Wallet Privacy Policy

Updated and Effective – 30-October-2019


Thank you for visiting our website. Your privacy and the protection thereof is of paramount importance to us.

This Privacy Policy, as amended or otherwise changed from time to time and explains the manner in which iOWN Limited (“iOWN”, “we”, “us”, “our”) collects, uses, maintains, stores, transfers and discloses User information. In this policy “User”, shall mean you, the User of the facilities and services.

iOWN Group DMCC acts as the authorised service provider for iOWN Group Ltd and iOWN Limited and in the offer of services to each of these entities as well as in its offer of services of a digital wallet, iOWN Group DMCC collects Personal Data of users.

This Privacy Policy should be read and interpreted together with the Terms and Conditions of the Facilities (as defined hereinbelow). By using the Facilities, you signify your agreement to this Privacy Policy.

Changes to this Privacy Policy

From time to time, iOWN may revise, amend or supplement this Privacy Policy to reflect necessary changes, i.e. changes in law, our Personal Data collection and usage practices, the features of the Sites or Platform(s), or certain advances in technology. If any material changes are made to this Privacy Policy, the changes will be prominently posted on the Site(s) and/or the Platform(s). iOWN, however, requires that you (the User) to occasionally familiarize yourself with the contents of this Privacy Policy, for your own information. Changes to this Privacy Policy are effective when they are published in this Policy.

Please be advised that this Privacy Policy does not confer any information that we may receive about you through channels external to iOWN’s Facilities, communication and data infrastructures, networks and/or systems.

Important Definitions

Terms which are not defined in this Privacy Policy shall have the meanings ascribed to them in the Terms and Conditions

  1. User Consent: when you access and use any content we own or operate on the iOWN Facilities, any other website(s), application(s), page(s) or feature(s) thereon and which is owned, operated, maintained or mandated under service by iOWN, you as the User expressly consent to the data practices prescribed in this Privacy Policy. This is further supported in your application for the creation of a User Account.

  2. Data Controller: iOWN is the Data Controller and the Data Processor of your Personal Data. Data protection is important to us and we adhere to applicable data protection laws and regulations, which includes both the data protection and privacy requirements, particularly of the Cayman Islands [namely, the Confidential Information Disclosure Law of 2016 and Data Protection Law of the Cayman Islands (2017 legislation and the subsequent Act commencing 30 September 2019)]; and further – where applicable to individuals in the European Union and the member states of the European Free Trade Association (“EFTA“), the General Data Protection Regulation (“GDPR” which had commenced on 25 May 2018) for the purposes mentioned in this policy. We may also process your Personal Data and you consent to the processing thereof, to satisfy all legal obligations, if it is necessary to carry out any obligations arising from any contracts entered into with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety or that of our customers, clients, other persons or other entities.

  3. Data Protection Office (“DPO”): iOWN has also appointed a DPO who is responsible for overseeing data-related matters to address any questions in relation to this Privacy Policy. If you have any questions about the Privacy Policy, including requests to exercise your rights related to data, please contact us here.

  4. If you are based in Europe, be advised that you have the right to make a complaint at any time to a supervisory authority, in particular within the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of the Data Protection law has taken place. Similarly, be advised that you have the right to make a complaint any time to the Office of the Ombudsman whom is the Cayman Islands’ supervisory authority for data protection (https://ombudsman.ky/). If you are based elsewhere globally, you have the right to make a complaint at any time to an appropriate supervisory authority within the appropriate locality, as per the law of the region. In respect of any complaints, however, we would appreciate the opportunity to address your concerns before you approach the Information Commissioner’s Office (ICO) or any other supervisory authority (as appropriate), and so, please contact us in the first instance so that we may try to resolve your complaint amicably Contact Us Page

  5. Wallet: means a digital wallet for the personal safekeeping of iOWN tokens issued by the token issuance company, iOWN Limited. The Wallet is available for devices running on Android systems, iOS systems and desktop internet platforms. Through the Wallet, you grant iOWN the consent to request and acquire information about your payment account from a third party, which maintains your payment account. Usage of the Wallet is defined in these Terms, which were issued by the Provider and accepted by the User.

