This Privacy Policy (this “Policy”) applies to the BlancBlock platform (the “Platform”) provided by BlankBlock Limited Liability Company (the “Company,” “we,” “us” or “our”), a company established under the laws of the Republic of Poland，whose address is street HOZA,No.86,Apt./Room 210,municipality WARSAW,post code 00-682,post office. It describes how the Company collects, uses, and discloses Personal Information (as defined below) that we obtain from Users of the Platform and any account services provided through the Platform, and how we use and disclose that information. For the purpose of this Policy, “Personal Information” refers to (a) information supplied by a User from which the identity of such User may be directly or indirectly determined, which includes any data relating directly or indirectly to a living individual, (b) any data from which it is practicable for the identity of the individual to be directly or indirectly ascertained; (c) any data in a form in which access to or processing of the data is practicable and (d) any other personal information as collected by us in the course of provision of our services of the Platform.
This Policy, the Cookie Policy on the website and the User Registration Agreement (together with the documents referred to in it) constitutes the entire agreement and supersedes and extinguishes all previous discussions, correspondence, negotiations, drafts and agreements for the subject matter hereof.
1.The Information We Collect From You and How We Collect It
We collect and process Personal Information directly from you when you register to use the Platform or submit such information as a part of the Know-Your-Client (“KYC”), as well as automatically through your use of the Platform.
2.Information We Collect Directly From You
2.1Personal Account and Profile Information: There are several types of accounts that can be established on the Platform. We collect the following information when you register an Account: name, mobile phone number and/or email address. When your Account meets certain standard, we may collect additional information: name in identity card/passport, date of birth, nationality, mailing address, residential address, mobile phone number and email address.
2.2Financial Information: We may collect additional financial and investment information from you to confirm your status and eligibility to set up other types of accounts or conduct certain transactions on the Platform, including your investment experience, finance-related qualifications and training (including any certifications received, issuing organization and date of issuance), your annual income level, liquid net worth, estimated net worth, source of funds, and source of wealth and whether you have had the opening of an account declined by another financial institution.
2.3Other Required Information: We may need to collect certain additional information to comply with legal requirements, such as whether you are a Politically Exposed Individual or on any restricted persons list, and applicable tax reporting forms, such as a W8-BEN for our purposes of conducting the KYC.
2.4Communications with Us: We collect information you give us during any support and feedback communications through email or when you contact us through contact forms on the Platform. We use this information to respond to your inquiries, provide support, facilitate transactions, and improve our Platform.
2.5Unless you have specifically notified us to the contrary, you will be deemed to have agreed and consented to the collection, use, processing, retention, transfer and disclosure of your Personal Information (including but not limited to those types and categories of information and data enumerated above) so collected by us in accordance with the provisions of this Policy.
2.6If you are required to provide any information about any other person, you hereby acknowledge and confirm that you have that other person’s authorisation or consent to provide his or her information to us and our collection, use, processing, retention and disclosure of such Personal Information in accordance with this Policy. Any person whose Personal Information are provided to us, whether by such person himself or herself or by any person his or her behalf, shall be deemed to have accepted and agreed to this Policy, which will be binding upon such person.
2.7We shall be entitled to assume, conclusively and without enquiry, that the authorisation or consent of any such other person as aforesaid has been obtained for the provision of his or her information to us and our collection, use, processing, retention and disclosure of such information in accordance with this Policy, and shall not in any event be responsible for any lack of authorisation or consent for the same. Further, you agree and undertake to indemnify, defend and hold us harmless from and against any losses, damages, costs, expenses, suits, actions, proceedings and third-parties demands and claims arising from or in connection to your failure to obtain valid authorisation or consent or your breach of any term or condition applicable to your disclosure of Personal Information and any other information of any other person.
3.Information We Collect Automatically
3.1When you use the Platform, our servers automatically record information using cookies and other tracking technologies, including information that your browser sends whenever you visit the Platform or your mobile application when you’re using it. This log data may include your Internet Protocol address, the address of the web page you visited before coming to the Platform, your browser type and settings, the date and time of your request, information about your browser configuration and plug-ins, language preferences, and cookie data. Such log data is not routinely deleted. Other technical data or information we would automatically collect include the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and details of any transactions, transfers, redemptions, purchases and payments you made on our Platform (including the use of the Company Card Services with details set out in the Company Card Service Agreement).
