Privacy Policy

SPIRIT Blockchain Capital Inc. and its subsidiaries respect and protect the privacy of the visitors to SPIRIT Blockchain Capital Inc. website and SPIRIT Blockchain Capital Inc. clients who use SPIRIT Blockchain Capital Inc. Services. To ensure transparency, this Privacy Policy describes SPIRIT Blockchain Capital Inc. (and its subsidiaries) information handling practices when you access content of SPIRIT Blcockahin Capital Inc. website located at spiritblockchain.com (http://www. spiritblockchain.com/), and when you are a client of SPIRIT Blockchain Capital Inc. or its subsidiaries.

Acceptance of the privacy policy

By accessing and using SPIRIT Blockchain Capital Inc.s Services, you signify that you have reviewed the terms of this Privacy Policy. Where SPIRIT Blockchain Capital Inc. requires your consent to process your personal information, SPIRIT Blockchain Capital Inc. will ask for your consent to the collection, use, and disclosure of your personal information as described further below. SPIRIT Blockchain Capital Inc. may provide additional „just-in-time“ disclosures or additional information about the data collection, use, and sharing practices of specific Services. These notices may supplement or clarify SPIRIT Blockchain Capital Inc.s privacy practices, or may provide you with additional choices about how SPIRIT Blockchain Capital Inc. processes your data.

If you do not agree with, or you are not comfortable with, any aspect of this Privacy Policy, you should immediately discontinue access or use of SPIRIT Blockchain Capital Inc.s Services.

Changes to this privacy policy

SPIRIT Blockchain Capital Inc. reserves the right to modify this Privacy Policy at any time, and when required by law, SPIRIT Blockchain Capital Inc. will notify you of changes to this Privacy Policy. If SPIRIT Blockchain Capital Inc. makes any material changes, SPIRIT Blockchain Capital Inc. will notify you by email (sent to the email address specified in our database), or by means of a notice on SPIRIT Blockchain Capital Inc.’s Services prior to the change becoming effective.

Personal information collected by SPIRIT Blockchain Capital Inc.

Personal information is data that can be used to identify you directly or indirectly, or to contact you. SPIRIT Blockchain Capital Inc.’s Privacy Policy covers all personal information that you voluntarily submit to SPIRIT Blockchain Capital Inc. and that SPIRIT Blockchain Capital Inc. obtains from SPIRIT Blockchain Capital Inc.’s partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you.

You may be asked to provide personal information at any time that you are in contact with any of the SPIRIT Blockchain Capital Inc. companies. The SPIRIT Blockchain Capital Inc. companies may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve SPIRIT Blockchain Capital Inc.’s products, services, and content (see the section below).

Except as described in this Privacy Policy, SPIRIT Blockchain Capital Inc. will not give, sell, rent, or loan any personal information to any third party.

Personal information collected

SPIRIT Blockchain Capital Inc. collects personal information to provide you with SPIRIT Blockchain Capital Inc.’s Services. When SPIRIT Blockchain Capital Inc. requires specific personal information from users, it is because such information is relevant for certain purposes. Any information you provide to SPIRIT Blockchain Capital Inc. that is not required is voluntary.

For example, SPIRIT Blockchain Capital Inc. collects personal information when you use or request information about SPIRIT Blockchain Capital Inc.’s Services, subscribe to marketing communications, request support, complete surveys, or sign up for a SPIRIT Blockchain Capital Inc. event or webinar. SPIRIT Blockchain Capital Inc. may also collect personal information from you offline, such as when you attend one of SPIRIT Blockchain Capital Inc.’s events, or when you contact your relationship manager. SPIRIT Blockchain Capital Inc. may use this information in combination with other information SPIRIT Blockchain Capital Inc. collects about you.

You are free to choose whether to provide SPIRIT Blockchain Capital Inc. with the types of personal information described below, but SPIRIT Blockchain Capital Inc. may not be able to serve you as effectively, or offer you some or all of SPIRIT Blockchain Capital Inc.’s Services, when you choose not to share certain information with SPIRIT Blockchain Capital Inc.

Here are some examples of the types of personal information SPIRIT Blockchain Capital Inc. collects and how SPIRIT Blockchain Capital Inc. may use it: When you become a Client of SPIRIT Blockchain Capital Inc. (or its subsidiaries, respectively), SPIRIT Blockchain Capital Inc., or SPIRIT Blockchain Capital Inc.’s external service provider may collect personal information. The following information may be collected: your name, date of birth, personal ID or passport, address, phone, email, full bank account details, tax or corporate identification number, company legal status, information that SPIRIT Blockchain Capital Inc. needs for establishing the controlling person of operating legal entities and partnerships or regarding the identity of the beneficial owner of non-operating entities or information regarding individuals with signatory powers (first and last name, address, email, curriculum vitae), or authorised traders (first and last name, nationality, date of birth, etc.). SPIRIT Blockchain Capital Inc. will use this information to fulfill your requests and provide the relevant Services.