  6. Data Subject: means any person whose Personal Data is being collected, held or processed. For ease of understanding: You are the Data Subject, as the User.

  7. Data Controller: means a person who (either alone or jointly with other persons) determines the purposes for and the manner in which any Personal Data is to be processed. As confirmed above, iOWN is the Data Controller. iOWN may process your Personal Data directly, or through affiliates or authorised agents and service providers of iOWN, who may be chosen by us for the purposes of furthering the individual and separate businesses of iOWN.

  8. Data Processor: means any person (other than an employee of the Data Controller) who processes Personal Data of a Data Subject, on behalf of the Data Controller.

  9. 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.

  10. Anonymous Data: means data that is not associated with or linked to your personal data. Anonymous Data (i.e. encrypted data) does not, by itself, permit the identification of individual persons.

  11. Facilities: means the Wallet facility, including wallet keys, tokens, transactions or any other Blockchain information, as well as services offered or provided by iOWN via websites www.iownx.com, local application (mobile, desktop, or otherwise).

  12. User Account: means the account created by you on our website www.iownx.com (or iOWNX application mobile, desktop or otherwise) to access our Facilities.
    Please note that: You will, generally, not be required to pay a fee to access your personal data (or to exercise any of the other rights), however, that we may charge a reasonable fee (determined at our sole discretion and which is payable by you, the User and/or Data Subject) if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under the aforementioned circumstances.

Information that iOWN collects

iOWN collects several different types of information for various purposes to provide and improve our services to you.

Types of data collected:

  1. Personal Data: While using our Facilities, we may ask you to provide with certain personally identifiable information that can be used to contact or identify you, including without limitation the following:

    1. your name;

    2. your email address;

    3. your address;

    4. your nationality;

    5. your identification documents;

    6. any other information that you choose to provide to us when filling out a contact form on our Website;

    7. your geographic location (country/territory where you are living and/or working);

    8. your job title, role and the name of your employer;

    9. your phone number;

  2. Profiling Data: While using our Facilities, we may ask you to provide personal data related to your investment interests, and experience with Blockchain based systems, including without limitation the following:

    1. your investment history;

    2. information about your income;

    3. geographical and business domain interests of investment;

    4. previous investment in Crypto assets;

  3. Usage Data: iOWN may also collect information when the Wallet is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the Wallet identifier, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We also use information from log files to analyse trends; operate, administer and maintain the Facilities; track Users’ movements and activity around and within the Facilities, gather demographic information about our User base as a whole, and better tailor our services to our Users’ needs. We may also collect blockchain analytics information related to blockchain usage; and blockchain addresses which you provide. We may also collect information about the device you use to access your Wallet, including the hardware model, operating system and version, and unique device identifiers, but this information is anonymized and not tied to any particular person.
    Except as noted in this Privacy Policy, we do not link this automatically collected data to Personal Data

  4. Location Data: iOWN may use and store information about your location if you give us permission to do so. We use this data to provide features of our services, to improve and customize our services. You can enable or disable location services when you use our Facilities at any time by way of your device settings.

  5. Wallet Information: If you create a Wallet, you will generate a public and private key pair, a 12 word secret phrase (mnemonic string) and a public wallet address. When you log-out of the Wallet, we collect an encrypted file, that, if unencrypted, would contain these keys. iOWN Collects only public information (public address) during wallet creation, and all private information remain in the storage of your device (mobile, desktop, or otherwise). Under no circumstances do we collect an unencrypted private key from you, nor can we decrypt any Wallet data.

  6. Transaction Information: In connection with the Facilities we provide, we may collect and maintain information relating to transactions you effect in your Wallet.

  7. Information which may be further required from you: We may need to request specific information from you to help us to confirm and verify your identity, so as to ensure that your rights to access your Personal Data or to exercise any of your other rights, as determined by contract, the law or otherwise. This is a security measure to ensure that Personal Data is not disclosed to any authorized person, who has no right to receive it. We may also contact you to ask you for further information in relation to your request, in order to speed up our response to any request received from you, when you exercise your rights.

  8. Information about criminal convictions or activities: When you register for or otherwise use our Facilities, we may receive information about your criminal convictions, when we perform certain necessary verification or compliance checks. We carry out these checks in order to detect and/or prevent any unlawful or fraudulent acts, as well as to comply with our legal obligations.

