PRIVACY POLICY
BACKGROUND:
This Policy applies as between you, the User of the Website and us, BNK To The Future Capital SPC acting for and on behalf of BNK To The Future BFT SP (“Issuer”), the provider of the Website. This Policy applies to our use of any and all data collected by us in relation to your use of the Website in connection with any application by you to register for and to participate in the Public Token Sale of BFT.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Data”
means collectively all information that you submit to the Issuer via the Website. This definition shall, where applicable, incorporate the definitions provided in Cayman Islands common law and the Confidential Relationships Preservation Law (as revised) of the Cayman Islands (the “CRPL”);
“Cookie”
means a small text file placed on your computer by the Website when you visit certain parts of the website and/or when you use certain features of the website. Details of the cookies used by the Website are set out in Clause 13;
“Issuer”
means BNK To The Future Capital SPC acting for and on behalf of BNK To The Future BFT SP;
“User”
means any third party that accesses the website and is not employed by the Issuer and acting in the course of their employment; and
“Website”
means the website that you are currently using (https://bnktothefuture.com/bf-token) and any sub-domains, sister domains of this site unless expressly excluded by their own terms and conditions.
Terms used but not otherwise defined hereunder shall have the meanings set forth in the “BNK TO THE FUTURE BFT SP – BFT PUBLIC TOKEN SALE TERMS & CONDITIONS”, as such terms may be modified, amended, supplemented, replaced or updated from time to time, and as made available to Users by the Issuer via the Website.
2. Scope of this Policy
This Policy applies only to the actions of the Issuer and Users with respect to the Website. It does not extend to any websites that can be accessed from the Website including, but not limited to, any links we may provide to social media websites.
3. Data Collected
Without limitation, any of the following data may be collected by the Website from time to time:
- Name;
- Date of birth;
- Gender;
- Job title;
- Profession;
- Contact information such as email addresses; telephone/mobile numbers; residential address and profile details from social media;
- Demographic information such as post code, preferences and interests;
- Financial information such as credit / debit card numbers; bank details; e-money details such as MangoPay, GoCardless, PayPal, Crypto-Currency Wallets etc. business plan of financial information; company accounts;
- IP address (automatically collected);
- Web browser type and version (automatically collected);
- Operating system (automatically collected);
- A list of URLs starting with a referring site, your activity on the Website, and the site you exit to (automatically collected);
- Other information/data that may be collected but not limited to are CCJ; personal and business credit rating; anti money laundering details; social media data; Companies Registry; records of payments and services used with the Issuer
4. Our Use of Data
4.1 Any personal data you submit will be retained by the Issuer during your use of the Website and a minimum of 7 years after the completion or termination of the Public Token Sale.
4.2 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This restriction on disclosure does not apply to our affiliates and / or other companies within our group (including without limitation and for the avoidance of doubt, to Bnk To The Future, the Cayman Islands company that is referenced in the “COMPANY DETAILS” section below).
4.3 All personal data is stored securely in accordance with the principles in Cayman Islands common law and the CRPL. For more details on security see Clause 13 below.
4.4 Any or all of the above data may be required by us from time to time in order to provide you with the best possible service and experience when using the Website. Specifically, Data may be used by us for the following reasons:
- Internal record keeping;
- Improvement of our products / services;
- Transmission by email of promotional materials that may be of interest to you;
- Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the website.
5. Other Third Party Agreements
The Issuer may use credit / ID agencies to perform a search on individuals. This search will not be visible to members and will not impact your own credit rating. The search will be performed only with your prior permission.
The Issuer will also perform ID verification on all applicants for the Public Token Sale. Copies of ID’s are stored in our servers in compliance with this privacy policy. ID verification information will also be used for the assessment of anti-money laundering, client due diligence, counter terrorism financing checks and your eligibility to participate in the Public Token Sale.
6. Other Agreements
In addition to this privacy policy, the Terms, and any disclaimers or risk warnings published on the Website apply to you and everyone else who uses the Website.
7. Third Party Websites and Services
The Issuer may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing and delivery of purchased items. The providers of such services may have access to certain personal data provided by users of the Website.
