PRIVACY POLICY.

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Last updated on 15 September 2022



1. ABOUT THIS PRIVACY POLICY

1.1 This Privacy Policy sets forth the handling practices of CryptoBLK Limited, a company incorporated under the laws of Hong Kong with company registration number 2529453 and having its own office of business at Units 505 – 510, 5/F., 1E Core Building, 1 Science Park East Avenue, Hong Kong Science Park, Shatin, New Territories, Hong Kong (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively calledCryptoBLK”, “we”, “our” or “us”) in regard to the collection, usage and disclosure of personal information or personal information that you may provide to us through using this website https://kentro.network) and our platform, namely Kentro (collectively the “Platform”), or by using any product or service provided by us via the Platform (the “Services”). 

 

  1. 1.2 CryptoBLK is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, CryptoBLK is committed to the appropriate protection and use of personal information that has been collected online. 

 

  1. 1.3 If you do not accept this Privacy Policy and/or do not meet and/or comply with the provisions set forth herein, then you should not use our Platform. 

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2. TYPES OF INFORMATION WE COLLECT

  1. 2.1 The following provides examples of the type of information that we collect from you and how we use that information.  

Context
Types of data
Primary purpose for collection and use of data

 Client information

We collect the full name, company, job title, department information and contact information (including but not limited to physical address for billing, email address and telephone numbers) of our clients and their employees with whom we may interact.  

We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.

Client user account information

We collect personal information from our clients when they create an account to access and use the Services or request certain free Services from our Platform. This information could include business contact information such as name, email address, title, company information, industry, and password for our Services.  

 

We have a legitimate interest in providing account related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with Services.

Contact information of vendors

Users of our Services may ask their vendors or service providers to submit company and security-related information on our Platform (e.g., to complete a security questionnaire). When a user invites a vendor we collect the name and email address of the vendor. 

 

We have a legitimate interest in contacting vendors on behalf of our clients in order to invite them to communicate with companies through our Platform. Among other things, the communication allows our clients to efficiently solicit, and receive, security questionnaires, and allows vendors to efficiently solicit, and transmit, security questionnaires. Additionally, we use this information to fulfill our contract to provide Services which may include soliciting, receiving, transmitting, and hosting responses to security questions. 

Account information of vendors 

We collect personal information from vendors when they create an account to access and use the Services or request certain free Services from our Platform. This information could include business contact information such as name, email address, title, company information, and password for our Services.  

 

We have a legitimate interest in providing account related functionalities to our vendor-users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, in some cases, we use this information to fulfill our contract to provide vendor-users with Services. 

Cookies and first party tracking 

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookies Policy below for further information.

 

We have a legitimate interest in making our Platform operate efficiently.

Cookies and third party tracking 

We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our Platform so that they can provide advertising about products and services tailored to your interests on our Platform, or on other websites. See our Cookies Policy below for more information.  

 

We have a legitimate interest in understanding our users and providing tailored services.

Demographic information 

We use IP information to 1) ensure the legality of our documents (under eSignature law); 2) understand how user behavior varies in different locations in order to improve our Services; 3) depending on location, provide a better support and success service.  

 

We have a legitimate interest in ensuring that our Services is legal and providing tailored services based on the location (Country) – such as appropriate 1) support, 2) contract content, and 3) templates. IP information will not be used for other purposes absent explicit consent. 

Email interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

 

We have a legitimate interest in understanding how you interact with our communications to you. Such data capture will only be deployed following receipt of explicit consent. 

Feedback/Support 

We collect personal information from you contained in any inquiry you submit to us regarding our Platform or Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script.

 

We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.

Mailing list

When you sign up for one of our mailing lists, we collect your email address. 

 

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. 

Marketing data 

When you subscribe to one of our mailing list(s), we collect your email address.  

 

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. 

Mobile device data 

We collect information from your mobile device when visiting our Platform. Such information may include operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information. 

 

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. 

Financial Data

Subsequent to Service enrollment (where we collect name, email and phone number, job role, company name and size), to place an order, we collect payment information for example, your billing address, bank account and credit card details. 

 

We use your information to perform our contract to provide you with products or services. 

Surveys 

When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Participation in any such surveys is completely voluntary and you therefore have a choice whether to disclose such information.  

 

We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. 

Platform interactions 

We use technology to monitor how you interact with our Platform. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. 

 

We have a legitimate interest in understanding how you interact with our Platform to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. 

Web logs 

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. 

 

We have a legitimate interest in monitoring our networks and the visitors to our Platform. Among other things, it helps us understand which of our services is the most popular. 

