In this Policy, "we", "us" and "our" refers The Badger Technology Company Limited (“Company” or “Invexcoin International”, indistinctly) is a company incorporated and registered in Gibraltar under the registration number 117775, having its registered address at 1.02 World Trade Center 6 Bayside Road, Gibraltar, GX111AA.
In this Policy, “Personal Data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
For the avoidance of doubt, Personal Data does not include data from which you cannot be identified (which is referred to simply as data, non-personal data, anonymous data, or de-identified data).
In this Policy, “processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. Your Information and the Blockchain
3. How we collect information from you
4. The type of information we collect
5. How we use your personal information
6. How we share your Information
7. Automated decision-making
8. How long do we keep your information?
9. Security Measures
10. Your Data Rights
11. Contact and Further information
Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
Accordingly, by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (this being your ‘right to be forgotten’), the right to rectification of your data or your rights to object or restrict processing, of your personal data. Data on the blockchain cannot generally be erased or changed, although some smart contracts may be able to revoke certain access rights, and some content may be made invisible to others; however, it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you it may be necessary to write certain personal data, such as your cryptographic wallet address, onto one or more blockchains; this is sometimes done but not limited to smart contracts and may or may not require you to execute such transactions using your cryptographic wallet’s private keys.
In most cases, ultimate decisions to (i) transact on the blockchain using your cryptocurrency wallet address, as well as (ii) share the public key relating to your Ethereum/Bitcoin or any other cryptocurrency wallet address with anyone (including us) rests on you.
IF YOU WANT TO ENSURE YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US.
IN PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN MAY BECOME PUBLICLY AVAILABLE.
Your information may also be written on other blockchains of the cryptocurrency which you use to purchase your tokens (e.g. such as the Bitcoin blockchain where you chose to pay in Bitcoin).
We collect information about you when you:
The personal information we collect will include your: Name; address; email address; telephone number; date of birth; nationality; identification cards or passport; tax identification number and/or any other identification number issued by a government; employment or business activity details; financial details including salary, income and employer details; source of income; geolocation; device information; cryptographic wallet address; biometric details; electronic signature; any public key that you share with us; communications; 2FA reset codes; names of family beneficiaries; information regarding financial transactions and financial operations carried out by other financial entities; and/or information about how you use our website or any other information that might be required by applicable laws.
We may also ask you to provide evidence of your identity such as asking for a copy of your passport, driving licence, proof of residence or income or any relevant identification card issued by a non-Prohibited Jurisdiction. We are required to ask for this information to comply with anti-money laundering (AML) legislation such as the Proceeds of Crime Act 2015, to ensure we safeguard against and report any suspicious activity.
We may also automatically collect the following information when you use our Applications:
The type of domain with which the User connects to the Internet; the IP address assigned; your geolocation; your login information; the date and time of access to the Applications and other data related to traffic; geolocation; API’S; the pages visited; unique device identifiers; the type of browser used; the operating system and/or platform used; the search engine as well as the keywords used to find the Applications; and other similar identifying information for communication with the Applications.
When you enter into a contract with us for the purchase of virtual currencies the following information is written onto the blockchain:
We use personal information about you in connection with the following purposes:
If you do not want your personal information to be used for marketing purposes, please contact us on the details below.
Why and when we share your information
We may share your Personal Data with third parties (including entities of the wider group of companies to which we belong) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process.
We may also be required by law or by a Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to public authorities to the extent we are obliged to do so according to the law, including the Employment and Training Board, Income Tax and Social Security department. We may also need to share your information in order to enforce or apply our legal rights.
In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
Transferring your information outside of the European Economic Area
Sometimes our business partners, third party service providers, agents, subsidiaries, affiliates, subcontractors and other associated organisations may be located outside of the European Economic Area (EEA). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.
We share your personal data with these third parties outside of the EEA where we have a legal basis for doing so, such as to provide you with our services or because we ourselves use service providers outside of the EEA in order to operate our business. If we transfer your information outside of the EEA to third parties we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).However, when interacting with the blockchain, as explained above in this Policy, the blockchain is a global decentralized public network and accordingly any personal data written onto the blockchain may be transferred and stored across the globe.
We do not use automated-decision making methods (including profiling), save that we may risk profiling our clients in compliance with applicable anti-money laundering legislation. This means decisions are not made by robots or computers, and therefore not ‘automated’. However, certain third parties may use certain automated decision-making tools or software. We are not responsible for the privacy practices of others and will take reasonable steps to bring such automated decision-making to your attention, but you are encouraged to become familiar with the privacy practices of any third parties you enter into any agreements with.
We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this Policy. Records can be held on a variety of media (physical or electronic) formats.Retention periods are determined based on the type of record, the nature of the record and activity of the legal or regulatory requirements that apply to those records. Typically, personal data which is collected pursuant to our legal obligations (such as AML) are retained for 5 years. Where personal data is collected pursuant to a contract or prior to the creation of a contract, these are retained for 6 years after the termination of the contract pursuant to our legitimate interests in defending any legal claims which may be brought against us. However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.
We have appropriate physical, technical and administrative security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have taken substantial precautions to ensure the security of your data. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality and a duty to comply with data protection procedures. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
You have certain rights under applicable legislation, and in particular under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“Gibraltar General Data Protection Regulation”) . We explain these below. You can find out more about the Gibraltar General Data Protection Regulation and your rights by accessing HM Government of Gibraltar, Laws of Gibraltar website at the following Link
a. Right Information and access
You have a right to be informed about the processing of your Personal Data (and if you did not give it to us, information as to the source) and this Policy intends to provide the information.
You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Data that we hold or process. To protect your Personal Data, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us using the details found in this policy.
b. Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.
The accuracy of your information is important to us. If you do not want us to use your Personal Data in the manner set out in this Policy, or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your Personal Data, please contact us using the details found in this policy
c. Right to erasure
You have the general right to request the erasure of your personal information in the following circumstances:
We will proceed to comply with an erasure request without delay and to such extent we are able to do so, unless continued retention is necessary for:
However, when interacting with the blockchain we may not be able to ensure that your personal data is deleted. This is because the blockchain is a public decentralized network and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances we will only be able to ensure that all personal data that is held by us is permanently deleted.
d. Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:
You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the services we can provide, and we will explain this to you if you decide to exercise this right.
However, when interacting with the blockchain, as it is a public decentralized network, we will likely not be able to prevent external parties from processing any personal data which has been written onto the blockchain. In these circumstances we will use our reasonable endeavours to ensure that all processing of personal data held by us is restricted, notwithstanding this, your right to restrict to processing may not be able to be fully enforced.
e. Right to data portability
Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
f. Right to freedom from automated decision-making
We do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your Personal Data are made by natural persons, not only by computers.
g. Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us.
h. Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us using the details found in this policy.
i. Raising a complaint about how we have handled your Personal Data
If you wish to raise a complaint on how we have handled your Personal Data, you can contact us using the details found in this policy.
j. Right to lodge a complaint with a relevant supervisory authority
You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
We are committed to fully comply with the data protection Applicable Legislation and help our users have visibility and ownership of their personal data. Therefore, if you wish to exercise any of your Data Subject Rights as set out in this Policy, or if you have any questions regarding this Policy or generally about the way we handle your Personal Data please enter this link o share your request with us.