Privacy Policy

Introduction

This privacy statement applies to the processing of your personal data by or on behalf of Europechain B.V. (also referred to as “we” or “us”), its group companies and affiliates other than processing your personal data in relation to an account with the Europechain public blockchain. The privacy statement regarding the latter processing is found here. 

If we write “data” that shall mean your “personal data”. Where we write “you” that may also include the company you work for if appropriate.

Europechain B.V. works closely together with its group companies and the companies that run the Europechain blockchains (also known as “block producers”). In this statement, those entities together are called “Europechain Partners”.  

We further refer to our commercial partners in this statement. Those are resellers that resell our services and products or provide services regarding one or more of the Europechain blockchains.  

Who controls the processing of your personal data?

Europechain B.V. based in Amsterdam with offices at Henri Dunantstraat 36a, Amersfoort, the Netherlands, registered with the Dutch chamber of commerce under number 74475649 is the controller for the processing of your data. 

Wish to contact us? 

You can contact us: 

• via e-mail at: [email protected];
• via telegram at: https://t.me/EOS_Europechain
• by mail to Europechain B.V. with the address stated above.

Which personal data do we process?

We might process the following personal data:

• Full name, year of birth, and gender;
• Phone number(s), (e)mail address(es), social media accounts (including such as Whatsapp and Telegram)
• Country of residence, nationality 
• Function and company or organization you work for 
• IP addresses
• Other information regarding the use of our websites and services. 
• Profiles made of you.  

How do we collect your data? 

• You provide your data to us. E.g. by filling a form or calling or mailing us. You also might provide third parties working for us with your data. 
• We collect your data if you visit our website. We may do so through the use of cookies, device fingerprinting and comparable techniques.
• We may collect your data stored on a Europechain blockchain, particularly the Europechain public blockchain.
• We may collect your data through the Europechain Partners.
• We may collect your data through third parties that independently have collected your data. Those third parties may be data traders, public registers, social media platforms (including services like Whatsapp and Telegram) and any other third party that collects data in order to share them, whether or not profiled.
• For what purposes do we process your personal data?

We process (including storing) your data:

• To execute an agreement with you;
• To comply with the law;
• To prevent fraud and money laundering; 
• To aid third parties to comply with the law;
• To ensure the law is not infringed;
• To meet compliance criteria set out by our suppliers and/or clients;
• To defend ourselves in the event of a (threatening) law suit or comparable event;
• To communicate with you. By mail, e-mail, telephone or by showing ads or other messages;
• To try and determine which products and services might be of interest to you, whether or not through profiling you; 
• To reach out to you to offer you our services or products;
• For other marketing purposes;
• To analyse your behavior on our website to improve our website and our other services and operations.
• To store your preferences;
• All of the above on behalf of the Europechain Partners and our commercial partners.

To the extent that the processing listed above requires your permission, we will request such permission in advance. You can always revoke such permission. 

We will not use your data to make decisions regarding you that raise legal obligations for you or that we can reasonably expect to be important to you for another reason. 

Lawful basis for processing

The lawful basis for processing is:

• Your consent; or
• Executing an agreement with you; or
• To comply with the law; or
• The legitimate interest of us, the Europechain Partners or third parties providing your privacy interests do not prevail.

Our legitimate interests are:

• Marketing
• Legal compliance by us or by our suppliers or clients and/or third parties.
• Preventing fraud and money laundering;
• Improving our website(s), services and products and operations;
• All of the above regarding the Europechain Partners and our commercial partners.

We have balanced these legitimate interests against your privacy interests. We do believe the balance tilts towards the processing. The data we collect for marketing are mainly business data and not intrusive. They refer mainly to your company and are largely published. The data we collect to prevent fraud or money laundering may be sensible but given the specific and limited use, we should have the right to processing those data. 

Sharing with third parties (other than processors)

We may share your data with the Europechain Partners and with our commercial partners. 

We may further share your data with our (tax) lawyers and accountants as well as with authorities where required.

Data processing in the Netherlands and abroad

Your personal data will only be stored and processed in Europe or, only in conformity with the GDPR, in third countries. 

Processors

In as far as we engage the services of a third party to process your data, we have taken the necessary contractual and organizational measures to ensure that your data will only be processed for the purposes described here.

We have or will engage the following processors:

Hosting providers where we host our company’s data, such as Google or Amazon.

SAAS providers, such as: CRM systems and administrative tools.

Service providers, such as KYC partners, e-mail processing parties and call centers we use to identify and/or communicate with you.

Security and retention

We have taken appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing. 

We will not retain or keep your data longer than allowed by law, required by law and/or necessary for the purposes for which the data are processed. The retention period therefore depends on the nature of the data and the purposes for which the data is processed. Retention periods may therefore vary accordingly. 

More specifically: 

We will delete data regarding an agreement upon expiry of the statutory limitation period of all our rights and obligations out of such agreement, providing we are not required to keep such data because of administrative rules or because we need those data in (possible) legal proceedings.  

We will delete marketing data if they are no longer relevant. 

In some cases, where your data remains relevant to information stored on one of the Europechain’s blockchains, notably the Europechain public blockchain, we may need to store some of your data infinitely. 

Inspection, correction and deletion

You have the right to know which personal data we keep regarding you, to inspect such data, and to request rectification or erasure. You also have the right to request restriction of processing or to object to processing, as well as the right to data portability. 

You can send an email or a letter to these ends with your name and contact information to us by using any of the contact details stated above. We may require you to identify yourself for security reasons.

In your request, please specify as much as possible which personal data you refer to. In general, we will respond within four weeks to a request for inspection or correction. In case of a deletion request we will delete the personal data as soon as possible, unless and to the extent that the law requires us to keep the personal data or if there are other compelling reasons to oppose removal. After the execution of a deletion request we will send you a message of confirmation. If the personal data is (partially) not deleted, we will send you a message in which we explain why your request could not (fully) be met. If we cannot identify which personal data are meant by a request for inspection, correction or deletion, we may ask you to specify your request in more detail. We suspend the execution of the request until you have provided us with such detailed specification. 

In some cases we may provide a hyperlink or other technique to enable you to object easily against specific processing, such as the sending of digital marketing material to you. Regarding our cookies, you may change your browser settings or use other widely available services. 

You always have the right to lodge a complaint with the supervisory privacy authority in your country of residence or in the Netherlands. 

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Amendment and version

We may amend this privacy statement. We recommend that you check regularly for changes.

This privacy statement was last amended June 2019.