2.2 We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources, including:
(a) our personnel, agents, advisors, consultants, and contractors in connection with our operations or Services;

(b) other users of our Services;

(c) other services linked to your account, for example if you register or log in your account using your Google credentials, we receive your name and email address to authenticate you, as permitted by your Google profile settings;

(d) our group companies or overseas offices that provide information technology services, system administrative services, and marketing services; and

(e) our business partners and service providers who provide technical, payment, delivery services, advertising networks, analytics, market research, and search information services.

3. USE AND PROCESSING OF PERSONAL INFORMATION

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3.1 We only use your personal information where the law allows us to. We use your personal information only where: 

  1. (a) we need to perform the contract we have entered into (or are about to enter into) with you, including to operate and provide our Services, to provide customer support and personalised features, and to protect the safety and security of our Platform; 

  2. (b) it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests; 

  3. (c) you have given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; 

  4. (d) we need to comply with a legal or regulatory obligation


3.2 Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.
In addition to the purposes and uses described above, we use information in the following ways: 
 
  1. (a) to identify you when you visit our Platform.  

  1. (b) to conduct analytics. 

  1. (c) to respond to inquiries related to support, employment opportunities, or other requests;or 

  1. (d) for internal administrative purposes, as well as to manage our relationships. 

4. SHARING OF INFORMATION

4.1 In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share personal information in the following situations: 
  1. (a) Affiliates and acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.  

  2. (b) Other disclosures with your consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this this Privacy Policy.

  3. (c) Other disclosures without your consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary. We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

  4. (d) Public. The Platform may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.  

  5. (e) Service providers. We share your information with our service providers. Among other things service providers help us to administer our Platform, send e-mail communications, conduct surveys, provide technical support, detect fraud, process payments, and assist in the fulfillment of orders. Our service providers will be given access to your personal information as is reasonably necessary to provide the Platform and related Services. Our service providers are contractually obligated to use your personal information only at our direction and in accordance with our Privacy Policy; to handle your personal information in confidence; and to not disclose your personal information to unauthorized third parties. Service providers who violate these obligations are subject to appropriate discipline including, but not limited to, termination as a service provider. 

4.2 Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal information with third parties without your consent.   

5. RETENTION OF YOUR PERSONAL INFORMATION

5.1 We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, we will delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it from further use. We periodically review the basis and appropriateness of our data retention policy.
6. HOW WE PROTECT YOUR PERSONAL INFORMATION

6.1 We implement security measures designed to protect your personal information from unauthorized access. We apply these tools based on the sensitivity of the personal information we collect, use, and store, and the current state of technology. We protect your personal information through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access, and unauthorize disclosure and alteration. We periodically review our information collection, storage and processing practices, including technical and organizational measures, to guard against unauthorized access to systems.  Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use.

6.2 While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

6.3 We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.4 By using our Platform, you acknowledge that you understand and agree to assume these risks. personal information.

7. HOW WE STORE AND TRANSFER INFORMATION INTERNATIONALLY

7.1 We collect information globally and primarily store that information online at a cloud solution provided by our service provider.  We may also from time to time transfer, process, and store your information in other server in or outside Hong Kong. 7.2 Some of the countries in which our company or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information. 7.3 While we take reasonable measure to ensure that service providers keep your information confidential and secure, such service provider’s practices are ultimately beyond our control.

8. YOUR PRIVACY RIGHTS

8.1 Applicable data protection legislation may give you as the data subject, various rights in relation to your personal information that we hold and process, which generally include:

(a) Right of access – the right to obtain from us confirmation as to whether or not personal information concerning you is being processed, and, where that is the case, access to that personal information and various other information, including the purpose for the processing, with whom the data is shared, how long the data will be retained, and the existence of various other rights.

(b) Right to rectification – the right to obtain from us, without undue delay, the putting right of inaccurate personal information concerning you. Right to erasure – sometimes referred to as the ‘right to be forgotten’, this is the right for you to request that, in certain circumstances, we delete data relating to you.

(c) Right to restrict processing – the right to request that, in certain circumstances, we restrict the processing of your data.

(d) Right to data portability – the right, in certain circumstances, to receive that personal information which you have provided to us in a structured, commonly used and machine-readable format, and the right to have that personal information transmitted to another controller.

(e) Right to object – the right, in certain circumstances, to object to personal information being processed by us where it is in relation to direct marketing, or in relation to processing supported by the argument of legitimate interest.

