- 1.2. This Policy governs the provision by Volley token of the services (“Services”) on the website [https://volleytoken.io/] (“Website”) as well as the operation of the Website for users and visitors (collectively, “Users” and “you”), and your usage or browsing of the Website and the Services.
- 1.3. Users of our Website are to read this Policy carefully and to refer to it as and when required. By accessing and using our Website, you are deemed to have accepted and agreed to Volley token’s practices as described in this Policy, and undertaken to comply with the Users’ obligations under this Policy. Volley token will ensure its own compliance with the standard of this Policy with regard to any personal data that may come into its possession or control or that which it may process in relation to the operation of the Website.
- 1.4. In the course of our business activities, we and our employees will handle the personal data of individuals (“Individuals”) including but not limited to merchants, consumers, service providers, suppliers, vendors, business associates, clients, customers, enquirers, visitors and general users of our Website.
- 1.5. Volley token recognizes the privacy of individuals and has adopted this Policy which is compliant with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”) to reflect Volley token’s commitment to respect and protect the Individuals’ privacy and personal data.
- 1.6. Volley token is acting as the data controller for our Website and other services that Volley token may offer (collectively referred to as the “Businesses”). All the data, including personal data, of the Individuals that are collected, processed, transmitted, and stored on and through the Website remains in the possession and under the control of the Company.
- 1.7. This Policy outlines the personal data that Volley token collects, how it may be used, how it is stored and retained, whom it may be transmitted to as well as Volley token’s and the Individuals’ responsibilities in relation to such uses and disclosures.
- 1.8. The PDPA recognizes the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organizations to collect, use or disclose personal data for legitimate and reasonable purposes.
2. Collection of information
- 2.1. We may collect and process the following information or data (including personal information and information that can be uniquely identified with individual persons) about the Individuals [client to confirm/amend as required]:
- (a) Full name, including any aliases;
- (b) a Unique identification number, such as an identity card number, birth certificate number, or passport number;
- (c) Residential address or registered or business address
- (d) Date of birth;
- (e) Nationality;
- (f) E-mail address(es) and other contact information that the Individuals may provide to us;
- (g) A record of any correspondence between the Individuals and us on the Website and in connection with the Businesses;
- (h) A record of the activities of the Individuals on the Website and in connection with the Businesses; and
- (i) Information that we may require from clients/users when they report a problem with the Website
- 2.2. We will collect only the information listed in paragraph 2.1 above that is reasonable for us to provide the Individuals with our services.
- 2.3. ain makes a reasonable effort to ensure that the personal data collected is accurate and complete. Volley token will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was initially provided.
- 2.4. Volley token only collects such information when the Individuals choose to supply the same to us. They do not have to supply any personal information to us but they may not be able to take advantage of all the services that Volley token offers without doing so.
- 2.5. Volley tokens may collect, in accordance with applicable laws and, where required, with the User’s consent, information relating to the devices that you use and the networks that you are connected to when using the Website. This may include the following information: your IP address, log-in information, smartphone device brand and type, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Website, products you viewed or searched for, download errors, length of visits to certain pages, and page interaction. We may collect this information through the use of various technologies including cookies.
- 2.6. In the event that your account in respect of the Website is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to the Website, after which we shall cease to retain your personal data.
3. Use of personal data
- 3.1. By using the Website and contacting Volley token, you expressly authorize and consent to Volley token gathering, reviewing, retaining and where reasonably required, transmitting your personal data to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide personal information to Volley token,
- 3.2. Volley token will also take appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations that are in line with the requirements under the PDPA.
- 3.3. Volley token may use this information to [client to confirm/amend as required]:
- (a) Ensure that the content on our Website is presented in the most effective manner for the Individuals and for their personal computers, smartphones, and other devices and customize the Website to their preferences; understand their activities and interests; and optimize our Website’s display of information, and manage our business;
- (b) Provide the Services to the Users and contact the Users on the same;
- (c) Carry out anti-money laundering and counter-financing of terrorism procedures;
- (d) Assist in making general improvements to the Website and our Businesses;
- (e) Profile and segment Users to provide appropriate services according to your needs;
- (f) Troubleshoot any technical issues faced by the Users in the course of usage of the Website;
- (g) Carry out and administer any obligations arising from any agreements entered into between the Individuals and Volley token ;
- (h) Allow the Individuals to participate in features of the Website and other Businesses;
- (i) Communicate with the Individuals by email or other chosen means to send relevant notifications about Volley token’s events and services that may be of interest to them for the purposes of building and promoting Volley token ;
- (j) Contact the Individuals and notify them about changes to the Website or the Businesses that Volley token offers (except where they have expressly requested for us not to do so);
- (k) Analyse how users are making use of the Website for Volley token’s internal marketing and research purposes;
- (l) Ensure that the Individuals comply with Volley token’s terms and conditions and the applicable law;
- (m) Send the Individuals important notifications that they will require in order to use the Website;
- (n) For promotional activities; and
- (o) For enforcement of the Individual’s legal obligations.
