Effective Date 19/11/2018
- Newsletter is a service that provides you with the latest news in your email.
- Forum is a service that allows users to exchange opinions and provide various notices about BOScoin.
- The Wallet is an electronic wallet service, which allows you to use BOScoin.
- Know Your Customer (“KYC”) service is a service verifying identity for one vote for one person in Congress Voting and for compliance with financial regulation in multiple jurisdictions. This service is provided by SUM AND SUBSTANCE LIMITED(“Sum&Sub”) at Office 7 Westwood Business Centre, Continental Approach, Westwood, Kent, United Kingdom, CT9 4JG.
Personal information consists of all information related to an identified or identifiable natural person, e.g. names, addresses, phone numbers or email addresses.
- 1.Information We Collect
- 2.How We Use the Information We Collect
- 3.Information Sharing
- 4.Retention of Personal Information
- 5.Your Choices
- 6.Your Rights
- 7.How We Protect Personal Information
- 8.Cookies and Others
- 9.International Transfer of Information
- 11.Contact Us
- Information We Collect
- The following personal information is collected in connection with the Services and the KYC process:
- Device Information
We collect information such as IP address, browser data, cookies of the device you use to access the Service.
- Account Information
We collect information associated with your email address used to access the Forum service and Newsletter, such as your nickname, profile picture and email address.
- Service Interactions
We collect information through your interactions with the Services, such as responses, answers, and content
- KYC Process
The KYC Process is operated by Sum&Sub. Sum&Sub is the controller of any personal information which you transfer to Sum&Sub in that regard. Sum&Sub collects information from you including your name, date of birth, email, country, image of Identification, selfie and other inputs. If you submit sensitive information through the KYC process, it will be collected and processed for the purposes set out below.
After the KYC Process, Sum&Sub informs us whether you have passed the KYC process.
- A) Provision of Services based on your contractual relationship with us
- Provide you with the Services, such as to respond to your request, questions and instructions made through Services;
- Identify and authenticate you so you may use certain Services;
- Respond to your inquiries
- B) Use of information for further purpose based on our legitimate interests
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- Through our Homepage and Wallet, we may collect personal information about your online activities on Homepage and Wallet. We may use Google Analytics on our websites and Google Firebase on our Wallet to improve our Services.
- The information we collect may be disclosed to or directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services, help provide the Services, and diagnose technical issues. See the Cookies section for further information on Google Analytics
- C) Other
- We disclose personal information about you through the Services as described in the following:
- Service Providers. We may disclose your information to carefully selected companies that provide services on behalf of us, such as companies that help us with customer contact centers, customer care activities, KYC process or that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.
- Other Parties When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties:
- to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
- to verify or enforce compliance with the policies governing our Services; and
- to protect the rights, property, or safety of us, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
- Other Parties in Connection with Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.
- We take appropriate steps to ensure that we process and retain information about you based on the following logic:
- at least the duration for which the information is used to provide you with a service;
- as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
- only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.
- We offer you certain choices in connection with the personal information we obtain about you. To limit communications you receive from us, or submit a request, please contact Us as specified in the Contact Us at email@example.com.
a. General Rights
ou have the right to request details about the information we collect about you and to request us to correct inaccuracies in that information or request the restriction of processing, and to request access to, or the erasure or portability of your information. Under the laws of some jurisdictions, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact us at firstname.lastname@example.org or use the address mentioned under section 11. You understand that, despite your request for deletion, we reserve the right to keep your personal information, or a relevant part of it, in line with the above section on “Retention of Personal Information” and applicable laws.
b. Right to Withdraw Consent
In case you consented to the processing of your data, you have the right to withdraw this consent with immediate effect. The legality of data processing prior to your withdrawal remains unchanged. To withdraw a consent, please contact us at email@example.com or use the address mentioned under section 11.
c. Right to Object
If personal data is processed on the basis of legitimate interests, you have the right to object to the processing of your personal data provided there are grounds relating to the particular situation. To do so, please contact us at firstname.lastname@example.org or use the address mentioned under section 11.
- We take protection of your information seriously and have put in place appropriate physical and technical measures to safeguard the information we collect in connection with the Services. Our security measures are state of the art. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.
- Cookies are small text files that are placed on your computer by websites that you visit. Cookies serve many useful purposes. For example:
- Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you log on to a service.
- Cookies help us and third parties understand which parts of our Services are the most popular because they help us see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the Services and provide you with a better experience.
- Cookies help us and third parties understand which ads you have seen so that you do not receive the same ad each time you access a Service. When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. You can also delete cookies stored on your end device by configuring the browser. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.
We use the following types of cookies on our website:
which enable you to order products and receive Services from our website. You can only disable essential cookies via browser settings.
which enable us to analyze the performance and design of our website and detect errors. For example, this type of cookie allows us to recognize that you have visited our website before and shows which sections of our website are most popular by allowing us to see which pages visitors access most frequently and how much time visitors spend on each page.
This website uses Google Analytics, a web analysis service provided by Google Inc., located at 1600 Amphitheatre Park-way, Mountain View, CA 94043, USA. We use Google Analytics to analyze and regularly improve the use of our website (legitimate interest). The statistics obtained allow us to improve our services and make them more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield. The information generated by the Google cookie about the use of the website will normally be stored on a Google server in the United States. However, if you are located within the EU or the European Economic Area, your IP address will be shortened by Google beforehand. In exceptional cases only, your full address will be transmitted to a Google server in the United States and shortened there. On our behalf, Google will use this information for the purpose of compiling reports on website activity and providing other services relating to website activity and Internet usage. The IP address transmitted from your browser as part of Google Analytics will not be associated with any other data held by Google. You may prevent web usage data (including your IP address) generated by the cookie from being transmitted to Google and processed there if you download and install this Browser-Plugin.
With your consent, we use the remarketing functions of Facebook, Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) on this website. The Facebook pixel used serves the purpose to display interest-based advertising to users of our website when they visit Facebook. For this purpose, we have implemented the Facebook pixel on this website. When you visit our website, this pixel connects to the Facebook servers. Facebook is then informed that you have visited our website. Facebook links this information with your Facebook account. The Facebook pixel enables us to measure, evaluate and optimize the effectiveness of Facebook ads for statistical and market research purposes. We only receive anonymous reports from Facebook. Further information on the collection and use of the data by Facebook as well as on your rights and possibilities to protect your privacy in this regard can be found in Facebook’s data protection information. You can revoke your consent to the use of the Facebook pixel at any time with effect for the future by following this link. You must be logged in to Facebook to do this.
You can opt out of seeing online interest-based ads from Facebook and other participating companies through the Digital Advertising Alliance in USA, the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europe or through your mobile device settings. Please note that ad blockers and tools that restrict our cookie use may interfere with these controls.
We use the Google Firebase Crashlytics provided by Google Inc., which is helpful to find out the causes of mobile application errors. You can refuse to use it by configuring Wallet. More information on Privacy and Security in Firebase can be found here.
- To exercise these rights, please contact us contact us at email@example.com. or via post 4th Fl. 415, Teheran-ro, Gangnam-gu, Seoul, Korea, 06160. In addition, our Data Protection Officer can be contacted at firstname.lastname@example.org. You can also contact the competent data protection authority as the responsible supervisory authority