(f) Right not to be subject to automated decision making – the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

8.2 In the event that you wish to exercise any of these rights you may do so by:

(a) contacting us using any medium you wish, including in writing, by telephone, by text, electronically, or using such social media as we employ for communication purposes;

(b) by completing a form which we can supply to you for this purpose; or

(c) through a third-party whom you have authorised for this purpose.

 

8.3 Any request under paragraph 8.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

 

8.4 Please note that your rights are not absolute, meaning that in some circumstances, exceptions exist under applicable law. The law may provide exemptions from requests involving your personal information.

9. MARKETING

9.1 We may also wish to provide you with information about special features of our Platform and Services or any other service or products we think may be of interest to you. If you would rather not receive this information, please send an email to [product@cryptoblk.io].

 

9.2 We may also want to provide you with related information from third parties we think may be of interest to you. If you would rather not receive this information, please send an email to [product@cryptoblk.io].   9.3 You may opt out of receiving marketing materials or newspaper from us by using the unsubscribe link in our communications, by updating your preferences within your account on our Platform, or by send an email to [product@cryptoblk.io]. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our Platform and Services.
10. COMPLAINT

10.1 We are committed to resolving valid complaints about your privacy and our collection or use of your personal information.  For questions or complaints regarding our data use practices or this Privacy Policy, please contact us as provided below. Should you remain unsatisfied with our response to your complaint, you have the right to contact your local data protection authority.

11. CHILDREN AND MINORS

11.1 CryptoBLK does not knowingly collect personal information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at:  [product@cryptoblk.io] . By using the Platform, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase and/or use the Services through the Platform.

12. THIRD PARTY WEBSITES AND SERVICES

12.1 We have no control over the privacy practices of websites or applications that we do not own. We are not responsible for the practices employed by any websites and/or services linked to and/or from our Platform, including the information and/or content contained therein. Please remember that when you use a link to go from our Platform to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Platform, are subject to such third-party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

13. CHANGES TO OUR PRIVACY POLICY

13.1 In general, changes will be made to this Privacy Policy to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Platform after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates. You can determine when this Privacy Policy was last revised by referring to the date it was last “Updated” above.

14. CONTACT US

14.1 For questions or complaints regarding our use of your personal information or Privacy Policy or to forward deletion requests, please contact us at: [product@cryptoblk.io]

15. COOKIES POLICY

15.1 We use cookies in connection with the operation of our Platform. A cookie is a small file that is sent by a web server (where we host our Platform) to a web browser (from where you view our Platform) and which is then stored by the browser. The cookie contains an identifier which is stored in your browser and then sent back to our server each time your browser accesses our Platform. These cookies may either be ‘persistent cookies’ (in which case they will continue to be held by your browser until they are deleted, or until a specified event/date) or they will be ‘session cookies’ which expire when you close your browser.

 

15.2 Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings. You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of the Platform’s features.

 

15.3 The cookies that we use fall into following groups:

(a) Essential: these cookies are necessary for the operation of our Platform, or essential to the provision of the Services. These include, for example, cookies that allow you, as a subscriber to our Services, to stay logged in to your account and to access information, sections of our Platform, or Services not generally available to non-subscribers. If you block these cookies you will not be able to access the Services (which you may have paid for).

(b) Performance: these cookies measure how often you visit our Platform and how you use them. They also allow us to calculate the number of visitors to our Platform, see what those visitors do on our Platform, how long they spend on the Platform, and which links they click. These cookies help us to improve how our Platform works, and enable us to make changes so that users stay longer or return more often. If you block these cookies, we will not be able to improve our Services as easily.

(c) Targeting: similar to performance cookies, these cookies tell us which pages you visit, and the links you follow, so that we can make our Platform more relevant to your interests. If you block these cookies, we will be unable to improve the experience our users get from our Platform.

(d) Functionality: these cookies make sure that you and your preferences are remembered when you return to our Platform. That means that you can store data that you wish to return to, complete logs as to what you have seen/used on the Platform, and generally allow us to provide you with a more personalised experience. If you block these cookies you may have reduced functionality, or not be able to store personal preferences.

(e) Advertising: these collect information about your visit to our Platform, such as what you have looked at and the links you have followed, so that we can target our advertising at you, or exclude certain types of advertising that would not interest you. We can also gather information about your browser, device and your IP address. If you block these cookies, you may receive advertising that is not relevant to you.

(f) Third party cookies: these are used where we use third-party applications on our Platform to customise the Services, or to provide an increased functionality. They may relate to the use of social media, or the use of another complementary service. If you block these cookies you may not be able to access the Services that you want to use.