3.2In addition to log data, we may also collect information about the device you use for the Platform, including the type of the device, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information may depend on what type of device you’re using and its settings.
3.3We may combine this information with other information that we have collected about you, including, where applicable, your name, user name, email address, and other Personal Information. In addition, we also work with third parties and we may receive Personal Information about you from them, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies. We will notify you when we receive Personal Information about you from them and the purposes for which we intend to use that Personal Information.
4.How We Use Your Personal Information
4.1We use your Personal Information for the following purposes:
(a)To provide our services of the Platform to you, to facilitate communications and transactions on the Platform, to communicate with you about your use of our Platform, to respond to your inquiries, to fulfil your orders, and for other customer service purposes;
(b)Carries out KYC procedures in accordance with our internal policies and requirements of applicable laws and regulations;
(c)researching, designing and launching new features or products;
(d)To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Platform; and
(e)To better understand how users access and use the Platform, both on an aggregated and individualized basis, in order to improve our Platform and respond to user desires and preferences, and for other research and analytical purposes.
5.How We Share Your Information
5.1Affiliates. We may disclose the Personal Information we collect from you to our Affiliates or subsidiaries solely for the purpose of providing the Platform’s services to you; however, if we do so, their use and disclosure of your Personal Information will be maintained by such Affiliates and subsidiaries in accordance with this Policy. Personal Information might also be disclosed to our Affiliates’ respective employee, officers, personnel, agents and representatives, on a need-to-know basis, in connection with our operations or provision of services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of customer support services). For the purpose of the Policy herein, “Affiliates” shall mean in relation to any person, any other person directly or indirectly, controlling, controlled by or under direct or indirect common control with that person, and a reference to “control” is a reference to the power, authority or ability, whether exercised or not, to control or direct a person’s business, affairs, management and/or policies, whether through the ownership of voting securities, by contract or otherwise.
5.2Service Providers. We may disclose the Personal Information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf, provided such third parties have agreed to only use such Personal Information to provide services to us.
5.3Business Transfers. If we are in the course of negotiations with, or going to implement any mergers with another company or entity, if substantially all of our assets are transferred to another company or entity, or as part of a bankruptcy proceeding, we may transfer the Personal Information we have collected from you to the other company or entity.
5.4In Response to Legal Process. We also may disclose the Personal Information we collect from you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a subpoena. We might also disclose the Personal Information to our legal advisors, auditors and other professional advisors and service providers (who shall be under a professional duty of confidentiality to us and with respect to information disclosed by us) for the purposes of complying with the legal process.
5.5To Protect Us and Others. We also may disclose the Personal Information we collect from you if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our User Registration Agreement or this Policy, or as evidence in proceedings in which we are involved.
6. Cookies
6.1 We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other Personal Information we collect from you (and our third-party service providers may do so on our behalf). For details, please refer to the Cookies Policy.
6.2 Cookies：Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process or to allow us to track your activities at our Platform. There are two types of cookies: session and persistent cookies.
6.3 Session Cookies：Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Platform. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Platform.
6.4 Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity. Please note that our systems do not currently respond to do-not-track signals.
6.5 Disabling Cookies：Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.
6.6.Third Party Analytics：We use automated devices and applications, such as Google Analytics, to evaluate usage of our Platform. We also may use other analytic means to evaluate our Platform. We use these tools to help us improve our Platform, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.
6.7 If you visit our Platform and your settings accept cookies, we will consider this as acceptance of our use of cookies. If you do not wish to permit such tracking and information collection by our cookies, you may adjust your settings in your web browser to reject some or all of our cookies. However, this may prevent you from accessing or using some or all of the features, functionalities and services of our Platform.
7.Third Party Website
Our Platform may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites and you shall have the responsibility to visit such third-party websites for the privacy implications. We encourage you to read the privacy policies or statements of these third-party websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites.