Any data used by such parties is used only to the extent required by them to perform the services that the Issuer requests. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties shall be processed within the terms of this policy and in accordance with Cayman Islands common law and the CRPL.
8. Links to Other Websites
The Website may, from time to time, provide links to other websites. The Issuer has no control over such websites and is in no way responsible for the content thereof. This policy does not extend to your use of such websites. Users are advised to read the privacy policy or statement of other websites prior to using them.
9. Changes of Business Ownership and Control
The Issuer may sell and/or transfer control of all or part of the Website. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this policy, be permitted to use the data for the purposes for which it was originally supplied to us.
In the event that any data submitted by users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. You will not be given the choice to have your data deleted or withheld from the new owner or controller.
10. Your right to withhold information
You may access certain areas of the Website without providing any data at all. However, to use all features and functions available on the website you may be required to submit certain data.
You may restrict your internet browser’s use of Cookies. For more information see Clause 13.
11. Accessing your own Data
You have the right to ask for a copy of any of your personal data held by the Issuer (where such data is held) on payment of a fee which will not exceed $75.
12. Security
Data security is of great importance to the Issuer and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected via the Website.
Specifically we use the following systems:
- Our system is protected behind a hardware firewall, which is port restricted.
- Our system uses a Comodo Instant SSL Certificates for secure site traffic transfer for all secure areas of the website.
13. Cookies
The Website may place and access certain first party cookies on your computer. First party cookies are those placed directly by the Issuer via the Website and are used only by the Issuer. The Issuer uses cookies to improve your experience of using the website and to improve our range of products and services. The Issuer has carefully chosen these cookies and has taken steps to ensure that your privacy is protected and respected at all times.
By using the Website you may receive certain third party cookies on your computer. Third party cookies are those placed by websites and/or parties other than the Issuer. Third party cookies are used on the Website for external social media profiles, and are detailed in full below. These cookies are not integral to the services provided by the website.
All Cookies used by the Website are used in accordance with current Cayman Islands common law and the CRPL.
Before any cookies are placed on your computer, you will be presented with a pop-up / message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling the Issuer to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of the website may not function fully or as intended. You will be given the opportunity to allow only first party cookies and block third party cookies.
Certain features of the Website depend upon Cookies to function. Cayman Islands common law deems these Cookies to be “strictly necessary”. These cookies are shown below. Your consent will not be sought to place these cookies. You may still block these cookies by changing your internet browser’s settings as detailed below.
The following first party Cookies may be placed on your computer:
Name of Cookie: _BankToTheFuture_session
Purpose: For keeping track of user session
Strictly Necessary? Yes.
The Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how users use the Website. This, in turn, enables us to improve the Website and the products and services offered through it. You do not have to allow us to use these cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable us to continually improve our business.
The analytics services used by the Website use cookies to gather the required information. Certain of these cookies may be placed immediately when you decide to visit the Website and it may not be possible to obtain your prior consent.
The analytics services used by the Website use the following cookies:
Name of Cookie: _utma
First / Third Party: Third Party
Provider: Google Analytics
Purpose: Identifying Unique Visitors
Name of Cookie: _utmc
First / Third Party: Third Party
Provider: Google Analytics
Purpose: Determining Visitors Session
Name of Cookie: utmz
First / Third Party: Third Party
Provider: Google Analytics
Purpose: Tracking Traffic Sources & Navigation
You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
14. Changes to this Policy
The Issuer reserves the right to change this policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the policy on your first use of the website following the alterations.
COMPANY DETAILS
The Issuer is a segregated portfolio of BNK To The Future Capital SPC (the “SPC”), a segregated portfolio company incorporated in the Cayman Islands, with registered office CO Services Cayman Islands, P.O. Box 10008, Willow House, Cricket Square, KY1-1001, Cayman Islands. The SPC is controlled by Bnk To The Future (a company incorporated in the Cayman Islands and registered with the Cayman Islands Monetary Authority (registered no. 1189274) as an excluded person under the Securities Investment Business Law (as revised) of the Cayman Islands), as holder of the SPC’s voting management shares.