Whenever you contact SPIRIT Blockchain Capital Inc. or respond to SPIRIT Blockchain Capital Inc.’s communications (e.g., email, telephone, in writing), SPIRIT Blockchain Capital Inc. will receive your contact information and any other personal information you choose to provide SPIRIT Blockchain Capital Inc. SPIRIT Blockchain Capital Inc. will use such information to fulfill your requests or to provide Services.

How personal information is used

SPIRIT Blockchain Capital Inc.’s primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, SPIRIT Blockchain Capital Inc. uses personal information to create, develop, operate, deliver, and improve SPIRIT Blockchain Capital Inc.’s Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how SPIRIT Blockchain Capital Inc may use this information include:

  • To provide you with SPIRIT Blockchain Capital Inc.’s Services and the client support that you request.
  • To process transactions and send notices about your transactions.
  • To verify your identity by comparing your personal information against third-party databases.
  • To send administrative or account-related information to you.
  • To better understand SPIRIT Blockchain Capital Inc.’s clients and the way they use and interact with SPIRIT Blockchain Capital Inc.-owned and/or SPIRIT Blockchain Capital Inc.-operated websites and Services.
  • To provide a personalised experience, and to implement the preferences that you request.
  • To customise, measure, and improve SPIRIT Blockchain Capital Inc. and the content and layout of SPIRIT Blockchain Capital Inc.’s website and applications.
  • To enhance security, prevent fraud, monitor and verify identity or service access, and to combat spam or other malware or security risks.
  • To deliver marketing, service update notices, and promotional offers based on your communication preferences.
  • To communicate with you about SPIRIT Blockchain Capital Inc.’s events and/or SPIRIT Blockchain Capital Inc.’s partner events.
  • To prevent and investigate potentially prohibited or illegal activities, and/or violations of SPIRIT Blockchain Capital Inc.’s posted user terms.
  • To resolve disputes, collect fees, and troubleshoot problems.
  • To comply with legal obligations.
  • To enforce SPIRIT Blockchain Capital Inc.’s agreements with third parties.
  • For quality control and staff training.

SPIRIT Blockchain Capital Inc. will not use your personal information for purposes other than those SPIRIT Blockchain Capital Inc. has disclosed to you without your permission. From time to time, SPIRIT Blockchain Capital Inc. may request your permission to allow SPIRIT Blockchain Capital Inc. to share your personal information with third parties. You may choose not to have your personal information shared with third parties where SPIRIT Blockchain Capital Inc. relies on consent as the lawful basis for processing your personal information. You may also choose not to allow SPIRIT Blockchain Capital Inc. to use your personal information for any purpose that is incompatible with the purposes for which SPIRIT Blockchain Capital Inc. originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or SPIRIT Blockchain Capital Inc. Services may not be available to you.

Information from third party sources

From time to time, SPIRIT Blockchain Capital Inc. may obtain information about you from third party sources as permitted by applicable law, such as public databases and ID verification partners: SPIRIT Blockchain Capital Inc. obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publically available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for such processing is to comply with SPIRIT Blockchain Capital Inc.’s legal obligations, such as anti-money laundering laws. In some cases, SPIRIT Blockchain Capital Inc. may process additional data about you based on public interest grounds to ensure SPIRIT Blockchain Capital Inc.’s Services are not used fraudulently or for other illicit activities.

SPIRIT Blockchain Capital Inc. also processes such information to provide support to you as part of SPIRIT Blockchain Capital Inc.’s contractual obligations to you. Lastly, SPIRIT Blockchain Capital Inc. processes such information in the public interest because it helps SPIRIT Blockchain Capital Inc. monitor, prevent, and detect fraud. Once SPIRIT Blockchain Capital Inc. obtains such information from third parties, SPIRIT Blockchain Capital Inc. will not subsequently share it with any other third parties except as described in this Privacy Policy. This information is shared with SPIRIT Blockchain Capital Inc.’s processors and corporate group, as necessary, to perform the Services.

Collection and use of information collected automatically

SPIRIT Blockchain Capital Inc. receives and stores certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly, but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), and your Internet Protocol (IP) address/MAC address/device identifier. For example, SPIRIT Blockchain Capital Inc. automatically receives and records information on SPIRIT Blockchain Capital Inc.’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g., country or city-level location), and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. SPIRIT Blockchain Capital Inc. may also collect information about how your device has interacted with SPIRIT Blockchain Capital Inc.’s website, including pages accessed and links clicked. SPIRIT Blockchain Capital Inc. may use identifiers to recognise you when you arrive at the website via an external link, such as a link appearing on a third party site.

