PRIVACY POLICY

Introduction
Important information and who we are

CryptoRobotics OÜ (the “Company”, “we”, “us” or “our”) respect your right to privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided below. Please also use the Definitions section to understand the meaning of some of the terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you make a contribution for a ROBO token (the “Token”).

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This version was last updated on November 15, 2021.

Controller

We are the data controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contacting us

Our Contact details

Our full details are:

Attention: Alina Sattarova

CryptoRobotics OÜ

Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145

You have the right to make a complaint at any time to the Finantsinspektsioon of Estonia, the supervisory authority for data protection issues in . We would, however, appreciate the chance to deal with your concerns before you approach the Finantsinspektsioon so please contact us in the first instance.

 Contact Details:

Finantsinspektsioon

Sakala 4

15030 Tallinn, Estonia

Tel: +372 668 0500

Email: [email protected]

Data Protection Inspectorate

The General Data Protection Regulation (GDPR) gives individuals the right to request:

• information on whether and which data are being collected and used about them and for which purposes;
• rectification or deletion of personal data and the right to submit claims;
• restriction of the processing of the personal data or transfer of the data.

If your rights have been violated and the violator does not respond to your request, please turn to the Data Protection Inspectorate. Above all, it is up to everyone to ensure the safety of their data. If you keep information pertaining to you carelessly or disclose it yourself, you can harm yourself – from a deluge of spam email to account or identity theft.

If you seek compensation, apology and repudiation, you need to turn to the county court. Cases of defamation (slander, insult) should also be reported to the county court.

In the case of suspecting a crime – such as identity theft, individual or harassing persecution, unlawful study of humans –, turn to the police.

Estonian Data Protection Inspectorate Contacts

39 Tatari St., 10134 Tallinn

Tel: +372 627 4135

e-mail [email protected]

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes address, email address and telephone numbers.

 Financial Data includes payment card details, wallet address.

Transaction Data includes details about payments to and from you.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data as part of our KYC (“know your customer”) requirements by providing such information and completing the forms for our whitelist process.

This includes personal data you provide when you:

• create an account on our website;
• make a contribution for a Token;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy or further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties.

 Data Protection Principles

We will ensure that the personal information we hold about you is:

• used lawfully, fairly and in a transparent way;
• collected only for specified and legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes we have told you about;
• accurate and kept up to date;
• not kept in a form which permits your identification for longer than necessary and kept only as long as necessary for the purposes we have told you about;
• kept securely; and
• not transferred to another country without appropriate safeguards being in place.

How we use your personal data

We will only use your personal data in accordance with Data Protection Legislation and the Data Protection Principals. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (see Contact Us).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

 CryptoRobotics OÜ

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you on the whitelist	(a) Identity (b) Contact	(a) Performance of a contract with you; (b) compliance with a legal obligation.
To process your contribution	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our T&C’s or privacy policy	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table:

• liasing with regulators (like the Finantsinspektsioon);
• liaising with third party service providers (which may be providing other services to you e.g. wallet providers, KYC providers, exchanges);
• liaising with any individual person and/or entity to which we have outsourced certain functions;
• liaising with our legal advisors in respect of the services being provided to you by us.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do ordinarily not transfer your personal data outside the European Economic Area (the “EEA”).

In circumstances where we do need to transfer any data outside of the EEA we will strive to ensure that the individual or entity receiving the personal data provides an adequate level of protection for that personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In most cases we will aim to keep records of personal data for a minimum of 5 years after the expiry of our contract.

Your legal rights

You have certain rights in relation to your personal data as summarised here:

• Right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with the information in this privacy notice;
• Right to withdraw consent –  where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time;
• Right of access – you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Correcting information – where we hold information about you that is inaccurate or incomplete, you have the right to ask us to rectify or complete it;
• Right to be erased – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
• Right to restrict processing – in certain circumstances you have the right to restrict some processing of your personal information, which means that you can ask us to limit what we do with it. For example, you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• Right to object to processing – you can object to us processing your personal information in certain circumstances, including where we are using it for the purpose of the Company’s legitimate business interests; 
• Right to data portability – you have the right to obtain from us and re-use your personal data for your own purposes.  This only applies, however, where the processing is carried out by automated means, to personal data that you have provided to us yourself (not any other information) and where the processing is based on your consent or for the performance of a contract; 
• Right to complain – you are able to submit a complaint to the Regulator about any matter concerning your personal information, using the details below.  However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.

Subject Access Requests

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may refuse to comply with your request in circumstances where your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests as soon as reasonably practicable and, in any event, within 30 days of receipt of the request.

Definitions

data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.

personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.

data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed.

data users are those of our employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.

data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.

processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

sensitive personal data and/or special categories of personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.