Numeraire Future Trends (NFTrends) Privacy Policy
October 12, 2023.
Introduction
Numeraire Future Trends, an ADGM company (referred to herein as “NFTrends”, “we”, “our”, or “us”), currently operates the website located at www.nftrends.ai (“Website”). As the operator of the Website, we take the protection of your personal data very seriously.
We collect and use your personal data in accordance with this privacy policy and in compliance with Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data (“Personal Data Protection Law“) and ADGM Data Protection Regulations 2021 (“ADGM Regulations“) and, in respect of any EU data subjects, the EU General Data Protection Regulation (together, the “Data Protection Legislation“). This privacy policy (“Privacy Policy“) provides you with information about the collection and use of your personal data when using the Website.
Our Website
This Privacy Policy relates to your use of our website only.
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
Information We Collect
When you access our Website, we and our service providers may obtain or request information about you, your computer or mobile device, and your interaction over time with the Website, as described below.
In addition to accessing our Website, we can collect this information when you register with us, contact us, send us feedback, purchase our services via our Website, post material to our Website, complete customer surveys, report any problem with our services, participate in any social media functions on our Website, or through your browsing activity while on our Website (see ‘Cookies’ below)
1. Personal information that is automatically collected.
When you visit the Website, we and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, our communications, and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state, or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
2. Personal information that you may be asked to provide.
When you visit the Website, you may be asked to provide the following information to us:
- Contact and account information, such as your first and last name, email address, phone number, date of birth, photographic identification, government issued identification and other contact details.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.
- Usage information, such as information about how you use the Website and interact with it, including information associated with any content you upload to the Website or otherwise submit to us, and information you provide when you use any interactive features of the Website.
- Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
3. Personal information that we obtain from third parties.
When you visit the Website, we may obtain information from the following sources:
- Cryptocurrency/NFT wallets. Where the use of a cryptocurrency/NFT wallet is used to access the Website, we may obtain information from the wallet related to your blockchain address and transactions.
- Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.
By using our Website, you consent to the disclosure of such personal data for the purposes set out within this Privacy Policy.
Using your Personal Data
1. We may collect, store, and use your personal data for purposes including the following. The processing is necessary for the performance of a contract, including:
- Administering or managing NFTrends;
- Facilitating the continuation or termination of the contractual relationship between you and NFTrends; and
- Facilitating the transfer of assets, and administering and facilitating any other transaction, between you and NFTrends.
2. The processing is necessary for compliance with applicable legal or regulatory obligations, including:
- Undertaking due diligence including anti-money laundering and counter-terrorist financing checks, including verifying identity and addresses (and, where applicable, in relation to beneficial owners);
- Sanctions screening and complying with applicable sanctions and embargo legislation;
- Complying with requests from regulatory, governmental, tax and law enforcement authorities;
- Surveillance and investigation activities;
- Surveillance and investigation activities;
- Carrying out audit checks, and instructing our auditors;
- Maintaining statutory registers; and
- Preventing and detecting fraud.
3. In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, including:
- Complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;
- Assessing and processing requests you make;
- Investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
- Providing you with, and informing you about, products and services;
- Managing our risk and operations;
- Complying with audit requirements;
- Ensuring internal compliance with our policies and procedures;
- Protecting NFTrends against fraud, breach of confidence or theft of proprietary materials;
- Seeking professional advice, including legal advice;
- Facilitating business asset transactions involving NFTrends or related entities;
- Monitoring communications to/from us (where permitted by law); and
- Protecting the security and integrity of our IT systems.
We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights, or freedoms.
Sharing your Personal Data
Transferring your Personal Data Internationally
Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Data Protection Legislation. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of the Data Protection Legislation.
Storing and Deleting your Personal Data
The information we hold about you will be transferred to secured servers. It may be accessed by our personnel or personnel of one of our suppliers for genuine business reasons such as the performance of contractual obligations or compliance with laws and regulations. By submitting your personal data, you agree to the transfer, storage, and processing of this information. We will take all reasonable measures to ensure your data is guarded securely in line with the terms of this Privacy Policy.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, and reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements.
Automated Decision-Making
We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the Data Protection Legislation.
Our Legal Basis
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- Consent: where you have given us clear consent for us to process your personal information for a specific purpose
- Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
- Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
- Economic or financial interests: where our use of your personal information is necessary for protection of economic or financial interests of the state.
- legitimate interests: for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own
Your Rights
You have certain data protection rights, including the right to:
- Be informed about the purposes for which your personal data are processed;
- Access your personal data;
- Require us to correct any mistakes in your information which we hold;
- Require us to delete your personal data in some limited circumstances.
- Object at any time to processing your personal information for direct marketing;
- Object to the processing of your personal data if it is being used for statistical survey purposes;
- Object or restrict the processing of your personal data in certain circumstances;
- Have your personal information transmitted to another organisation;
- Object to decisions based on automated processing that produce legal effects concerning you and;
- Lodge a complaint with the relevant authorities in accordance with the Data Protection Legislation
Cookies Policy
A cookie is a piece of data that is stored on your browser. Cookies are used to distinguish you and remember you and your preferences when you visit our Website.
We use the following cookies:
Strictly necessary cookies: These are needed for the operation of our Website and Platform. The cookies collect information in respect of the operation of the Website and for example, allow you to log on to secure areas of the Website.
Performance/Analytical: These cookies collect information about how users use our Website including the number of Users. These cookies help us to improve the way our Website works.
Functionality: These cookies record the visit to the Website and how you accessed the website. These cookies may be used to personalise our service to you.
Targeting cookies: These are third party cookies set through the Website by our advertising partners. They are used by those companies to build a profile of your interests and show you relevant adverts on other websites.
Most internet browsers automatically accept cookies. Cookies are stored on your computer and transmitted by you. You can set your browser to refuse all or some browser cookies. By changing the settings in your Internet browser, you are able to deactivate or restrict the transmission of cookies. Cookies that have been saved may be deleted at any time. Please note if you delete or disable cookies, you may not be able to access all parts of our Website.
Changes
We reserve the right to change this policy from time to time by updating this Data Privacy Policy on the website. We recommend that you read the updated Privacy Policy to keep informed of any changes from time to time. Your continued use of our Website is deemed acceptance of any changes.
Data Security
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We do our best to protect the information we have about you but cannot guarantee the security of information transmitted. We do take the guarding of the security of your personal information seriously and the information you provide to us is stored on secure servers.