PRIVACY POLICY

TIEXO

version updated on 10th of December 2021 –

This Privacy Policy (the “Policy”) describes how JAXABLE S.R.L. (a Romanian limited liability company registered under relevant Trade Registry Office under no. J40/18337/31.10.2017, RO38426225, headquartered in Bucharest, Sector 2, 20A Alexandru cel Bun St., Room 3, Bl. T19B, Entrance A, 8th floor, Ap. 50 – “Tiexo”/ the “Controller” / “We”), acting as controller, collects and processes the personal data (“Data”) of users (each „User”/ “You”) of our website www.tiexo.com (the “Website”) and generally of the online services/products Tiexo provides via the Website (collectively, the “Services”). Thus, we hereby inform you on the following:

This Privacy Policy has been drawn up in accordance with the provisions of the Regulation (UE) 679/2016 of the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).

Please be aware that this Policy supplements our Terms of Services with regard to any details/aspects regarding the processing of personal data and by running/accessing the Website and/or any Service, you agree to the terms outlined in this Policy.

This Policy does not apply to any personal data/ information collected by third-party websites or services that you may access through the Services or that you submit to us without our request/control, via any electronic message/text/ e-mail you choose to send to us.

  • ELIGIBILITY

Our Services are not designed for / directed towards children; we do not collect or intentionally request personal data concerning people under 18. If you are under 18, please do not register and/or use our Services and do not send us any personal data about you. Moreover, if we are notified or find I any way that personal data of a person under 18 has been provided to us, we will immediately delete such information as soon as possible.

  • PERSONAL DATA WE COLLECT AND PROCCESS

Personal data means any information relating to an identified or identifiable natural person.

We collect and process various data/information from You/regarding You in the context of the Services. Insofar as this data/information leads to your identification and represents personal data, we hereby inform you on the main aspects related to such personal data collection and processing by Tiexo, as personal data controller.

