Privacy Policy does not apply to, and we are not responsible for, such technologies placed by third party analytics services.

VTOS primarily collects personal data about you from you. From time to time, we may, however, also collect data about you from third party sources, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.

We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, status on any sanctions lists maintained by public authorities, and other relevant data.

YOUR RIGHTS

Your individual rights

You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.

Right Information and access
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source) and this Privacy Policy intends to provide the information. Of course, if you have any further questions you can contact us on the above details.

Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information that you provided. You may also request that we restrict the processing of that information. The accuracy of your information is important to us. If you do not want us to use your personal information in the manner set out in this Privacy Policy, or need to advise us of any changes to your personal information, or if you would like any more information about the way in which we collect and use your Personal Information, you can contact us at [email protected]

Right to erasure (right to be ‘forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:io

  1. The personal information is no longer necessary for the purpose for which it was collected;
  2. You withdraw your consent to consent based processing and no other legal justification for processing applies;
  3. You object to processing for direct marketing purposes;
  4. We unlawfully processed your personal information; and
  5. Erasure is required to comply with a legal obligation that applies to us.
However, when interacting with the blockchain we may not be able to ensure that your personal data is deleted. This is because the blockchain is a public decentralized network and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances we will only be able to ensure that all personal data that is held by us is permanently deleted.

We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
  1. Exercising the right of freedom of expression and information;
  2. Complying with a legal obligation under EU or other applicable law;
  3. The performance of a task carried out in the public interest;
  4. Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
  5. The establishment, exercise, or defense of legal claims.

Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:

  1. You contest the accuracy of the personal information;
  2. Where processing is unlawful you may request, instead of requesting erasure, that we strict the use of the unlawfully processed personal information;
  3. We no longer need to process your personal information but need to retain your information for the establishment, exercise, or defense of legal claims.
You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the services we can provide and we will explain this to you if you decide to exercise this right.
However, when interacting with the blockchain, as it is a public decentralized network, we will likely not be able to prevent external parties from processing any personal data which has been written onto the blockchain. In these circumstances we will use our reasonable endeavours to ensure that all processing of personal data held by us is restricted, notwithstanding this, your right to restrict to processing may not be able to be fully enforced.

Right to data portability

Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person. Right to freedom from automated decision-making As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.

Right to object to direct marketing (‘opting out’)

You have a choice about whether or not you wish to receive information from us. We will not contact you for marketing purposes unless:

  • You have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
  • You have otherwise given your prior consent (such as when you download one of our guides)
You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details. Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.

Right to request access

You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.

Right to withdraw consent

Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details.

Raising a complaint about how we have handled your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us at [email protected] and we will then investigate the matter.

Prior to any gathering of the personal information that is provided by you, we ask all users to state that have read and have understood our Terms and privacy policy. All of this information will be stored by us in Amazon Servers located in Oregon, USA.

Children

VTOS is not directed at children under the age of 13, and does not consciously collect any Personal Information from children under the age of 13. We request that all VTOS users be at least 18 years old (or a legal age in your jurisdiction) or have received parental consent and supervision when using the Service.

Links to Other Sites

The site may contain links to other websites. If you choose to visit a linked site by “clicking on” on another third-party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites.

Modifications

We may occasionally modify the privacy policy. All changes will be effective upon posting on the Site. You can determine when the privacy policy was last revised by referring to the “Last Updated” legend at the top of the page. You agree to be bound by any such changes if you continue to use the Site after such changes have been posted. We may change, restrict access to, suspend or discontinue the site or the service, or any portion thereof, at any time.

Questions about Our Privacy Policy

If you have any questions or concerns regarding this privacy policy, you may contact us by e-mail at [email protected]

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