PRIVACY POLICY

STARFLEET ORIGINTRAIL KNOWLEDGE ECONOMY

TRACE LABS AS A COMPANY RESPECTS YOUR PRIVACY AND IS COMMITTED TO PROTECTING YOUR PERSONAL DATA. THIS PRIVACY POLICY WILL INFORM YOU AS TO HOW TRACE LABS LOOKS AFTER YOUR PERSONAL DATA WHEN YOU UTILISE OUR SERVICES, VISIT OUR WEBSITE (REGARDLESS OF WHERE YOU VISIT IT FROM) AND INTERACT WITH IT, AND TELL YOU ABOUT YOUR PRIVACY RIGHTS AND HOW THE LAW PROTECTS YOU.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE AND LET US KNOW IF YOU HAVE ANY QUESTIONS OR OTHER FEEDBACK REGARDING IT.

PLEASE NOTE THAT BY ACCESSING, BROWSING, VIEWING, OR IN ANY WAY USING THE WEBSITE AND THE SERVICES OFFERED THEREIN, YOU CONSENT AND AGREE TO BE BOUND BY THE TERMS AND CONDITIONS FOR THE USE OF THE WEBSITE AND OUR SERVICES OFFERED THEREIN, WHICH ARE AN INTEGRAL PART OF THIS PRIVACY POLICY.

Important information and who we are:

Trace Labs Ltd, a company registered and incorporated under the laws of Hong Kong, company registration number: 2714388 (hereinafter »Trace Labs«, »We«, »Us«, »Our«).

1. Definition

1.1 The terms in this Privacy Policy have the following meaning:

“Personal Data (or Data)”

Information provided by You that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.

“Usage Data”:

Information collected automatically through this Website regarding Your behaviour on the Website.

“You”:

The individual using and/or visiting this Website who, unless otherwise specified, coincides with being the subject to whom the Personal Data applies.

“Processor”

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of Trace Labs.

“Controller”:

Trace Labs Ltd, a company registered and incorporated under the laws of Hong Kong, located at Wyndham Street 46-48, Hong Kong, company registration number: 2714388.

“Website”

The website, governed by Us and located at https://staking.origintrail.io or any other URL, which may replace it.

“Services”

The service provided or enabled by Trace Labs via Website as described in the related Terms.

“Cookie”

Cookies are tracking files consisting of small sets of data stored in Your browser. For cookie policy please click here.

“Bounty Award”

A bounty pool of 5 million TRAC tokens has been designated exclusively for those staking for Starfleet and is to be made available once ODN v5 is launched on the mainnet. These tokens will be distributed on the xDAI blockchain as xTRAC.

“Starfleet”

An OriginTrail-community run blockchain network. [TRACE LABS TO DEFINE]

“Bounty Receipt”

A document confirming the bounty token transaction, used for purposes of accounting.

2. Owner and Controller

2.1 Trace Labs is the owner of the Website and the Controller of your Personal Data, that is being processed when utilising the Website and/or the Services offered therein.

3. Types of data collected

3.1 When You submit a form for Bounty Receipt we collect the following Personal Data:

Identity Data, namely:
1. first name,
2. last name,
3. permanent address,
4. country of residency,
5. information regarding age (only information whether you are of legal age in your country of residency),
6. ID/passport/driver’s licence number,

Contact Data, namely:
1. e-mail address.

3.2 When You interact with Our Website, We will automatically collect Usage Data by using cookies and other similar technologies, which may include, but are not limited to the IP addresses or domain names of the computers utilized by You who use this Website, the URI addresses, the time of the request etc.

3.3 If you fail or decline to provide the requested Personal Data, We may not be able to enable Your use of the Website and/or (certain) Services offered therein.

4. Legal basis of processing

4.1 We will process Personal Data relating to You only if and to the extent that at least one of the following legal grounds applies:

You have given Your consent for one or more specific purposes (opt-in),
provision of Personal Data is necessary for the performance of an agreement with the You and/or for any pre-contractual obligations thereof,
processing is necessary for compliance with a legal obligation to which We are subject,
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Us,
processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party.

5. Transfer of Personal Data

5.1 The Data is processed at the Our operating offices, located in Hong Kong, and in any other places where our affiliated companies or external partners, involved in the processing, are located.

5.2 We may transfer your Personal Data to third countries under the standard contractual clauses or adequacy decisions about certain countries, approved by European Commission as applicable. Hereby we confirm that all the necessary safeguards prescribed by applicable legislation on protection of personal data are in place prior to such transfers.

6. The purpose of processing

6.1 We process Personal Data you provide to us when submitting Bounty Receipt form for the purpose of:

registering Your account in order to claim the Bounty Award,
verifying the accuracy of your Personal Data,
enabling the transaction for claiming the Bounty Award to your wallet,
compliance with Our legal requirements (including, but not limited to good accounting practices),
to fulfil our legitimate interests, such as to administer and protect Our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

6.2 The Personal Data is collected to allow Us to provide the Services and to comply with Our legal obligations, respond to enforcement requests, protect Our rights and interests (or those of Our users or third parties), detect any malicious or fraudulent activity, registration, authentication etc.

6.3 We will only process Your Personal Data for the purposes for which We collected it.

6.4 If We need to process Your Personal Data for an unrelated purpose, We will seek Your prior approval, unless otherwise required by applicable law.

7. Retention time

7.1 We retain Your Personal Data for as long as required to fulfil the purposes for which the Personal Data have been collected for, but no longer than for the period of 7 years, unless otherwise required by applicable law.

7.2 After the course of the retention period the personal data will be deleted or anonymised to a form that it no longer constitutes personal data. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

8. Your rights

8.1 You may exercise certain rights regarding your Personal Data, in particular:

Withdraw the consent at any time. You have the right to withdraw Your consent to the processing of Your Personal Data, without affecting the lawfulness of processing based on consent before its withdrawal.
Object to processing of Your Data. You have the right to object to the processing of Your Data if the processing is carried out on a legal basis other than consent.
Access Your Data. You have the right to learn if Personal Data is being processed by Us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Personal Data undergoing processing.
Verify and seek rectification. You have the right to verify the accuracy of Your Data and ask for it to be updated or corrected.
Restrict the processing of Your Data. You have the right, under certain circumstances, to restrict the processing of your Personal Data. However, please be informed that in such case, the fulfilment of certain purposes of the processing of Personal Data cannot be achieved.
Have Your Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of Your Personal Data from Us. However, please be informed that your Personal Data may be anonymised instead of deleted, to such form that it can no longer identify you and thus does not constitute personal data.
Receive Your Personal Data and have it transferred to another controller. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. You have the right to bring a claim before their competent data protection authority.

8.2 Details about the right to object to processing. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Us or for the purposes of the legitimate interests pursued by Us, You may object to such processing by providing a ground related to their particular situation to justify the objection. You must know that, however, should Your Personal Data be processed for direct marketing purposes, You can object to that processing at any time without providing any justification.