Categories of data and source of collectionPurpose and legal basis we use for legal processing; recipients
1. Your virtual /crypto asset wallet address (we collect this data directly from you) !!! We do not collect, process or store login credentials or other security related information (secret phrase or private key associated with your account); You must not, at any moment, share your login credentials or other security related information with any other person or allow any other person to access your account/to use your digital wallet. You shall be solely responsible if this happens !!!Purpose : it is necessary for us to process this data in order to provide our Services as per our contractual relationship under the Terms of Service; including award of utility and benefits to NFT holders; Legal basis for lawful processing : – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract). Recipients: the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers).
1. Smart contract address, token ID, token standard, your blockchain network public address, metadata (we collect this data directly from you)Purpose : it is necessary for us to process this data in order to provide our Services as per our contractual relationship under the Terms of Service; including award of utility and benefits to NFT holders; including presenting to the public/users of our Website/to potential buyers/sellers your intentions/offer; Legal basis for lawful processing : – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract); Recipients: the User, as data subject (in respect of its own data, upon data access request); the public/other users of the Website when viewing/engaging with your NFT offers/NFTs; our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers).
1. User’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of the Website to which you browsed and the time you have spent on those pages/ features, the frequency of your using our Services, other statistics/analytics: (we automatically collect this data when You use/engage with our Website/Services)Purpose : it is necessary for us to process this information for our legitimate business needs, mainly to manage our Services, to report and fix errors, to improve our Services (offering new features, functions and increased functionality), to evaluate system security and stability; including in order to prevent fraud and/or system/platform protection (e.g. identify, investigate, deter against fraudulent, unauthorized, or any illegal/non-compliant activity); Legal basis for lawful processing : – processing of this data is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, which have been assessed as not being overridden, in the context of this processing, by the User’s interests or fundamental rights and freedoms. Other purpose : tracking advertising tailored to your interests, on the Services and other websites; legal basis for processing : your express consent for cookies to be placed on your device Recipients: the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers).
1. (Account) registration data (username, email address) : we may collect this information from you when you voluntarily provide such information when you register for access to the Services or use our Services;Purpose : it is necessary for us to process this information in order to provide the Services as per our Terms of Service (our contractual terms); Legal basis for lawful processing – processing of this data is necessary for the performance of the Terms of Services, i.e. the contract to which the User (as data subject) is party or in order to take steps at the request of the data subject prior to entering into this contract. Other purpose : we may also use this information also for: customer service; correspondence/other communications with you, technical/support or administrative messages (e.g. to let you know about new features/events, transactional correspondence), general customer support, analysing and improving our business/portfolio (e.g. collecting information about how you use our Services to optimize the design and placement of certain features), providing a safe and enjoyable user experience; Legal basis for lawful processing – processing of this data is necessary for the purposes of the legitimate interests pursued by the Controller or of a third party, which have been assessed as not being overridden, in the context of this processing, by the User’s interests or fundamental rights and freedoms. Other purpose : we may also use your email address for delivering to you (direct) marketing communication for our Services/activity on the Website; Legal basis for lawful processing – your clear, freely given consent, expressed upon subscribing to our communication/newsletter channels; you may withdraw this consent at any time thereafter, free of charge and in an easy manner, including by accessing the Unsubscribe link we will include in every direct marketing message we send to you.
1. Messages, images, or other content you send to us ( e.g. during correspondence/communication): we collect this information from you when you voluntarily provide such information when use our ServicesPurpose : we may use this information during our performance of the contracted Services, as well as for customer service, technical support, Services and business improvement and development; Legal basis for lawful processing – processing of this data is necessary for the purposes of the legitimate interests pursued by the Controller or of a third party, which have been assessed as not being overridden, in the context of this processing, by the User’s interests or fundamental rights and freedoms. Recipients : the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers); our group companies.
1. Your actions when offering to purchase an NFT, or to sell an NFT, including any NFT minting/purchase (including auctioning) processPurpose : it is necessary for us to process this information in order to provide the Services as per our Terms of Service (our contractual terms); including award of utility and benefits to NFT holders; including presenting to the public of our Website/to potential buyers/sellers your intentions/offer; Legal basis for lawful processing – processing of this data is necessary for the performance of the Terms of Services, i.e. the contract to which the User (as data subject) is party or in order to take steps at the request of the data subject prior to entering into this contract; Recipients : the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers); our group companies.
1. Any of the data mentioned at points a. – f. above when we are required to comply with the legal requirementsPurpose: We may use your personal information/ data which may be necessary to comply with the applicable laws, lawful requests and investigations (e.g. answers/providing information to/during official requests/investigations from government authorities), including to defend/pursue our rights, including in court; Legal basis for lawful processing – processing of this data is necessary for the purposes of the legitimate interests pursued by the Controller or of a third party, which have been assessed as not being overridden, in the context of this processing, by the User’s interests or fundamental rights and freedoms; also, when processing is necessary for compliance with a legal obligation to which the Controller is subject. Recipients : the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers); our group companies.
1. Any of the data mentioned at points a. – f. needed for the implementation and consummation of any group/ corporate/M&A reorganisation/transaction of TiexoPurpose : If (corporate) transformations/changes on Tiexo/Tiexo business (e.g. due-diligence, sale of shares, etc.) occur (e.g. Tiexo shareholders/owners carry out an assessment for and/or a sale or transfer of all or a part of Tiexo business/ shares and/or assets (including any merger, spin-off, financing, acquisition, or bankruptcy transaction or proceeding). Legal basis : We may process your (personal) above, only in so far as it is necessary for such purpose, in the legitimate interests pursued by the Controller or of a third party, which have been assessed as not being overridden, in the context of this processing, by the User’s interests or fundamental rights and freedoms; Recipients : the User, as data subject (in respect of its own data, upon data access request); our service providers, usually acting as data processors involved in data processing on our behalf (e.g. customer support, hosting, email delivery and database management services); relevant authorities/courts, upon exercise of their legal powers; our advisors, for protecting our interests/representing us (our insurers, bankers, auditor, lawyers); our group companies; potential buyer/offeror/beneficiary (including its advisors).

For conducting transactions with tokens/digital assets, we use Moonlet wallet extension (https://moonlet.io/), as well as third-party electronic wallet extensions such as (but not limited to), Phantom wallet (https://phantom.app/) or Solflare wallet (https://solflare.com/); your interactions with any third-party electronic wallet extensions are governed by the respective, applicable, privacy policy(ies). Please read carefully their policies, for information on your personal data processing.