How SPIRIT Blockchain Capital Inc. protects and stores personal information

SPIRIT Blockchain Capital Inc. understands how important your privacy is, which is why SPIRIT Blockchain Capital Inc. maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to SPIRIT Blockchain Capital Inc.

SPIRIT Blockchain Capital Inc. may store and process all or part of your personal and transactional information, including certain payment information, in Switzerland, and elsewhere in the world, where SPIRIT Blockchain Capital Inc.’s service providers are located. SPIRIT Blockchain Capital Inc. protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, SPIRIT Blockchain Capital Inc. uses computer safeguards such as firewalls and data encryption, SPIRIT Blockchain Capital Inc. authorises access to personal information only for those employees who require it to fulfill their job responsibilities.

However, SPIRIT Blockchain Capital Inc. cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with SPIRIT Blockchain Capital Inc.’s Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify SPIRIT Blockchain Capital Inc. immediately if you become aware of any unauthorised access to or use of your account.

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

How SPIRIT Blockchain Capital Inc. protects and stores personal information

SPIRIT Blockchain Capital Inc. takes care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. SPIRIT Blockchain Capital Inc. will never sell or rent your personal information. SPIRIT Blockchain Capital Inc. will only share your data in the following circumstances:

  • SPIRIT Blockchain Capital Inc. may share your information with service providers under contract who help with parts of SPIRIT Blockchain Capital Inc.’s business operations such as marketing and technology services. SPIRIT Blockchain Capital Incs.’s contracts require these service providers to only use your information in connection with the services they perform for SPIRIT Blockchain Capital Inc., and prohibit them from selling your information to anyone else.
  • SPIRIT Blockchain Capital Inc. shares your information with financial institutions with which SPIRIT Blockchain Capital Inc. partners to process payments you have authorised.
  • SPIRIT Blockchain Capital Inc. may share your information with companies, or other entities that SPIRIT Blockchain Capital Inc. plans to merge with or be acquired by. Should such a combination occur, SPIRIT Blockchain Capital Inc. will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
  • SPIRIT Blockchain Capital Inc. may share your information with any third parties where required to do so by applicable law or any court or other authority to which SPIRIT Blockchain Capital Inc. is subject in any jurisdiction; or SPIRIT Blockchain Capital Inc. believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the SPIRIT Blockchain Capital Inc. Agreements and any other applicable policies.
  • SPIRIT Blockchain Capital Inc. may share your information with other third parties with your consent or direction to do so.

How SPIRIT Blockchain Capital Inc. share personal information with other parties

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting your relationship manager. However, this right is limited where personal information is needed for regulatory purposes.

If you decide to end your client relationship, SPIRIT Blockchain Capital Inc. will mark your account in SPIRIT Blockchain Capital Inc.’s database as „Closed,“ but will keep your account information in SPIRIT Blockchain Capital inc.’s database for a period of time as allowed by applicable law. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by SPIRIT Blockchain Capital Inc. for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

Rights in the relation to the use of your personal information

You have a right of access to the personal information that SPIRIT Blockchain Capital Inc. holds about you under the Federal Act on Data Protection (and the General Data Protection Regulation) and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

You can object to SPIRIT Blockchain Capital Inc.’s use of your personal information for direct marketing purposes at any time, and you may have the right to object to SPIRIT Blockchain Capital Inc.’s processing of some or all of your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact SPIRIT Blockchain Capital Inc. as set out below.

Retention of personal information

SPIRIT Blockchain Capital Inc. will retain your personal data for as long as is necessary for the purposes of SPIRIT Blockchain Capital Inc.’s business relationship with you, to perform SPIRIT Blockchain Capital Inc.’s contractual obligations to you, or if longer, as required for legal and regulatory purposes.

Changes to this privacy policy

SPIRIT Blockchain Capital Inc. may periodically post changes to this Privacy Policy on this page. SPIRIT Blockchain Capital Inc. encourages you to visit this page often. When required by law, SPIRIT Blockchain Capital Inc. will notify you of any changes to this Privacy Policy. If SPIRIT Blockchain Capital Inc. makes any material changes SPIRIT Blockchain Capital Inc. will notify you by email (sent to the email address specified in your account), or by means of a notice on SPIRIT Blockchain Capital Inc.’s Services prior to the change becoming effective.

SPIRIT Blockchain Capital Inc. , November 2018