CLOUDCHAIN

Privacy Policy

[updated: 01 October 2020]

This Privacy Policy (“Policy”) explains what you can expect from us and what we need from you in relation to your personal data. Kindly read this Policy carefully as this is legally binding when you use CLOUDCHAIN Services, without regard to how you access or use, including through mobile devices.



We reserve the right to revise, amend or update this Policy at any time by posting the updated version on this site including its effective date. Further, we shall announce material changes to this Policy by pail.

Definitions

The following terms used in this Policy are defined as follows:

“Digital Asset”

is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “cryptoasset,” or “digital commodity”), which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

“CLOUDCHAIN Account”

means a user-accessible account offered via the CLOUDCHAIN platform to enable access to various blockchain-based financial services.

“CLOUDCHAIN,” “CLOUDCHAIN,”

“We,” and “Us” refers to CLOUDCHAIN and its wholly owned subsidiaries (also referred to collectively as "we," or "us").

“Personal Information”

or

“Personal Data”

refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

Data controller

CLOUDCHAIN provides various blockchain-based financial services. CLOUDCHAIN is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any relevant local privacy laws and regulations.

CLOUDCHAIN uses encryption to protect your information and store decryption keys in separate system. Data controllers process and retain your personal information on our servers where our data centers are located.

Where we have a legal obligation to do so, we have appointed Data Protection Officers (DPOs) to be responsible for privacy program for the respective data controllers. If you have any questions about how we protect or use your Personal Information, you can contact our DPOs by pail at legal@Cloudchain.ai.

Protecting personal information

We are serious about guarding the privacy of your Personal Information and work hard to protect CLOUDCHAIN and you from unauthorized access to, or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption with SSL; the availability of two-factor authentication (2FA) at your discretion, and periodic review of our Personal Information collection, storage, and processing practices.

We restrict access to your Personal Information only to CLOUDCHAIN pployees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our pployees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Information from unauthorized access.

Unfortunately, despite best practices and technical safeguards, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data during transmission, and any acts of transmission are at your own risk.

Information we may collect about you

When using the CLOUDCHAIN Services, we may collect and use the following data about you as part of our Know-Your-Client (KYC) procedure

  1. Full legal name;
  2. Residential address, including country of residence;
  3. pail address;
  4. Mobile phone number;
  5. Date of birth
  6. Proof of identity (

    e.g.,

    driver's license, passport, or government-issued identity card);
  7. Identification number issued by a government;
  8. Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, necessary to comply with our legal obligations under various Anti-Money Laundering (AML) obligations, such as Financial Action Task Force Recommendations as, the European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (BSA).

Information we collect about you automatically

Account Information.

Information that is generated by your CLOUDCHAIN account activity including, but not limited to, instructions regarding funding and disbursment, orders, trades, and account balances;

Log Information.

Information that is generated by your use of CLOUDCHAIN Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

Location Information.

Information that is automatically collected via analytics system providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;

Correspondence.

Information that you provide to us in written or oral correspondence, including opening a CLOUDCHAIN account, and with respect to ongoing customer support; and logging of phone numbers used to contact us.

Information we receive about you from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from thp. For example:

  1. The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
  2. Business partners may provide us with your name and address, as well as financial information;
  3. Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website;
  4. Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided us.

General Provisions

Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.

In providing the personal data of any individual (other than yourself) to us during your use of the CLOUDCHAIN Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data for the purposes set out in this Privacy Policy.

Uses of Personal Data

Below we set forth in a table format, a description of all the ways we use your personal data as stated above, 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 at legal@Cloudchain.ai 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.

What we use your personal information for Type of information Our reasons Our legitimate interests
To provide the CLOUDCHAIN Services:

  • To carry out our contractual obligations relating to you; including the operation of your CLOUDCHAIN account and the provision of our support services.
  • Submitted Information Fulfilling contracts

    Our legitimate interests

    Our legal obligation
    Being efficient about how we fulfill our legal and contractual duties.

    Our commercial interest in providing you with a good service.

    Complying with regulations that apply to us.
  • To comply with legal and/or regulatory requirements; including, but not limited to anti-money laundering requirements.
  • Submitted Information

    Device Information

    Third Party Information
    Our legitimate interests

    Our legal obligation
    Complying with regulations that apply to us.
    To combat against fraud:

  • To verify your identity to protect against fraud, comply with financial crime laws, and to confirm your eligibility to use our products and services; and


  • To help us make better decisions about how we manage your CLOUDCHAIN Account.
  • Submitted Information

    Device Information

    Third Party Information
    Fulfilling contracts

    Our legitimate interests

    Our legal obligation
    As part of CLOUDCHAIN’s efforts to keep our Services safe and secure.
    To help CLOUDCHAIN provide services that interest you:

  • To provide you with information about new functionality, features, or services we offer related to, or similar to, CLOUDCHAIN Services;

  • To provide you with information about new functionality, features or services we feel may interest you;

  • To make suggestions and recommendations to you and other users of CLOUDCHAIN;

  • To process applications for CLOUDCHAIN services, including making decisions about whether to agree to approve any applications.
  • Submitted Information

    Device Information

    Third Party Information
    Our legitimate interests Developing products and services for existing customers and any applicable fees in relation to thp. Defining types of customers for new products or services. Being efficient about how we fulfil our legal and contractual duties. Seeking your consent when we need it to contact you.
    To keep the CLOUDCHAIN Services available and properly functioning;

    To administer internal operations necessary to CLOUDCHAIN Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;

    To notify you about changes to our service, changes to our terms and policies, and as part of our efforts to keep the CLOUDCHAIN Services, safe and secure.
    Submitted Information

    Device Information
    Fulfilling contracts

    Our legitimate interests

    Our legal obligation
    Being efficient about how we fulfill our legal and contractual duties.

    Complying with regulations that apply to us.

    Where we store your personal data

    Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.

    Automated decision making

    We may use Automated Decision Making (ADM) to improve your experience or help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have legal effects on you. In any event, no decision with legal effects on you shall be made solely on the basis of automated processing without your informed and express consent.

    Privacy when using digital assets and blockchains

    Funding your account CLOUDCHAIN account may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer system. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.

    Data Retention

    As CLOUDCHAIN is subject to various legal, compliance and reporting obligations, we are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need-to-know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.

    Right of Rectification

    You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date.

    Right of Erasure

    You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which CLOUDCHAIN is subject to.

    Portability

    You may have the right to transfer certain personal data between data controllers, for example, to move your account details from one online platform to another.

    Location Information

    You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to rpove our applications from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to rpove or disable location services may interfere with your use and functionality of the CLOUDCHAIN Services.

    Access to information

    Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact support@Cloudchain.ai.

    Changes to this Privacy Policy

    Any changes we may make to our Privacy Policy will be posted on CLOUDCHAIN’ Site and applications and, where appropriate, notified to you by pail. Kindly monitor periodically the Site to see any updates or changes to our Privacy Policy.

    Contact

    We welcome any questions, comments and requests regarding this Privacy Policy and should be addressed to legal@Cloudchain.ai.