We may embed our Instagram / Discord / Telegram / Twitter / YouTube feed on our Website, looking to entice our Users to check out our profiles/news on such pages/account, to increase awareness of our Services/news. When you engage with such feeds by clicking these third-party icons on our Website, you are directed to the respective feed on our account on the respective platform. When you engage with the said pages/products of third-parties:

  • we will collect the information regarding your registered account on such platforms (including certain information/data provided by your interactions with these platforms features – your “likes”; “sharing”), for the purpose of improving our Services.
  • the third-parties controlling these external pages/websites may collect information as described in their privacy policies and/or any applicable cookies policy); this may include information about how people using their products/services, such as the types of content that they view or engage with, or the actions they take, as well as information about the devices they use (e.g. IP addresses, operating system, browser type, language settings, cookie data). The information actually collected and processed by third-parties depends on whether and how people use the services/products of these third-parties. The processing of personal data for some of these products might be subject to a joint controllership relationship we share with the respective third-party (the other controller, if the case). Please be aware that such third parties may also process the data for their own advertising purposes, as well as for the advertising purposes of third parties, in accordance with their own responsibility and privacy policies; please refer to Instagram / Discord / Telegram / Twitter / YouTube privacy policies, where you will also find additional information on how you can exercise your rights as a data subject, directly towards such controllers, with respect to your data processed thereby.

Please note that we are not responsible for the contents of any third-party platform/website/service we may offer a link/connection on our Website; such link does not mean that we have reviewed or endorsed its contents/practices, including privacy practices. While visiting such third-party website or service, you are subject to its privacy practices and policies, not ours. This privacy policy(ies) does/do not apply to any personal information that you provide to these other websites and services.

Based on your prior freely given consent (as lawful basis), we may process your personal data to serve you marketing materials through push-up notifications and/or to advertise of several services provided by our affiliated partners.

Also, we use Google Analytics on our Website, for analytics and measurement, mainly to understand how our services are used and to offer you a customized user experience. This relies on first-party cookies set by us upon your prior consent. In this manner, data generated through Google Analytics can be linked by us (as Google Analytics customer) and by Google, to third-party cookies that are related to visits to other websites. The information thus collected by Google when we use Google Analytics, why Google collects it, and how it is used to improve experience, is detailed in Google policies available on their website.

  1. COOKIES

We use cookies and similar technologies on our Website. Cookies are small text files placed on your computer or mobile device when you access websites. “First party” cookies are set by domains that you are visiting at the time. “Third party” cookies are set by domains other than those of the websites that you visit. Web beacons are transparent pixel images that are used in collecting information about website usage, e-mail response and tracking. Like cookies, the local storage technology allows websites to store information on a computer or mobile device. Local storage is typically persistent and, unlike cookies, data in local storage is not automatically transferred over the internet every time when the website is visited that stored the data. We refer to cookies, web beacons and local storage together as “cookies and similar technologies”. Most cookies fall into one or more of the following categories:

  • Strictly necessary: These types of cookies are essential to provide services specifically requested by website visitors. Without them, websites cannot function or deliver the requested services;

  • Performance: These cookies collect information about how visitors are using a website, such as which pages are most popular, which method of linking between pages is most effective, and if users encounter error messages from web pages. These cookies allow us to provide a high-quality user-experience, as well as measure audience of the website pages. The information collected by these cookies does not directly identify users. They are designed to help improve how websites work;

  • Functionality: These cookies remember choices that you make so as to improve your experience;

  • Personalised ads and content, ad and content measurement, audience insights and product development – upon your prior consent.

  • TYPES OF COOKIES AND LOCAL STORAGE POLICY

We use local storage to assign you a unique user ID for purposes of communication with you. Local storage are deleted when the WebSite that stored them deletes them. You can also delete local storage from your browser at any time you like by visiting your web browser settings.

We use the following cookies:

Google Analytics

  • Purpose: Performance
  • Retention period: From session up to two years
  • Description: We use Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies that allows us to analyze the use of our website and to compile reports on website activity and internet usage.
  • Used names:_ga, _gid, _gat, _gaexp, _utm, __utmc, UTMD_, __utmv, __utmz, _gat_gtag_UA_ID, gadwp_wg_default_view, gadwp_wg_default_swmetric, gadwp_wg_default_metric, gadwp_wg_default_dimension, gadwp_ir_default_dimension, gadwp_ir_default_swmetric, gadwp_ir_default_metric
  • Sharing: Privacy statement

