Last updated: July 21, 2018.
ROMAD HOLDING LTD (the “Company”, “we”, “us”), а legal entity established under the
laws of the Republic of Cyprus, with its registered office at Kallipoleos, 17,
3rd floor, Office 303, 1055, Nicosia, the Republic of Cyprus, registration number:
HE 365697, respects your privacy and commits to protect it.
data collected from you.
RoBust Defense token or RBDT – token, issued by the Company or its affiliates,
with the use of the blockchain technology according to the demands that are generally
accepted for this type of technology.
Software ROMAD Endpoint Defense or Software – the software, which is designed
to secure from viruses and Trojans, block unauthorized system calls to an operating system
and resist to malwares, with supplemented documents.
Token generation event or TGE - sales of RBDTs.
Website – Company’s website
2. GENERAL INFORMATION
This Policy is designed to assist you with understanding regarding the types of personal
data we collect, store and process; the purposes for such operations and other relevant matters.
By continuing to use the Website, creating an account, participation in TGE, holding of RBDT,
you agreed with this Policy and allow us to collect, store and process your personal data
in accordance with this Policy for all purposes defined herein. If you do not agree with
this Policy in general or any part of it, you should not access the Website, use services
or product, offered on the Website, participate in TGE.
It is important for you to understand: (і) what personal data we collect, store and process;
(іі) how you can influence on operations we carry out with your personal data.
Please read this Policy carefully.
3. WHAT PERSONAL DATA DO WE COLLECT
The Company collects personal data when you:
use the Website and/or
participate in TGE, as defined in (і) agreement between you and the Company and
(іі) Terms and Conditions, that can be found at the Website.
Personal data includes:
country of residence;
IP-address and utm_source;
other information about you that you give us by filling in forms on the Websites
or necessary by default to provide your our services.
4. WHAT ARE THE PURPOSES OF THE DATA PROCESSING
We use your personal data in order to:
process transactions and send notices about your transactions;
enable your participation in TGE;
protect in full your legal interests;
perform our obligations regarding any contracts concluded between you and us;
fulfill our obligations under the applicable legislation;
provide you with the full scope of information regarding TGE and our Website operation;
administer, improve our Website by data analysis, testing, statistical and research
operations as well as developing new options;
ensure that our Website content is presented in the most effective manner;
provide you with all of our Website functionality and ensure its security;
handle communications with you and respond to you requests;
detect, investigate and prevent unauthorized activities and fraudulent transactions.
5. LEGAL BASIS FOR YOUR PERSONAL DATA PROCESSING
Data processing operations are performed after you give us consent expressed directly
(e.g., by accepting this Policy or clicking consent bottom) and/or resulted from any
affirmative actions that indicate your consent (e.g., voluntary filling of any of the
forms on the Website).
Please keep in mind that your personal data procession is our legitimate interest
and required for necessary for the performance of agreements between you and us regarding TGE.
In certain cases, when additional verification by a bank or compliance authority is needed
to comply with governmental rules, anti-money laundering (“AML”) or “know-your-customer” (“KYC”)
policies, we may require you to provide additional information. Such collection of information
may be demand of the applicable legislation.
This additional information shall only be necessary if requested and may be required prior to
activation of your account. We are sometimes required to compare the personal data you provide
with third party databases in order to verify its accuracy and confirm your identity to comply
with relevant AML regulations and KYC regulations. We may use your personal data and other
information we collect to detect, investigate and prevent fraudulent transactions and other
illegal activities, develop new products and services and to verify compliance with our Terms
6. WHAT OPERATIONS DO WE PERFORM WITH YOUR PERSONAL DATA
We use your personal data to make all opportunities of our project available and convenient
for you. In line with this, we use your data to activate your account, to provide necessary
support and protection, and to improve our Website, services and products.
We also use your personal data only to identify you and send notifications. Apart from this,
we collect and store your personal data in secured registers. Please note that we do not amend,
disclose or transfer your personal data. We will store your personal data for a period of TGE
or up to your request to erase it, unless we have an obligation to save and keep it under the
applicable legislation (e.g., AML).We will keep some of your personal data despite the demand
to erase it or restrict its processing if it’s requirement of applicable law or necessary for
performing our legal duties or establishing, pursuing, or defending a claim.
The information that we collect from you may be transferred to, and stored in various
jurisdictions outside of your country of residence, including third countries.
We will take all steps reasonably necessary to ensure that your information is treated
securely and in accordance with this Policy.
7. YOUR RIGHTS
You have the following rights:
||Ways of realization
to access your personal data
by log in to your account
to restrict the processing of personal data if (і) the processing of your personal
data is unlawful; (іі) we no longer need your personal data to process it.
by requesting us directly via any mean indicated in Chapter 12
to get a copy of your personal data and receive your personal data in a machine-readable
to object the use of your personal data
to withdraw your consent if you are a resident of EU
to request for your personal data erasure
the right to lodge a complaint with a supervisory authority if you are a resident of EU
the complaint can be filed both before the relevant Data Protection Authority
to correct your personal data
using the account functionality or by referring to us directly
Please be aware that after your have contributed to TGE, in certain cases we will not able
to enforce some of the abovementioned rights according to applicable legislation (e.g., AML)
or requirements of public authorities.
You may also enjoy other rights envisaged by the applicable legislation.
We completely respect and follow, where applicable, the rules and provisions of the EU General
Data Protection Regulation (GDPR). Within the scope of GDPR we are the data controller of your
personal data, so that we will implement appropriate technical and organizational measures in
an effective way in order to meet the requirements of GDPR and protect the rights of all TGE
on our Partners operation strategies, but we provide you all necessary information about such
Partners and their privacy policies.
You can change your browser settings in order to block all files and/or notifications regarding
its sending. Unfortunately, some of the website functions may work incorrectly afterwards.
9. THIRD PARTIES
Please be aware that we will process your personal data only by ourselves, our affiliates
and/or our Partners without any disclosure to any third parties.
Your personal data may be disclosed exclusively upon request of the competent authority
(public, government, regulatory, judicial and law enforcement) in a strict compliance
with the procedure foreseen by the applicable legislation.
We may share your personal data to other parties only after receiving your prior and
explicit consent for that.
10. PROTECTION OF YOUR PERSONAL DATA
We apply a number of technical and organizational measures in order to ensure the
secure storage and use of your personal data. Along with this, we take measures to
prevent non-authorized access and the personal data outflow.
Please be aware that apart from our efforts, we expect that you will also apply
certain protection measures, as complete security of your personal data can be reached
only through join efforts.
11. CHANGES TO THIS POLICY
This Policy may be updated from time to time. We place its current version on the
Website as soon as possible. Please check updates or amendments to our Policy.
In case of substantial changes that can strongly influence on your rights realization,
we will notify your regarding such changes via email.
12. HOW TO CONTACT US
If you have any feedback, concerns or complaints, please contact us directly:
Email: [email protected]