  9. If you fail, neglect and/or refuse to provide us with your Personal Data: Where we need to collect Personal Data by law, or under iOWN’s Terms and Conditions, in contracting with you and if you fail to provide that data when requested, we may not be able to perform the services. In this case, we may close your User Account, however, we will notify you if this is the case at the time.

  10. Data collected from third parties: We may also collect other Personal Data supplied by third-party entities and service providers / agents in the outsourcing of services, including, but not limited to third party identity verification sources and services; verification via social networking websites; Cryptographic Exchange websites; and International Payment Service Providers.

  11. Certain services, such as two-factor authentication , may require our collection, use, processing, transfer and storage of your phone number and possibly other data. We may associate that phone number to your mobile device identification information.

  12. If you provide us feedback or contact us, we will collect your name and e-mail address, as well as any other content included in form in which it was received (i.e. the details and content of an email), in order to send you a reply or in to contact you.

  13. We also collect other types of Personal Data that you voluntarily provide to us when contacting us – i.e. in seeking support services via email, information submitted via an online contact form, video conferencing service information, other contact information, or other information provided to support services staff.

Data Collected automatically and iOWN’s use of Cookies and Persistent Local Data

  1. Data collected automatically includes, without limitation cookies, webpage counters and other analytics tools.

  2. iOWN collects web browser information in order to enhance your User experience on our facilities, as well as to track how the facilities and Services are being used.

  3. We collect and use cookies to identify and prevent fraudulent or illegal activity.

  4. We may use both session / transient cookies (which expire once you close your device 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 and in using our facilities. This type of information is collected to make our Facilities more useful to you and to tailor the experience with us to meet your special interests and needs.

  5. Cookies are not permanent and will expire after a short time period of inactivity. Data collected via technical means, such as cookies, webpage counters and other analytics tools, are normally kept for a period of up to one (1) year from expiry of the cookie.

  6. You may opt to deactivate your cookies, but it is important to note that you may not be able to access or use some features of our Site or Platform, should you do so, as such Cookies may enable certain functions thereon.

  7. Please note that iOWN is not responsible and will not be held liable for any loss resulting from your decision or inability to use cookies.

  8. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.

How to update your information

  1. Whenever possible, you can update your Personal Data directly within your User Account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

  2. If you wish for iOWN to update your information please contact us in making such a request.

  3. We will retain your information for as long as your User Account has not been closed or as may be needed to provide you access to your User Account and or services of iOWN.

  4. If you wish to close your User Account, please contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms and Conditions.

iOWN’s use of the information it collects

We will only use your Personal Data when the applicable laws allow us to. Most commonly, we will use your Personal Data in the following circumstances:

  1. To facilitate the creation of and to secure your User Account on our network(s) and related and integrated facilities (where applicable);

  2. To prudently identify you and perform the necessary identity verification through our own efforts or through a service provider/providers;

  3. To provide improved administration of our Facilities;

  4. To improve the quality of your User experience when you interact with our Facilities;

  5. To send you an e-mail to verify ownership of the e-mail address provided when your User Account is created;

  6. To send you administrative e-mail notifications or other communications: i.e. User Account activity, transaction processing, security or support and maintenance or other advisory services;

  7. To identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;

  8. To notify you about important changes to our Facilities, Privacy Policy, Terms and Conditions or other User-related facilitates of iOWN;

  9. To respond to your inquiries or other requests received;

  10. Where it is necessary for our legitimate interests (or those of a third party), but where such interests do not override your fundamental rights; and/or

  11. Where we need to comply with a legal or regulatory obligation.

iOWN may be compelled to surrender User information to legal authorities without express User Consent, if presented with a court order or similar legal or administrative order, or as required or permitted by the laws, rules, and regulations of any nation, state, or other applicable jurisdiction.

Please be advised that we may process your Personal Data without your knowledge or consent where this is required or permitted by law. In general, the Personal Data which you submit to us is used either to respond to requests that you make, or to aid our service to you, the User.

