The security and protection of your Personal Data are one of the top priorities of Tritone Capital Management AG., a company duly incorporated under the laws of Switzerland, with registration number CHE-374.578.434 and with an official address at Rue de la Cite 1 | First Floor CH-1204 Geneva, Switzerland (the “Company, “Us” or “We”) which operates a website hosted at the URL www.3ton.io (the “Website”).
The Company shall collect Personal data from both natural or legal persons who browse the Website (the “Visitors”) and from natural persons who are Users of the platform (the “Users”)
The Company uses privacy by default and privacy by design standards and undertakes to store your Personal Data in a secure manner and to process your data with all appropriate care and attention following the Federal Data Protection Act (RS 235.1), the Ordinance on the Federal Data Protection Act (RS 235.11).
“Consent” shall mean any freely given, specific, and informed indication of his or her wishes by which a Data subject signals agreement to the Processing of Personal data relating to him or her;
“Data controller” shall mean the natural or legal person who, alone or jointly with others, determines the purposes and means of the Processing of Personal data and who is in charge of this Processing;
“Data subject” shall mean natural or legal persons whose data is processed, whether it is a User or a Visitor;
“Disclosure” shall mean making Personal data accessible, for example, by permitting access, transmission, or publication;
“Personal data” shall mean all information relating to an identified or identifiable person;
“Personal data breach” shall mean a breach of security leading to the accidental or unlawful destruction, loss, or alteration of – or to the unauthorized disclosure of, or access to – Personal data transmitted, stored, or otherwise processed;
“Processing” shall mean any operation or set of processes – by automated and other means – that is performed upon Personal data or sets of Personal data, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmitting, disseminating or otherwise making available, aligning or combining, or erasing;
“Recipient” means third, public authority, agency, or other body – that is, someone or something other than the Data subject or the Company – to which the Personal Data is disclosed;
The Company provides this Notice to describe its procedures regarding the Processing and Disclosure of Personal data collected by the Company while using the Website.
This Notice shall apply to any use of the Website, whatever the method or medium used. It details the conditions at which the Company may collect, keep, use and save information that relates to you, as well as the choices you have made about the collection, utilization, and disclosure of your data.
By browsing the Website, Visitors acknowledge that the Company may collect and process a certain number of personal data that relate to them and that they have read and understood this Notice and agree to be bound by it and to comply with all applicable laws and regulations.
Users acknowledge that the Company may collect and process a certain number of Personal data related to them and that they have read and understood this Notice and agree to be bound by it and comply with all applicable laws and regulations.
In particular, the Consent for the Processing of Personal data is given once the Visitor and the User tick the box in the pop-up window which says, “I have read the Privacy Notice and agree to it.”
Consent is also given when the Users freely submit to the Company the Personal Data required to become a User and whenever the User connects his cryptocurrency wallet. This confirms that the Company is free to use these Personal Data within the limit provided by law and this Notice
If you disagree with the terms of this Notice, please do not become a User, please do not connect your cryptocurrency wallet, and kindly refrain from using the Website.
4. PRINCIPLE FOR PROCESSING PERSONAL DATA
While Processing Personal data, the Company will respect the following general principle:
a) Fairness and lawfulness
When Processing Personal data, the individual rights of the Data subjects must be protected, and Personal Data must be collected and processed lawfully, in a fair manner, in good faith, and be proportionate to the objective.
b) Restriction to a specific purpose
Personal data handled by the Company should be adequate and relevant to the purpose for which they are collected and processed. This requires, in particular, ensuring that the types of Personal Data collected are not excessive for the purpose for which they are collected. Subsequent changes to the purpose are only possible to a limited extent and require substantiation.