GDPR Plugin

  • Purpose: The GDPR plugin is a plugin that places cookies to help DPOs in making a website compliant.
  • Retention period: 365 days
  • Description: The GDPR plugin is a plugin that places cookies to help DPOs in making a website compliant.
  • Used names: gdpr, gdpr[consent_types], gdpr[allowed_cookies], gdpr[privacy_bar], cookie_notice_accepted, cookies_accepted, gdpr[privacy_bar, gdpr[allowed_cookies, gdpr[consent_types
  • Sharing: Privacy statement

WordPress

  • Purpose: WordPress log in cookie
  • Retention period: 30 days
  • Description: Cookie to keep you logged in
  • Used names: _wordpress_
  • Sharing: Privacy statement

Algolia

  • Purpose: This cookie is used to be able to use the Algolia search function on our website.
  • Retention period: 365 days
  • Description: This cookie is used to be able to use the Algolia search function on our website.
  • Used names: algoliasearch-client-js
  • Sharing: Privacy statement

WP_API Schema

  • Purpose: This cookie makes it possible to provide Schema JSON-LD / SEO markup for articles, events, local business, products, recipes, reviews and many more.
  • Retention period: 365 days
  • Description: This cookie makes it possible to provide Schema JSON-LD / SEO markup for articles, events, local business, products, recipes, reviews and many more.
  • Used names: wp-api-schema-model, wp-api-schemamodel_xxxxxx
  • Sharing: Privacy statement

Twitter

  • Purpose: Target users with personalised ads
  • Retention period: 1 year
  • Description: Twitter tracks users to target them with personalised ads
  • Used names: metrics_token
  • Sharing: Privacy statement

Linkedin

  • Purpose: Tracking purposes
  • Retention period: 6 months
  • Description: LinkedIn tracks users to target them with personalised ads
  • Used names: X-LI-IDC
  • Sharing: Privacy statement

Google Fonts

  • Purpose: Display of fonts on our website
  • Retention period: 365 days
  • Description: We use the Google Fonts API to display fonts on our website. The Google fonts API requests your IP address when visiting our website.
  • Used names: tcb_google_fonts
  • Sharing: Privacy statement

Google Recaptcha

  • Purpose: reCaptcha will check if the website visitor is human, not a bot
  • Retention period: 2 Weeks
  • Description: Actively monitors user actions across the entire property and returns a score which represents the probability if it is a human or a bot.
  • Used names: API Call
  • Sharing: Privacy statement

You can adjust the privacy settings in your browser to block all cookies; however, this could severely affect your browsing experience as many websites may not function properly. Your browser may allow you to delete all cookies upon closing your browser. This option, though, results in persistent cookies getting deleted that may store your preferences and personalized settings on websites that you visit regularly. It is possible to keep desired cookies, though, as your browser may allow you to specify which websites are always or never allowed to use cookies. More details on how to delete cookies or how to manage cookies in different internet browsers can be found by accessing the links below:

  • Cookie settings in Internet Explorer;
  • Cookie settings in Firefox;
  • Cookie settings in Chrome;
  • Cookie settings in Safari web and iOS.

To opt out of being tracked by Google Analytics please visit http://tools.google.com/dlpage/gaoptout. Comprehensive information on how organizations use cookies is available at: www.allaboutcookies.org.

  1. DISCLOSURE OF YOUR PERSONAL DATA

We do not rent, trade, or sell your personal data and we do not share your personal data with recipients (third parties / organizations) without your express and specific consent, except as described in this Policy and for the purpose indicated therein. In any case, we shall disclose personal data, insofar it is strictly necessary for the accomplishment of the corresponding purpose. We may disclose your data only to our data processors mentioned in this Privacy Policy.

  • CROSS-BORDER DATA TRANSFER

We do not transfer, process and/or store personal data in countries outside EEA (the European Economic Space).

Should your personal data processing, subject to the GDPR, take place outside EEA, we shall ensure, we will take appropriate available measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy and the applicable law, primarily GDPR. These measures may include:

  • entering into European Commission approved standard contractual arrangements; and/or
  • using any other adequate transfer tool/ data transfer mechanisms in accordance with GDPR including, where the case, additional safeguards.

Regarding transfers of information to our sub-processors, details are available in their privacy policies: nevertheless, please refer to us any question you may have in this respect and we will try to give our support.

