Privacy Policy

Token Flow Insights SA, Route des Jeunes 105a, 1212 Grand-Lancy

Version 2.0, September 2022

1. Scope

This privacy policy ("Privacy Policy") explains how Token Flow Insights SA, Route des Jeunes 105A, 1212 Grand-Lancy, Lancy, Switzerland ("TFI") processes and protects your personal data when you use a website operated by TFI (as listed below) and TFI's products and services provided via a TFI website, or any other page or subdomain operated by TFI, as well as any other site, marketplace or application that may be used to access TFI’s products or services (together, "Services").

Websites operated by TFI are the following, including any subdomains or subpages:

Unless otherwise defined in this Privacy Policy or in our Terms of Service at https://tokenflow.live/terms, the definitions used in this Privacy Policy have the same meaning as in the Swiss Federal Act on Data Protection.

The websites operated by TFI may use cookies to collect information to improve their functioning or TFI's Services. For more information regarding TFI's use of cookies, please consult the Cookie Policy of the respective website.

2. Personal Data TFI Collects

TFI collects the following categories of personal data when you use the Services:

Personal details
Contact details
Login details
User information and usage data
Payment details
Recruitment details
Client requests

3. How TFI Collects Personal Data

TFI collects information about you when you use the Services, including taking certain actions within it.

Directly

When you access, use, or otherwise interact with the Services.
When you correspond with TFI by electronic means.
When you sign up to receive TFI's newsletter and other marketing materials.
When you create an account or otherwise submit your data to TFI.

Indirectly

From public sources, such as public directories.
From third parties which make our Services available, such as marketplaces and other Distribution channels.
From third parties, such as social media plugins and analytics, third-party cookies.

4. Legal Basis and Purposes

The legal basis for collecting and using the personal data described in this Privacy Policy depends on the personal data TFI collects and the specific purposes for which the data was collected.

Contract: To perform TFI's contractual obligations or take steps linked to a contract with you. In particular:

To provide the Services and manage your account.
To recruit.

Consent: TFI may rely on your freely given consent at the time you provided your personal data. In particular:

To provide you with news, special offers, newsletters, and general information about goods and services that TFI offers (requires explicit consent).
To promote TFI's services.

Legitimate interests: TFI may rely on legitimate and/or vital interests based on TFI's evaluation that the processing is fair and reasonable. In particular:

To maintain and improve the Services.
To develop new services.

Public interest: To meet regulatory and public interest obligations. In particular:

To comply with applicable regulations and legislation.

5. Data Retention

TFI retains personal data for so long as it is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements.

6. Service Providers

TFI may employ third-party companies and individuals ("Service Providers") to facilitate the operation of the Services, assist TFI in analyzing how the Services are used, or perform related services, such as payment, and delivery of IT infrastructure services. These third parties have access to your personal data only and insofar as necessary to perform these tasks on our behalf.

Type(s) of service providers who might access your personal data:

Accounting, audit and insurance firms
Banks and financial services providers
Marketing, social media, questionnaire and mailing providers
Candidate management and job recruitment firms
Functional services providers, such as e-mail and cloud service providers and cloud databases
Signing and documentation tools
Monitoring, analytics, and tracking tools

7. Data Transfers

For the majority of the activities, TFI and/or the Service Providers referred to in Section 6 process your personal data in Switzerland or in the EU/EEA. However, when necessary, some information may be transferred to the USA and other third countries.

TFI safeguards your personal data per contractual obligations and applicable data protection legislation when transferring data abroad.

Such safeguards may include:

the transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner;
applying standard data protection model clauses, binding corporate rules, or other standard contractual obligations that provide appropriate data protection.

8. Data Disclosure

TFI may disclose your personal data in the good faith belief that such action is necessary:

To comply with a legal obligation (i.e., if required by law or in response to valid requests by public authorities, such as a court or government agency);
To protect the security of the Services and defend our rights or property;
To prevent or investigate possible wrongdoing in connection with TFI;
To defend TFI against legal liability.

9. Data Security

TFI takes reasonable technical and organizational security measures deemed appropriate to protect your stored data against manipulation, loss, or unauthorized third-party access. TFI's security measures are continually adapted to technological developments.

TFI also takes internal data privacy very seriously. TFI's employees and the Service Providers are required to maintain secrecy and comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.

TFI takes all the steps reasonably necessary to ensure that no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your personal data (as described in Section 7 Data Transfers).

The security of your personal data is important to TFI but remember that no method of transmission over the Internet or electronic storage is 100% secure. While TFI strives to use commercially acceptable means to protect your personal data, it cannot guarantee its absolute security. TFI recommends using antivirus software, a firewall, and other similar software to safeguard your system.

10. Your Rights

You have the below data protection rights. TFI will respond to your request without undue delay, at the latest within one calendar month after receipt. Please note that TFI may ask you to verify your identity before responding to such requests.

Right of access: You have a right to request a copy of your personal data, which TFI will provide to you in an electronic form.
Right to amendment: You have the right to ask TFI to correct records if you believe they contain incorrect or incomplete information about you.
Right to withdraw consent: If you have provided your consent to the processing of your personal data, you have the right to withdraw your consent. This includes cases where you wish to opt-out from marketing communications. Once TFI has received notification that you have withdrawn your consent, TFI will no longer process your information for the purpose(s) to which you initially consented unless there is another legal basis for processing. To stop receiving emails from TFI, please click on the 'unsubscribe' link in the email you received or contact TFI at privacy@tokenflow.live.
Right to erasure: You have the right to request that TFI deletes your personal data when it is no longer necessary for the purposes for which it was collected or when it was unlawfully processed.
Right to restriction of processing: You have the right to request the restriction of processing of your personal data where you believe it to be inaccurate, unlawful, or where TFI no longer needs to process it for the initial purpose, but where TFI is not able to delete it due to a legal obligation or because you do not want us to delete it.
Right to portability: You have the right to request that TFI transmits your personal data to another data controller in a standard format such as Excel, where this is data which you have provided to TFI and where TFI is processing it on the legal basis of your consent or to perform contractual obligations.
Right to object to processing: Where the legal basis for processing of your personal data is TFI's legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. TFI will abide by your request unless it has a compelling legal basis for the processing which overrides your interests or if TFI needs to continue to process the personal data for the exercise or defence of a legal claim.
Right to lodge a complaint with a supervisory authority: You have the right to appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch/edoeb/en/home.html).

11. Links to Third-Party Apps and Sites

TFI's Services may contain links to websites or apps not operated by TFI. If you click a third-party link, you will be directed to that third party's site or app. TFI has no control over and assumes no responsibility for the content, security, cookies, privacy policies or practices of any third-party sites or services.

12. Changes to this Privacy Policy

TFI may update the Privacy Policy from time to time. TFI, therefore, encourages you to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

If you're located in the EU or UK, you may submit your request to TFI's appointed GDPR Representative: Prighter.

You may contact the GDPR Representative via the following channels:

Electronically via the compliance landing page on Prighter's website,
In writing to the address shown on the compliance landing page linked above.

14. Contact

If you have any questions about this Privacy Policy, do not hesitate to get in touch with us at:

Token Flow Insights SA
Route des Jeunes 105A
1212 Grand-Lancy, Lancy
Switzerland

privacy@tokenflow.live

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