All data collected automatically will be used to administer or improve our services, including the following:

  1. We use KYC Chain to verify your identity by termining whether the uploaded documents (proof of identity document such as international passport, proof of address such as utility bill) you provide matches the personal information in your submitted form of identification during the onboarding and User registration or User Account creation process. This technology collects information from your biometric data, and it shares this information with us. We use that information to verify your identity. We will store your biometric data for as long as is necessary to perform the services, and as long as the User Account exists and will comply with applicable law relating hereto. By using the iOWN services, you agree that KYC Chain may collect your biometric data from the biometric data you submit to perform identity verification and that KYC Chain may share that information with us.

  2. We may create Anonymous Data records from Personal Data by excluding certain information (i.e. your name) which may make 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 navigation of the facilities of iOWN. We reserve the right to use Anonymous Data, aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties at our sole discretion.

The Sale of Data: iOWN does not sell User data to any third party.

Data Retention: iOWN will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

iOWN will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods

Marketing: We provide you with choices regarding the Personal Data that iOWN uses, particularly concerning marketing and advertising. We have established the following personal data control mechanisms:

  1. Promotional offers from iOWN: We may use your Personal Data to determine what may be of interest to you. This is how we decide which products, services, and offers may be relevant and of interest to you. By using our facilities, using our services, registering a User Account, in contacting us, in requesting information from us, you expressly opt-in to receive marketing communications from iOWN.

  2. Third Party Marketing: We will obtain your express consent to opt-in and share your Personal Data with any company outside of iOWN for that company’s own marketing purposes.

  3. Opting out: You can ask us or third parties to stop sending you marketing related material and/or communications at any time by following the opt-out Unsubscribe on any marketing message sent to you or by contacting us.

How iOWN shares Personal Data

  1. e disclose your Personal Data, as described in this Privacy Policy.

  2. 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, government requests, to defend against legal claims, investigate or bring legal action against illegal or suspected illegal activities, to enforce our Terms and Conditions, or to protect the rights, safety, and security of iOWN, our Users, other persons or the public.

  3. We may share your Personal Data with third party service providers in order to provide you with the services that we offer you through our site or application; to conduct quality assurance testing; to facilitate the creation of User Accounts; to provide technical support, operational support and maintenance services; to verify your identity; and/or to provide other services to iOWN and any facilities of iOWN. These third-party service providers are required not to use your Personal Data for any purpose, other than to provide the services mandated by us.

  4. We share some Personal Data with certain third-party entity for whom we may perform services in relation to the iOWN token. We only share the Personal Data which is necessary for them to perform those services. Please note that those entities have their own privacy policies which will govern the shared information and which are available at the links below

  5. We may use social plugins, widgets and other features (“Social Features“) that are made available by and/or accessed through third party social networks. These Social Features allow these social networks to place cookies on your browser and to collect certain information, which may be associated with your name, personal details and personal social network account. These Social Features are operated solely by the respective social networks, and their service providers, and we recommend that you carefully read their privacy policies before you decide to use them. We have no control over or access to the information collected, stored or used by such social networks, and the information practices of such social networks are not covered by this Privacy Policy. If you do not wish to associate any information collected via the plugins, widgets and/or other features with your personal social network account information, you should refrain from using these Social Features and logout from your social network account before any visit to or use of our facilities, or using our services.

  6. We may share some or all of your Personal Data with third parties (i.e. if iOWN is acquired by a new owner) in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset forming part of iOWN’s good will. If another company acquires iOWN, its business or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations held by iOWN regarding your Personal Data, as described in this Privacy Policy.

  7. iOWN website may contain links to other third-party websites which are not owned or operated by iOWN and too, which are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s site. iOWN strongly advises you to review the privacy policy of every site you visit. iOWN is not responsible for the privacy policies of these third-party websites, regardless as to whether they were accessed using the links from our facilities. iOWN has no control over and assumes no liability for the content, privacy policies or practices of any third-party sites or services.

Other than as stated in this Privacy Policy, iOWN does not disclose any of your Personal Data to third parties unless required to do so by law enforcement, court order, or in compliance with legal reporting obligations.