  • HOW LONG WE KEEP YOUR PERSONAL DATA

We will hold your personal data on our systems for as long as required to make you available Services. We reserve the right to retain your data for a longer period in case of a complaint or if we reasonably believe there is a likelihood of litigation in respect to our relationship with you.

There may be some circumstances when you can ask us to delete your data, so please consider the fact that we also may retain some non-personally identifiable information (anonymised data) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

  • HOW YOUR DATA IS SECURED

We take the protection of Users’ information/ data very seriously. We employ industry standard security measures to reduce the risks of unauthorized access to Tiexo Services and to deal with any data breaches. We will notify you of any personal data breach where we are legally required to do so.

We are committed to protecting personal information from loss, misuse, disclosure, alteration, unavailability, unauthorized access and destruction and takes all reasonable precautions to safeguard the confidentiality of personal data, including through use of appropriate organizational and technical measures. Organizational measures include physical access controls to our premises, staff training and locking physical files in filing cabinets. Technical measures include use of encryption, passwords for access to our systems and use of anti-virus software.

In the course of provision of your personal data to us, personal data shall be mainly transferred to us over the internet. Although we make every available effort to protect the personal information which you provide to us, the transmission of your personal data over the internet is not completely secure. As such, we cannot guarantee the security of personal data sent to us over the internet and thus any such transmission is at your own risk.

Users of our Services are responsible for maintaining the security of any password, user ID or other type of authentication. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security has occurred.

You acknowledge that the procedures/mechanisms employed by us do not provide absolute security and you cannot expect that the Service will be immune from any risks associated with the common risks from the use of blockchain networks. Any information that you choose to provide to us is made at your own risk.

  • YOUR CHOICES REGARDING YOUR PERSONAL DATA

As data subject, you can exercise the following rights regulated by the GDPR:

  • Right of access;

  • We will provide you with a copy of any data we hold about you;

  • Right of rectification;

  • We will modify your data if any of them are incorrect or inaccurate;

  • Right of erasure;

  • We will delete your personal information/data.

If erasure is not technically possible or we consider that we have a reasonable legal ground to retain your data that you ask us to erase we will inform you accordingly.

  • Right to data portability;

  • We may transfer your data to another service provider; this applies only while processing the User’s data on their consent, and only by automatic means.

  • Right to object.

  • You may object to processing of your data, at any time, due to your particular situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds and an overriding interest for the processing or (ii) if the purpose is the establishment, exercise or defence of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it. 

You may always object to the processing of your personal data for direct marketing that was based on our legitimate interest, regardless of any reason. If the marketing was based on your consent, you can withdraw consent.

  • Time period: We will try to fulfil your request within one month. Nevertheless, this period may be extended with up to two months due to reasons relating to the specific legal right or the complexity of your request. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.
  • Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to statutory restrictions. If we deny or limit your access, we will advise you of the reason for such measure.
  • You can exercise any of your rights at any time by reaching out to us using the information from the Contact section set out here. When you write to us making a request to exercise your above rights, we are entitled to identify you first, and ask you to provide identification details to help us to verify your identity. It will help us in the process of giving you a fast and accurate answer to your request if you clearly point out which right you wish to exercise and the reason for exercising it. We reserve the right to delay auctioning on your request if you do not provide us with enough information/details. Only when you have provided us with the exact/complete information, we can proceed to process your request.
  • The Romanian supervision authority, whom you may contact part of your legal rights has its contact data available at www.dataprotection.ro.

Please direct your questions regarding the way we collect, use or store data subject’s personal data and any requests in the exercise of your legal rights related thereto to the following contact details: [email protected]

We will investigate and use all reasonable efforts to resolve any request or complaint of a data subject. If you are not satisfied with our reply, you may also make a complaint to the relevant data protection supervisory authority, as per the law – we indicate here the National Supervisory Authority for Processing of Personal Data or ANSPDCP – the supervisory authority in Romania, the country where we are based (email : [email protected], head office 28-30 G-ral. Gheorghe Magheru Blvd., Sector 1, postal code 010336, Bucharest, Romania).

  • OTHER PROVISIONS

Contact details:

If you have any inquiries, questions or concerns about this Policy, you may reach us at [email protected].

Please be informed that this Policy is regularly updated by Tiexo in accordance with legislative changes and requirements and updated versions will be brought to the attention of data subjects.

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