Chainlify Limited (incorporated and registered in England with company number 11388203 whose registered office is at The Retreat, 406 Roding Lane South, Woodford Green, Essex, England, IG8 8EY) ("Chainlify") takes data privacy seriously. We recognise and value the trust that individuals place in us when providing us with personal data and we are committed to safeguarding the privacy and security of personal data we may collect from visitors to our websites.
This Privacy notice aims to help you understand our personal data collection, usage and disclosure practices by explaining:
- Who we are and what we do
- What personal data we collect about you
- How we obtain the personal data about you
- How we use your personal data
- Who we share your personal data with
- Which countries we transfer your personal data to
- How long we keep your personal data
- How we protect your personal data
- What rights you have in relation to your personal data
- Who is the data controller for your personal data
- How you can contact us
- How we will update this Privacy notice
By providing your personal data to us (whether via one of our websites, by email, in person or over the phone), you agree to the processing set out in this Privacy notice. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided to you when we collect personal data from you.
Please note: This Privacy notice does not apply to, and Chainlify is not responsible for, any third party websites which may be accessible through links from this website. If you follow a link to any of these third party websites, they will have their own privacy policies and you will need to check these policies before you submit any personal data to such third party websites.
This Privacy notice aims to help you understand our personal data collection, usage and disclosure practices by explaining:
1. Who we are and what we do
Chainlify is a blockchain as a service platform (BaaS) designed to streamline every aspect of blockchain application development. Chainlify is also a community focused around blockchain technologies, where members collaborate, share knowledge, and exchange services.
2. What personal data we collect about you
We may collect and process different types of personal data in the course of operating our business and providing our services. These include:
- basic personal details such as your name;
- contact data such as your telephone number and postal or email address;
- demographic data such as your address, preferences or interests;
- personal data provided to us or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data;
- identification and other background verification data such as a copy of passports or utility bills or evidence of beneficial ownership or the source of funds to comply with client due diligence/"know your client"/anti-money laundering laws and collected as part of our member / customer acceptance and ongoing monitoring procedures;
- recruitment related data such as your curriculum vitae, your education and employment history and other information relevant to potential recruitment by Chainlify;
- website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies; and
- any other personal data relating to you that you may provide.
3. How we obtain the personal data about you
We may collect or receive your personal data in a number of different ways:
- where you provide it to us directly, for example by corresponding with us by email, or via other direct interactions with us such as completing a form on our website or registering for and using one of our services;
- where we monitor use of, or interactions with, our websites, any marketing we may send to you, or other email communications sent from or received by Chainlify;
- third party sources, for example, where we collect information about you to assist with "know your client" checks as part of our member / member acceptance procedures or where we receive information about you from recruitment agencies for recruitment purposes; or
- publicly available sources - we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date.
4. How we use your personal data
We will only use your personal data where we are permitted to do so by applicable law. Under EU data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:
- Contract performance: where your information is necessary to enter into or perform our contract with you.
- Legal obligation: where we need to use your information to comply with our legal obligations.
- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
- Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).
We may use your personal data in the following ways. In each case, we note the grounds that we rely on to use your personal data.
- To provide our services to you and to conduct our business – to administer and perform our services, including to carry out our obligations arising from any agreements entered into between you and us;
Legal grounds: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you), consent.
- To facilitate use of our websites and to ensure content is relevant – to respond to requests for information or enquiries from visitors to our websites and to ensure that content from our websites is presented in the most effective manner for you and for your device;
Legal grounds: legitimate interests (to allow us to provide you with the content and services on the websites), consent, contract performance.
- For marketing and business development purposes – to provide you with updates on the Chainlify and its services, or for example, details of token offerings. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in section 12 below;
Legal grounds: legitimate interests, consent.
- For research and development purposes – analysis in order to better understand your needs and marketing requirements and to better understand our business and develop our services and offerings;
Legal grounds: legitimate interests (to allow us to improve our services).
- For recruitment purposes – to enable us to process applications for employment and to assess your suitability for any position for which you may apply at Chainlify;
Legal grounds: legitimate interests (to ensure that we can make the most appropriate recruitment decisions for Chainlify), contract performance (in order for us to take steps at your request to enter into a contract with you).
- To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations (performing client due diligence/"know your client", anti-money laundering, anti-bribery, sanctions or reputational risk screening); for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them); to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties;
Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities, to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud).
- To inform you of changes – to notify you about changes to our services or our terms and conditions services or this Privacy notice;
Legal grounds: legitimate interests (to ensure we can notify you about changes to our service, terms and conditions etc).
- To reorganise or make changes to our business -In the event that we are undergo a re-organisation (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process or transfer to that re-organised entity or third party your personal data for the same purposes as set out in this Privacy notice or for the purpose of analysing any proposed re-organisation;
Legal grounds: legitimate interests (in order to allow us to change our business).
5. Who we share your personal data with
Chainlify is based in, and operates entirely from, the UK. We may share your personal data with a variety of the following categories of third parties:
- Our professional advisors (e.g. legal, financial, business, risk management or other advisors), bankers and auditors;
- Our insurers and insurance brokers; and
- Third party service providers to whom we outsource certain functions such as technology and IT services;
6. Which countries we transfer your personal data to
In the course of providing our services, we may need to transfer personal data to locations outside the jurisdiction in which you provide it or where you are viewing our website. If you are based in the European Economic Area ("EEA"), this will mean that your personal data may be transferred to, accessible from, and/or stored at, a destination outside the EEA in which data protection laws may not be as comprehensive as in the EEA.
Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy inside the EEA and implement appropriate measures to ensure that your personal data is protected in accordance with applicable data protection laws. Where a third party service provider processes the personal data of EEA residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal data.
7. How long we keep your personal data
We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose. Our retention periods are also based on our business needs and good practice.
8. How we protect your personal data
We recognise that information security is an integral element of data privacy. While no data transmission (including over the Internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorised access, use, disclosure, alteration or destruction in accordance with data protection law requirements.
Everyone at Chainlify and any third party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.
Alongside our role, please also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites or online services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
9. What rights you have in relation to your personal data
If you have any questions about our use of your personal data, you should first contact us via the details provided in section 12 below. Under certain circumstances and in accordance with EU or other applicable data protection laws, you may have the right to require us to:
- provide you with further details on the use we make of your information
- provide you with a copy of information that we hold about you;
- update any inaccuracies in the personal data we hold;
- delete any personal data that we no longer have a lawful ground to use;
- where processing is based on consent, to withdraw your consent so that we stop that particular processing;
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- restrict how we use your information whilst a complaint is being investigated.
You may also ask us not to process your personal data for marketing purposes. We will inform you if we intend to disclose your information to any third party service provider for this purpose. As indicated in section 4 above, you can exercise your right to prevent such processing at any time by using an unsubscribe facility or contacting us via the contact form.
We are also required to take reasonable steps to ensure that your personal data remains accurate. In order to assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us via our contact form or by using any relevant facilities (such as ‘manage your communications’) that we provide.
If you contact us to exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the relevant Supervisory Authority.
10. Who is the data controller of your personal data
Chainlify Limited, with the details set out in section 1 above, is the data controller of your personal data processed by us under this Privacy notice.
12. How you can contact us
If you have any questions about this Privacy notice or how we process your personal data, please contact us via our contact form.
13. How we may update this Privacy notice
This Privacy notice was last updated in March 2019.