Please also use the Glossary at the end of this document to understand the meaning of some of the terms used in this policy.
1) Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Tokenise is made up of different legal entities which collectively provide services to and are responsible for this Tokenise Platform:
Tokenise International Limited – Registered in Gibraltar at 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA (Reg no 114255).
Kession Capital Limited, trading as Tokenise – Registered in England and Wales at 42 Lytton Road, Barnet, Hertfordshire, EN5 5BY (Reg no. 07987057), trading address is 7th floor, Hyde House, London NW9 6LH. Kession Capital Limited is authorised and regulated in the UK by the Financial Conduct Authority (Firm Reference Number: 582160).
Daxnet BB (Barbados) Ltd – Registered in Barbados at Burnham Court, Bishops’ Court Hill, Upper Collymore Rock, St. Michael, Barbados (Reg no.42799). Daxnet BB (Barbados) Ltd is authorised as a Self-Regulatory Organisation by the Financial Services Commission.
Kession Captial International Limited – Registered in Barbados at Burnham Court, Bishops’ Court Hill, Upper Collymore Rock, St. Michael, Barbados (Reg no. 42895).
These entities may change from time to time.
When We change the contents/conditions of Our existing privacy statements and or notices We will take all measures necessary to ensure that any changes are communicated to you in such a way that will ensure that you will actually notice them and read them.
This means, for example, that a notification of changes will be communicated by way of an appropriate means (e.g. email/ hard copy letter etc.) specifically devoted to those changes.
This version was last updated on 6 August 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- The Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from or through us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
- How is your Personal Data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section ‘Use of our Cookies’ below further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers based inside or outside the EU;
(b) advertising networks based inside or outside the EU; and
(c) search information providers based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
- Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside or outside the EU.
- KYC/AML services providers based inside and outside the EU.
- How we use your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note: we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your subscriptions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or policies
(b) Asking you to leave a review or take a survey
(c) Dealing with complaints
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. You may unsubscribe here: firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
A Cookie is a small text file that is placed and stored on your computer, mobile or other devices by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information about visitor behaviors to the website owner. The Cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. All cookies used by and on Our Site are used in accordance with the current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. by giving your consent here you are enabling Us to provide the best possible experience and service to you.
You can also choose to delete Cookies on your computer or device at any time. Here is a list of the Cookies We use:
|__cfduid||Cookie associated with sites using CloudFlare, used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information.|
|_ga||Used by Google Analytics to distinguish users.|
|_gat_gtag_UA_116829625_2||Google Analytics cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where Visitors have come to the site from, and the pages they visited.|
|_gid||Used by Google Analytics to distinguish users.|
- Disclosure of your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the above.
- Internal Third Parties – Other companies in Tokenise acting as joint controllers or processors and who are based inside and outside of the EEA and provide IT and system administration services and undertake leadership reporting.
- External Third Parties:
- Service providers based inside and outside the EEA who provide KYC/AML services.
- Service providers based inside and outside the EEA who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in inside and outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based inside and outside the EEA.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International Transfers
We will share your personal data within Tokenise. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- How and where we store your data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
The data that we collect from you may be transferred to, and stored at, a destination inside or outside the European Economic Area (“EEA”). It may also be processed by staff operating inside or outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. Access to your information is limited to those who have a need to manage it. Where your information is transferred from the EEA to a country that is not subject to an adequacy decision by the EU Commission, we will seek to ensure that it is adequately protected by (i) ensuring that EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules are in place or (ii) relying on derogations (e.g. contractual necessity). A copy of the relevant mechanism can be provided for your review on request, using the contact details provided below.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Data subjects may submit a Subject Access Request – to obtain a copy of the personal data that we hold about them in a structured and portable manner.
To make a Subject Access Request please write to Michael Kessler at:
Tokenise, 7th Floor, Hyde House, Edgware Road, London, NW9 6LH.
You will need to provide the following documentation for verification purposes:
- Your full name, address and any reference number We hold for you,
- Identification documents showing name, address and signature;
- A copy of your driving licence (shows all 3) or
- A copy of your passport and a recent utility bill or bank statement.
We will seek to ensure that inaccurate or incomplete data will be rectified. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details above).
Request erasure (Right to be forgotten)
You can notify Us if you wish to exercise your right to erasure. Such a withdrawal of consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact. We may retain a copy of any personal data if the processing is necessary for the establishment, exercise or defence of legal claims.
Object to processing
You can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
You can request a transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data, you have the right to withdraw this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Make a complaint
If you have any cause for complaint about our use of your personal data, please contact us using email@example.com. We will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (www.ico.org.uk).
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- How to Contact Us
Email Us on: firstname.lastname@example.org
Write to us:
The Tokenise Team