8.Security of Your Personal Information
8.1We have implemented reasonable precautions consistent with applicable laws and regulations to protect the Personal Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security. Therefore, all Users (including their Authorized Individuals) of the Platform must comply with the security requirements in the Terms and take the following additional steps to help ensure the security of their Personal Information and the access to their account:
(a)You should choose a robust user identification, password, and PIN to access your account (“User Credentials”) that nobody else knows or could easily guess. User Credentials must meet the requirements we specify when you establish those User Credentials. You should keep your User Credentials secure and private, and not share your User Credentials with any third party.
(b)You should install anti-virus, anti-spyware, and firewall software in your personal computers and mobile devices;
(c)You should update operating systems, anti-virus, and firewall products with security patches or newer versions on a regular basis;
(d)You should remove file and printer sharing in computers, especially when they are connected to the internet;
(e)You should make regular backups of your critical data;
(f)You should consider the use of encryption technology to protect highly sensitive or confidential information;
(g)You should completely log off and clear your browser cache after finishing each online session with the Platform;
(h)You should not install software or run programs of unknown origin;
(i)You should delete junk or chain emails;
(j)You should not open email attachments from strangers;
(k)You should not disclose personal, financial, or credit card information to little-known or suspect websites;
(l)You should not use a computer or a device that cannot be trusted; and
(m)You should not use public or internet cafe computers to access online services or perform financial transactions.
8.2You should immediately notify us at privacy@blancblock.com if you become aware of any unauthorized use or access of your Account or User Credentials. We are not responsible for any lost, stolen, or compromised User Credentials or for any activity on your Account via unauthorized activity using your User Credentials. Please note, however, that the transmission of information via the Internet is not completely safe. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your information transmitted to our Platform. Any transmission is at your own risk.
9.DIRECT MARKETING
9.1Your name, email address, telephone number, contact address, social media contact, date of birth, as well as information about your subscriptions, products and services portfolio, transaction and activity patterns and behaviours, browsing records, content viewing held by us may be used by us in direct marketing of our services and any new or existing products, services and facilities offered by us, our Affiliates and business partners, including but not limited to technology solutions, payment services, as well as other similar products and services. For the avoidance of doubt, “direct marketing” in this Policy shall mean (a) the offering or advertising of the availability, of goods, facilities or services; or (b) the solicitation of donations or contributions for charitable, cultural, philanthropic, recreational, political or other purposes through direct marketing means.
9.2By entering into the Terms and accepting this Policy, you will be deemed to have consented to the use of your Personal Information for direct marketing purposes in accordance with this Clause 9, unless you expressly indicate to us your objection to such use. Notwithstanding the foregoing, we shall inform you if we use your Personal Information in direct marketing for the first time.
9.3If for any reason, we intend to provide your Personal Information to any third party for use by such other third party for direct marketing purposes, we would inform you in writing stating:
(a)the persons or class(es) of persons to which the Personal Information is to be provided;
(b)the purpose of providing your Personal Information to such person;
(c)the kinds of Personal Information to be provided to such person;
(d)the marketing subjects in relation to which the Personal Information is to be used.
9.4We will not provide your Personal Information to such third party unless written consent is obtained from you for the same. You shall also have the right at any time to request us to cease providing your Personal Information to any third parties for direct marketing in accordance with Clause 10.4 below.
9.5If you prefer not to receive any direct marketing communications from us or our marketing partners, or you would like us to cease to provide your Personal Information to any third parties for direct marketing purposes, you may opt out of such direct marketing or request us to cease providing your Personal Information to such third parties at any time thereafter by updating the preference settings in your account on the Platform or by email to us. Upon actual receipt of your request, we shall cease to so use or disclose your Personal Information as soon as practicable without charge to you.
10. Rights of access, correction, and deletion
10.1You can access, edit, update, or delete your Account or Personal Information we have collected at any time by accessing your account settings or emailing us at support@blancblock.com. We reserve the right to charge a reasonable fee for processing any data access request, as may be notified to you via publication or posting on our Website or any other means for the giving of notices and communications per the Terms.
