Privacy Policy
Date Last Revised: 11th June 2024
1. ABOUT THIS POLICY
1.1 This is the Privacy Policy for Persistence Sub One Ltd. (collectively referred to herein as “PRS1”, “us”, “we” or “our”).
1.2 This Privacy Policy describes how we may collect, use, disclose and process your personal data when you:
1.3 We will only use your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Privacy Policy.
1.4 By providing us with personal data, you acknowledge that our collection, use, disclosure and processing of personal data will be in accordance with this Policy, including, for the avoidance of doubt, the cross-jurisdictional transfer of your data. DO NOT provide any personal data to us if you do not accept this Privacy Policy.
1.5 This Privacy Policy supplements but does not supersede or replace any consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.
1.6 Our Applications may contain links to other websites that are not owned or maintained by us. These links are provided only for your convenience. You may also be accessing our Applications through third party websites and/or platforms. This Privacy Policy only applies to our Applications. When visiting these third party websites, their privacy policies apply.
1.7 If you have any feedback or issues in relation to your personal data, or about this Privacy Policy, or wish to make a complaint to us, you may contact our Data Protection Officer at : Email : [email protected] This does not affected your statutory rights. For example, if the GDPR applies to you, you may also have a right to lodge a complaint with a European supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of Data Protection law has taken place. When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.
2. AMENDMENTS TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. The updated policy will supersede earlier versions and will apply to personal data provided to us. The updated Privacy Policy will take effect when made available on https://persistence.one/privacy (“Privacy Policy”).
3. WHAT PERSONAL DATA WE COLLECT
3.1 What is personal data. “Personal data” is data that can be used to identify a natural person. Examples of personal data include wallet addresses, and user-specific information for analytical purposes, email addresses and any other information of a personal nature.
3.2 Voluntary provision of personal data. We may collect personal data (1) that you voluntarily provide to us; or (2) from third parties; or (3) through your use of our (or our services provider’s) digital technologies and services (Please see Section 4 How We Collect Personal Data for further details). What personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide. When our collection is based on consent, you can choose not to provide us with personal data. You also have the right to withdraw your consent for us to continue collecting, using, disclosing and processing your personal data, by contacting us in accordance with paragraph 1.7. However, if you do so, it may not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you require.
3.3 Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself (such as your team members, family members and next-of-kin). If you do so, you represent and warrant that you have brought this Privacy Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such inBoxiduals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.
3.4 Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.
3.5 Minors. Our Applications and/or services are not intended to be accessed or used by children, minors or persons who are not of legal age. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us.
3.6 Excluded Persons and Excluded Jurisdictions. Our Applications and/or services are also not intended for Excluded Persons, and/or access and/or use in Excluded Jurisdictions. Please refer to the relevant terms (including the Foundation Delegation Program Terms and Conditions) for the specific excluded persons and jurisdictions.
4. HOW WE COLLECT PERSONAL DATA
4.1 Personal data you provide. We collect personal data that is relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, such as when:
4.2 Personal data provided by others. Depending on your relationship with us, we may also collect your personal data from third party sources, for example, from:
5. WHAT WE DO WITH YOUR PERSONAL DATA
5.1 What we do. We collect, use, disclose and process your personal data where:
5.2 General purposes. We collect, use, disclose and process your personal data for purposes connected or relevant to our business, to manage your relationship with us. Such purposes would include:
Where personal data is used for a new purpose and where required under applicable law, we shall obtain your consent.
5.3 Legitimate business interests. We may also collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that this does not override your interests or rights, which include:
5.4 Marketing purposes. In order for us to market products, updates, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us However, no marketing, using your personal data in non-aggregated and/or identifiable form would be carried out unless you have provided us with your consent to use your personal data for such marketing purposes. If you do not want us to use your personal data for the purposes of marketing you can withdraw your consent at any time by contacting us in accordance with paragraph 1.7.
5.5 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
5.6 Contacting you. When we contact or send you information for the above purposes and purposes for which you have consented, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with paragraph 1.7 above.
6. USE OF AUTOMATED DATA COLLECTION TECHNOLOGIES
6.1 Cookies. In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. There are three main types of cookies:
6.2 How we use cookies. We use cookies for the following purposes:
We may also automatically collect and store certain information about your interaction with our Applications including IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data.
6.3 Other technologies. In addition to cookies, we may use some other similar technologies as follows (as and where applicable):
6.4 Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Please note you may not be able to take advantage of all the features of our Applications, including certain personalised features, if you delete or refuse cookies.
6.5 Mobile Opt-out. Where applicable if we do support a mobile version of our product - If you access our Applications through mobile devices, you can enable a "do not track" feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Add Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalised to your interests.
6.6 If you are a resident in the EU. For more information on managing cookies, please visit www.youronlinechoices.eu and www.allaboutcookies.org. The above links have further information about behavioural advertising and online privacy.
6.7 Changes to our uses of Cookies. If we change anything important about this Paragraph 6 on cookies, we will notify you through a pop-up on the website for a reasonable length of time prior to and following the change. You may review this Paragraph by visiting the sites and clicking on the “Privacy Policy” link.
7. DISCLOSURE OF PERSONAL DATA
7.1 Disclosure to related parties. We may disclose or share your personal data with our related parties in order to provide our services to you, manage our shareholder and investor returns, for management and compliance purposes, and to utilise shared group IT functions.
7.2 Disclosure to third parties. We may also disclose your personal data to third parties in connection with purposes described in paragraph 5, including without limitation the following circumstances:
When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
8. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
Transfers. We may transfer your personal data to different jurisdictions in connection with the purposes described in paragraph 5:
Safeguards. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this policy and applicable laws regardless of the jurisdictions they are transferred to, but in any event to a level that is no less stringent than the jurisdiction from which the personal data is transferred. When we transfer your personal data internationally and where required by applicable law we put in place appropriate safeguards including EU Model Clauses or rely on EU Commission adequacy decisions. You may obtain details of these safeguards by contacting us.
9. SECURITY AND RETENTION OF PERSONAL DATA
9.1 Unauthorised access. While we take reasonable precautions to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes.
9.2 Vulnerabilities. We do not make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.
9.3 Period of retention. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer, e.g. where we are required to do so by law.
9.4 Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
10. YOUR RIGHTS
10.1 Rights you may enjoy. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights may include:
If you wish to exercise any of your rights, you may contact us in accordance with paragraph 1.7. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.
10.2 Limitations. We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.