4. With whom do we share the Individuals’ information
- (a) Service providers: We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, server hosting, marketing, and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.
- (b) We do not provide any non-anonymized personal information to third parties. We will adhere strictly to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.
- 4.2. Volley token may disclose your information, including personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency, to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.
- 4.3. Volley tokens will not transfer any of the Individuals’ personal data to a country or territory except to organizations that provide a standard of protection to personal data that is comparable to the protection under the PDPA.
5. Third-Party Sites
6. How we protect personal information
- 6.1. Volley token will take security measures to help safeguard your personal information from unauthorized access, collection, use, copying, modification, disposal, and disclosure. However, no system can be completely secure. Therefore, although Volley token takes steps to secure the Individuals’ information, we cannot guarantee that the Individuals’ personal information, activities on the Website, or other communications in relation to the Businesses will always remain secure.
- 6.2. If you wish to delete all of their personal data in our possession, you may email us at [to insert]. Your personal data in our possession will be deleted within 24 hours.
7. Children’s privacy
- Although the Website is for a general audience, Volley token restricts the use of the Website to individuals aged 18 and above. Volley token does not knowingly collect, maintain, or use the personal information of children under the age of 18. It is your sole responsibility to provide your correct birth date.
8. No Third-party Rights
- This Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to the Individuals.
- 9.1. As part of Volley token’s efforts to ensure that we properly manage, protect and process your personal data, we will review our policies, procedures, and processes from time to time.
- 9.2. Volley token reserves the right to amend the terms set forth under this Policy at our sole and absolute discretion.
- 9.3. Volley token will post details of any changes to this Policy on the Website to help ensure that the Individuals are always aware of the information that we collect, how we use it, and in what circumstances if any, that we share it with other parties.
- 9.4. You are encouraged to visit the Website from time to time to ensure that you are well-informed of our latest policies in relation to personal data protection.
10. Specific provisions related to the European Union General Data Protection Regulation (GDPR)
- 10.1. Volley token acknowledges that the GDPR will apply if we process or hold any personal data of individuals residing in the EU (“EU Individuals”) or if we offer goods or services to individuals in the EU.
- 10.2. Volley token will process the personal data of EU Individuals only if consent is provided by the EU Individual for the processing for specific purposes if it is necessary for the performance of a contract or if it is necessary for our compliance with a legal obligation.
- 10.3. Volley token will process the personal data of EU Individuals lawfully, fairly, and transparently, collect and apply the personal data only for specified, explicit, and legitimate purposes, limit the collection of personal data to only what is required, ensure the accuracy of the personal data, not keep the personal data in personally identifiable form for longer than is necessary and secure and protect them in accordance with the GDPR.
- 10.4. Volley token will uphold the following rights of EU Individuals in accordance with the GDPR:
- (a) Right to access and obtain a copy of the EU Individuals’ personal data, including the purposes of processing and to who the personal data has been disclosed;
- (b) Right to rectify inaccurate personal data concerning the EU Individual;
- (c) Right to erasure of personal data concerning the EU Individual in certain circumstances;
- (d) Right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
- (e) Right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used, and machine-readable format, and the right to transmit that data to another organization;
- (f) Right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
- (g) Right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.
- 10.5. We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments, and the need to apply careful consideration in the adoption and engagement of our data processors.
11. Contact & Data Protection Officer
- If at any time you would like to contact Volley token with your views about Volley token’s privacy practices, or with any inquiry or request relating to your Personal Data, including but not limited to, the following:
- · Any request to provide you with your personal data that is in Volley token’s possession or control;
- · Any request to withdraw your consent for the collection, use, and/or disclosure of your personal data;
- · Any inquiry on the ways in which your personal data has been or may have been used or disclosed by Volley token within one year prior to the date of the inquiry; and
- · Any request to correct an error or omission in your personal data,
- you should use one of the following means:
- · Email our Data Protection Officer at [firstname.lastname@example.org]
Volley token will process your request within ten (10) working days from the date on which the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose your personal data.
However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that Volley token will not be able to continue with the existing relationship with you and the contract that you have with us will have to be terminated.