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 we use cookies and similar technologies
- 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.
11. How we use cookies and similar technologies
When you visit our websites we may send a cookie to your computer. This is a small data file stored by your
computer to help improve functionality or tailor information to provide visitors with more relevant pages. For
details of the cookies employed by us, please see our cookie policy section
below, which forms part of this Privacy notice. We may also analyse website traffic to identify what visitors
find most interesting so we can tailor our websites accordingly.
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
We may change the content of our websites and how we use cookies without notice and consequently our Privacy
notice and Cookie Policy may change from time to time in the future. We therefore encourage you to review them
when you visit the website to stay informed of how we are using personal data.
Last updated March 2019.