Extraterritorial data storage and transfers outside of the European Economic Area (if you are based in Europe) and outside of the Cayman Islands

We store your Personal Data at secure locations and ensure that appropriate security standards are in place regarding the safeguarding, confidentiality, and security of the data. The information that we collect from you will be transferred to, and stored in, destinations outside of your country with subsidiaries, service providers and business partners (i.e., Data Processors) who are engaged on our behalf. To the extent that we transfer your Personal Data outside of your country of residence, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with relevant data protection laws including Confidential Information Disclosure Law of 2016 and Data Protection Law of the Cayman Islands (2017 legislation and the subsequent Act commencing 30 September 2019)] and the General Data Protection Regulation

Security precautions exercised by iOWN for protection of your Personal Data

  1. We take the protection of your Personal Data seriously and in so doing, we use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information.

  2. iOWN servers and business operations are entirely located between Amazon Web Hosting Cloud (United States of America), and Azure Web Hosting Cloud (Europe).

  3. iOWN’s facilities are scanned on a regular basis for security holes and known vulnerabilities, in order to best ensure its security.

  4. Your Personal Data is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential.

  5. Please note that no transmission over the Internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavours will be made to secure data and the ability to access your personal information.

  6. Without prejudice to our efforts on protection of your data, nothing contained in this Privacy Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk. Please note, that iOWN and the Facilities do not guarantee that your data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

  7. We would like to draw your attention on the fact that iOWN will under normal circumstances never ask for financial or payment information, such as your credit card number, passcode, User Account number or pin number, in an e-mail, text or any other communication that we send to you. Please, always check that any website on which you are asked for financial or payment information in relation to our reservations or services is in fact legitimately owned or operated by iOWN. The risk of impersonating hackers exists and should be taken into account when using our facilities and/or Services.

  8. If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately. Please also immediately notify us if you become aware of any unauthorised access to or use of your User Account here.

  9. Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your data, please accept that you play a vital role in protecting your own Personal Data, including the adoption of sufficient safety measures such as your choosing of an appropriate password of sufficient length and complexity and to not reveal this password to any third-parties.

  10. Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us, or receive from us by Internet or wireless connection, including: email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us.

Your Legal Rights

The rights that are available to you in relation to the Personal Data we hold about you are outlined below:

  1. Right to Access your Personal Data that we process and receive a copy of it.

  2. Right to Rectify inaccurate Personal Data we have concerning you and to have incomplete Personal Data completed.

  3. Right to Data Portability, that is, to receive the Personal Data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this information to another service provider. Where technically feasible, you have the right that your Personal Data be transmitted directly from us to the service provider you designate.

  4. Right to Withdraw Consent to processing your Personal Data, at any time, where the processing is based on consent. If you do that, we will still process certain information on a legal basis other than consent, as described in this Privacy Policy. Withdrawing your consent will not affect the lawfulness of the data processing we carried out based on your consent before such withdrawal.

  5. Right to Object, based on your particular situation, to using your Personal Data on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your Personal Data for direct marketing purposes.

  6. Right to Restrict processing your Personal Data (except for storing it) if you contest the accuracy of your Personal Data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the Personal Data and request instead to restrict its use; if we no longer need the Personal Data for the purposes outlined in this Privacy Policy, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending the verification whether our legitimate grounds for processing overrides yours.

  7. Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your Personal Data. However, we may still process your Personal Data if it is necessary to comply with a legal obligation, or for the establishment, exercise or defense of legal claims. If we have disclosed your Personal Data to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.

If you wish to exercise any of the rights set out above, please contact us.

Miscellaneous

  1. Time limit to respond to User requests in exercising the aforementioned rights: We aim respond to all legitimate requests without undue delay and within one (1) month calendar of receipt of any request from you. Occasionally it may take us longer than one (1) month if your request is particularly complex, or if you have made duplicated or numerous requests. In this case, we will notify you of receipt of such request(s) and keep you updated as to the status of progress concerning such request(s).

  2. Children’s privacy: Minors are ineligible to use our services. We do not and will not knowingly solicit or collect information from anyone who is not of legal age. Should we retrospectively become aware that a minor has provided us with Personal Data, we will erase such information immediately and close the related User Account.

Contacting Us

If you have any questions about our Privacy Policy as outlined above, or if you have any complaints, please contact us.