Privacy policy

Last revised: 26 Sep 2018

SociumNet Ltd. (hereinafter - “we”, “us” and “our”) value the privacy of visitors to our websites. To ensure transparency, this Privacy Policy describes our information handling practices when you access content we own or operate on the websites located at sociumtrade.com, or any other websites, pages, features, or content we own or operate (collectively, the "Website(s)"). Acknowledge yourself with this Privacy Policy carefully. If you have any questions about this Privacy Policy, please contact us at support@sociumtrade.com.

  1. Acceptance of Privacy Policy

    By accessing and using our Website, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. If you do not agree with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Website.

  2. Changes to Privacy Policy

    We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Website prior to the change becoming effective.

  3. Information about SociumNet Ltd.

    SociumNet, Ltd is a private limited company incorporated in Malta with company number C86095 and whose registered office is 83, St. Paul’s street, Valleta, Malta. SociumNet will be conducting a Token sale and then developing SociumTrade project as described on the Website, Token sale agreement and Whitepaper.

  4. The personal information we collect

    Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you. SociumNet may share your personal information with companies directly connected to SociumNet or its third party services providers (for example KYC/AML services provider) and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content (see the section below). Except as described in this Privacy Policy, SociumNet will not give, sell, rent or loan any personal Information to any third party.

  5. Personal information collected

    We collect personal information to allow you to participate in our Token sale. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our services when you do choose not to share certain information with us.

    For example, we collect personal information which is required for our KYC/AML services provider to verify your identity. We also collect personal information when you use or request information about our Token sale, subscribe to marketing communications, request support, complete surveys, etc. We may also collect personal information from you offline, for example when you contact our customer support.

    We collect the following types of information:

    1. Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
    2. Formal Identification Information: Tax ID number, passport number, national identity card details, photograph identification cards.
    3. Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
    4. Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
    5. Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.
  6. How your personal information is used

    Our primary purpose in collecting personal information is to provide you with the most accurate information about our Token sale and to make sure that any funds gathered during Token sale are legal and can be used to develop a great product for you. In general, we use personal information to create, develop, operate, deliver, and improve our Website, content and advertising, and for prevention of anti-fraud. We may use this information in the following ways based on our contract with you:

    1. To maintain legal and regulatory compliance

      To legally use the funds gathered during Token sale we are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, transaction information, online identifiers, and/or usage data in certain ways. For example, we must identify and verify customers sending funds to our Token sale in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records.

    2. To provide you services

      We process your personal information in order to provide services to you. For example, when you want to buy our tokens, we require certain information such as your identification, contact information, and payment information. We cannot provide you with services without such information.

    3. To provide Service communications

      We send administrative information to you to keep you updated about our Token sale, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect you.

    4. To provide customer service

      We process your personal information when you contact us to resolve any questions, disputes or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests.

    5. To ensure quality control

      We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Website. Our basis for such processing is based on the necessity of performing our contractual obligations with you.

    6. To ensure network and information security

      We process your personal information in order to enhance security, monitor and verify identity, combat spam or other malware or security risks and to comply with applicable security laws and regulations. Without processing your personal information, we may not be able to ensure the security of our Website and satisfy our legal obligations.

    7. For research and development purposes

      We process your personal information to better understand the way you use and interact with our Website. In addition, we use such information to customize, measure, and improve content and layout of our website. Without such processing, we cannot ensure your continued enjoyment of our Website. We process this personal information to satisfy our legitimate interests as described above.

    8. To engage in marketing activities

      Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Website and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.

    We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or services may not be available to you.

  7. Information from third party sources

    From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.

    1. Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws.
  8. Collection and use of information collected automatically

    We receive and store certain types of information automatically, such as whenever you interact with the Website. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software and your Internet Protocol (IP) address/MAC address/device identifier.

    For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at the Website via an external link, such as a link appearing on a third party Website.

  9. Information sharing with third parties

    We allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We will never sell or rent your personal information. We will only share your information in the following circumstances:

    1. We share your information with third party identity verification services in order to prevent fraud. This allows us to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
    2. We may share your information with service providers under contract who help with parts of our Token sale such as marketing and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
    3. We share your information with financial institutions with which we partner to process payments you have authorized.
    4. We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate any violations.

    Please note that any third parties you interact with may have their own privacy policies, and we are not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, who may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

  10. How we protect and store personal information

    We understand how important your privacy is, which is why we maintain (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

    However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Website, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

    Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

  11. How to change your personal information

    You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking Settings, Personal information.

    After participation in Token sale we will keep your account information in our database for a period of time. This is necessary in order to make sure that people, who participated in Token sale haven‘t committed fraud and will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

  12. Rights in relation to the use of your personal information
    1. Rights of access, correction and deletion

      You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

    2. Right to object

      You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.

    If you wish to exercise any of these rights, please contact us as set out below.

  13. Retention of personal information

    We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

    1. Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
    2. Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
    3. Recording of our telephone calls with you may be kept for a period of up to six years.
    4. Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
  14. Children’s personal information

    We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, we will require the user to close his or her account and will not allow the user to continue participate in Token sale. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 participating in our Token sale so we can take action to prevent access to our Token sale.

  15. Legal bases for processing personal information

    We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of SociumNet, our customers or others.

  16. Direct Marketing

    We will contact you if you are located in the EU by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to use your personal information in this way, or to pass your personal information on to third parties for marketing purposes contact us at info@sociumtrade.com. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services.

  17. Individual Rights

    When we receive an individual rights request via email we may take steps to verify your identity before complying with the request to protect your privacy and security.

    Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

    1. Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of data processing based on consent before your withdrawal.
    2. Right of access to and rectification of your personal information. You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by us that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
    3. Right to erasure. You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. The above is subject to limitations by relevant data protection laws.
    4. Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.
    5. Right to restriction of or processing. You have the right to restrict or object to us processing your personal information where one of the following applies:
      1. You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
      2. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
      3. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
      4. You have objected to processing, pending the verification whether the legitimate grounds of SociumNet processing override your rights.
    6. Notification of erasure, rectification and restriction. We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.
    7. Right to object to processing. Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
    8. Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
    9. Right to lodge a complaint. If you believe that we have infringed your rights, we encourage you to contact us first at info@sociumtrade.com so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.
    10. Storage of your personal information. We will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.
    11. Data Protection Officer: You may reach the Data Protection Officer at support@sociumtrade.com.

    Your rights to personal information are not absolute. Access may be denied when:

    • Denial of access is required or authorized by law;
    • Granting access would have a negative impact on other's privacy;
    • To protect our rights and properties; and
    • Where the request is frivolous or vexatious.
  18. Cookies

    The Website may use a browser feature called a “cookie” to collect information anonymously and track user patterns on Website. A cookie is a small text file containing a unique identification number that identifies a customer’s browser, but not the customer personally, each time that customer visits a websites using cookies.

    Cookies tells us which pages of the Website are visited and how many people visited each one. This helps enhance visitors’ online experience. Cookies also serve to identify your computer so that your preferences can be saved for future visits, and SociumTrade may work with third parties that use these cookies to help us.

    You have the right to decide whether to accept cookies. You can exercise your preferences in relation to cookies served on our Website. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Website.

  19. How to contact us

    If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us at support@sociumtrade.com, or by writing to us at: 83, St. Paul's Street, Valletta, Malta. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.