10.2We will respond to your requests within a reasonable period of time, but no later than the time period required by law. Please note that notwithstanding the foregoing, there may be circumstances in which we are unable to accommodate a request to edit, update, access, or delete an account profile or Personal Information. This includes but is not limited to:
(a)any basis where such request can be denied under applicable law;
(b)where we need to retain the information to comply with federal, state, or local laws or for accounting or tax purposes;
(c)where we need to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
(d)where we need to cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third parties reasonably and in good faith believes may violate federal, state, or local law;
(e)where we need to retain information to exercise or defend legal claims;
(f)where the information contains legal privilege or proprietary information of another party; or where complying with the request would compromise others’ privacy or other legitimate rights.
10.3If we determine that we cannot respond to any request in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement for verifying your identity.
11.Transfer of Personal Information
11.1We may store your Personal Information on servers located in the countries where our main offices are located. If such jurisdiction is outside your jurisdiction of residence, you consent to the transfer of your Personal Information to such jurisdiction for purposes of providing the services of Platform to you, even if such other jurisdiction has less protections for Personal Information than your jurisdiction of residence. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and confidentially in accordance with this Policy and the applicable laws.
12.Retention of Personal Information
12.1For the purpose of compliance with the applicable law, and to enable the provision of our Services to you, we will retain any personal information which you have provided to us or which we otherwise collect in accordance with this Policy throughout the continuance of your use of our Platform and Services and for a period required by applicable law or order, direction or request of the relevant authorities after the termination of your account with us (the “Retention Period”).
12.2After the expiration of the Retention Period, we will, unless prohibited by applicable law, erase, delete and destroy your Personal Information held by us and take practicable measures to ensure that our Affiliates, agents and third-party service providers to which we have disclosed your Personal Information in accordance with this Policy do the same. As we may engage third-party data processors to process Personal Information on our behalf, we would adopt reasonable safeguards and procedures (including by contractual means) to prevent any Personal Information transferred to the data processor from being kept longer than is necessary for the processing of such Personal Information.
13. LIMITATION OF LIABILITY
13.1We shall in no event be liable to you in respect of any claims, losses, damages, expenses (including any legal fees) arising out of or in connection with the use, processing, retention and/or disclosure or dissemination of any Personal Information in accordance with this Policy and any consents or authorisations that you may have otherwise provided to us.
13.2Without prejudice to the generality of Clause 13.1, in no circumstances shall we be liable to you or any other person:
(a)for lost profits, lost revenues, lost business opportunities, lost data, other intangible losses or any punitive, exemplary, special, incidental, indirect or consequential losses or damages, regardless of whether such losses or damages were direct or indirect, foreseeable or unforeseeable, and whether we and our Affiliates, agents and representatives have been advised of the possibility of such damages;
(b)for any loss or damage arising from or in connection to:
(i)any act or omission on the part of any third parties (including any third-party agents and service providers); or
(ii)an unusual or unforeseeable event outside our reasonable control and/or the consequences of which could not have been avoided even if all due care had been exercised; or
(iii)resulting from hacking, tampering, virus transmission or other unauthorised access or use of the Platform and/or the Services or any information, feature or functionality contained therein.
14.Children Under the Age of Majority
Our Platform is not designed for any persons or users under the age of majority. If we discover any persons not attaining the age of majority providing Personal Information to us, we shall remove such information from our systems.
15.Contact Us
If you have questions about this Policy or would like to make a complaint, please contact us via our live chat services or at privacy@blancblock.com.
16.Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please ensure to conduct periodically checking. We will post any changes to this Policy on the Platform. If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Platform or providing a push notification through the website (you should make sure your website settings allow for such push notifications) or sending an email that you have provided in your Account, (for this reason you should make sure to update your account information promptly if it changes). By continuing to use our Services and website after the changes come into effect (namely the date on which the updated Policy is posted on our Platform or such other effective date as stated in the updated Policy or other written notice to you), you are deemed to have accepted the revised or updated Privacy Policy and will be bound by it accordingly. If you disagree with the terms of this Policy or any such changes or updates, you should immediately cease to use our Services.