The Data subject must be informed of how his/her Personal Data is being handled. When the Personal data is collected, the Data subject must be informed of:
- the existence of the present Notice;
- the identity of the Data controller;
- the purpose of Personal data Processing;
- third-parties to whom the data might be transmitted.
d) Consent of the Data subject
Personal data must be collected directly from the individual concerned, and the Consent of the Data subject may be required before Processing Personal data. The Consent must be obtained in writing or electronically for documentation purposes. The Consent is valid only if given voluntarily. Suppose, for any reason, the Consent of the Data subject is not given before Processing Personal data. In that case, this one should be secured in writing as soon as possible after the beginning of the Processing.
Personal data can be processed without Consent if it is necessary to enforce a legitimate interest of the Company. Legitimate interests are generally of a legal (e.g., filing, enforcing, or defending against legal claims) or financial (e.g., valuation of companies) nature. The Processing of Personal Data is also permitted if national legislation requests, requires, or allows this.
Personal Data kept on file must be correct and, if necessary, kept up to date. Inaccurate or incomplete Personal data should not be kept on file and deleted.
5. COLLECTED DATA
This Notice applies to all information received during your visit to or use of the Website, when you subscribe to our newsletter, and when you become a User or connect your cryptocurrency wallet.
In particular, the Company will collect the following Personal data:
a) Visitors' data
When you browse the Website, even if you do not subscribe to our newsletter, do not become a User, and do not contact us, the Company automatically:
- collects your cookies;
- uses Google Analytics;
- uses Facebook pixel;
- uses Hotspot;
- uses Intercom;
- uses Hotjar;
- uses Twitter connect.
b) Users' data
When you become a User, the Company shall collect:
- your Ethereum address;
- your email address.
c) Newsletter’s subscriber data
When you, as a Visitor or a User, subscribe to our newsletter, We collect your IP address, name, surname, country of residence, and email address for the sole purpose of sending you our newsletter. Please note that you are entitled to unsubscribe from our newsletter whenever you want and at your sole discretion by contacting us in accordance with Section 19 of this Notice
6. USE OF DATA
The following paragraphs describe the various purposes for which the Company uses your data. Please note that not all of the uses below will be relevant to everyone. Generally, the main reason we collect Personal data is to enable you to enjoy and easily navigate the Website, transfer your tokens to your cryptocurrency wallet, and keep you updated about all developments of the 3TON Project. If you contact us via email to the contacts set out on the Website, We will keep a record of that correspondence.
a) Users data:
Users understand and agree that their transactional information will be made public on the BNB Blockchain Explorer and, therefore, disclosed to anyone. The Company will employ Users’ data to provide them with a better service, and in particular to:
- communicate with them;
- answer their questions and comments;
- prevent potentially prohibited or illegal activities;
- conduct research and compile statistics on usage patterns;
- process transactions;
- manage the accounts;
- comply with our legal requirements;
- as otherwise described to the Users at the point of collection.
b) Collect of the cookies:
c) Use of Google Analytics:
7. THIRD-PARTY DISCLOSURE
The Company may share your data to any other relevant third parties, in particular, if We are requested to do so to comply with a court order or law enforcement authorities request, or if We find it necessary, as determined in the Company’s sole discretion, to investigate, prevent or take action regarding illegal activities, to defend our interest or as otherwise required or permitted by law. Where a cross-border transfer is done, the Company ensures that adequate protection is guaranteed for personal data to be transferred outside of Switzerland and the European Economic Area (hereinafter: the “EEA”). In some specific cases, when this level of protection is not guaranteed, the Company will obtain your prior consent or establish with the Recipient of Personal data a contractual framework or sufficient safeguards that ensure adequate protection abroad. You may request access to a copy of these safeguards by contacting the Company. Unless otherwise stated, the third parties which receive data from the Company are prohibited from using this Personal data beyond what is necessary to provide the product or service to you, directly or by participating in the Company’s activities.
8. STORAGE OF YOUR PERSONAL DATA
Your data will be stored in Europe. You agree that the Company may store your data in any country of the EEA, including Switzerland. The storage and processing of your data may require that your data are ultimately transferred/transmitted to and/or stored at a destination outside of your country of residence. Where permitted by law, by accepting the terms of this Notice, you agree to such transferring, transmission, storing, and/or Processing. You also agree that such activities may eventually occur to or in countries offering a lower level of protection than your country of residence.
9. RETENTION OF YOUR PERSONAL DATA
Following applicable laws, the Company will use your data for as long as necessary to satisfy the purposes for which your data was collected or to comply with applicable legal requirements.
10. SECURITY OF YOUR PERSONAL DATA
The Company applies high industry standards and will always use adequate technical and organizational measures following applicable laws to ensure that your data is kept secure. In the event of a Personal Data breach, the Company shall, without undue delay and wherever feasible, however not later than within 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, the Company shall communicate this breach to you, if feasible, without undue delay.
11. ACCESS TO YOUR DATA AND INFORMATION RIGHTS
You have the right to request access to or information about the Personal Data relating to you that the Company processes. Where provided by law, you, your successors, representatives, and/or proxies may (i) request deletion, correction, or revision of your Personal Data; (ii) oppose the data processing; (iii) limit the use and disclosure of your Personal Data; and (iv) revoke Consent to any of our data processing activities if the Company is relying on your Consent and does not have another legal basis to continue processing your data. These rights can be exercised by contacting us through our contact form or by writing to us at: email@example.com. Before processing your request, we will contact the person submitting the ticket to confirm her/his identity. We reserve the right to choose the communication channel we find most suitable in given circumstances and to request from the submitting person to prove her/his identity in a way we consider trustful. The Company may refuse, restrict or defer the provision of Personal Data where it has the right to do so, for example, if fulfilling the request will adversely affect the rights and freedoms of others.
12. PORTABILITY OF YOUR DATA
You also have the right to receive your Personal Data, which you have provided to the Company, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company. This right can be exercised by writing to us at: firstname.lastname@example.org. , The Company may refuse, restrict or defer the provision of Personal Data where it has the right to do so, for example, if fulfilling the request will adversely affect the rights and freedoms of others.
13. PRIVACY BY DESIGN AND BY DEFAULT
The Company will, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, effectively and to integrate the necessary safeguards into the processing to meet the requirements of the GDPR and protect your rights. The Company will implement appropriate technical and organizational measures to ensure that, by default, only Personal Data necessary for each specific purpose of the processing are processed. This obligation applies to the amount of your Personal Data We collect, the extent of their processing, the storage period, and accessibility. These measures will ensure that, by default, your Personal Data is not made accessible without your intervention to an indefinite number of third parties.
14. CONTACTING THE COMPANY AND COMPLAINTS
The Company hopes to be able to answer any questions or concerns you have about your Personal data. You can contact the Company at the postal address or email address at: email@example.com. You have the right to make a complaint if you feel your data has been mishandled or if the Company has failed to meet your expectations. You are encouraged to contact the Company about any complaints or concerns, but you are entitled to complain directly to the relevant supervisory authority.
15. CHANGES TO THE PRIVACY NOTICE
The Company may modify this Notice from time to time and will post the most current version on the Website. If a modification reduces your rights, a pop-up window will inform you immediately when you browse our Website, and you will have to accept the changes.
16. DATA CONTROLLER
The data controller of the file is Tritone Capital Management AG., Rue de la Cite 1 | First Floor CH-1204 Geneva, Switzerland (CHE-374.578.434).
18. JURISDICTION AND GOVERNING LAW
This Notice and any questions relating to it shall be governed by the laws of Switzerland, to the exclusion of any rules of conflict resulting from private international law. Any dispute relating to this Notice must exclusively be brought before the courts of Geneve and subject to an appeal to the Swiss Federal Court.
To ask questions or make comments on this Notice or to make a complaint about our compliance with applicable privacy laws, please get in touch with us through: a). our email address: firstname.lastname@example.org; or b). our address: Tritone Capital Management AG., Rue de la Cite 1 | First Floor CH-1204 Geneva, Switzerland. We will acknowledge and investigate any complaint under this Notice.