If you have any questions, please feel free to contact us at: firstname.lastname@example.org.
References in this Policy to “Point Network”, “we”, “our” or “us”, are to POINT NETWORK LIMITED, a private company incorporated in the Republic of Vanuatu, and references to “user”, “you” or “your” are to the person who is visiting, using, accessing or installing (i) our website www.pointnetwork.io (“Website”) and/or (ii) our software products, including any downloadable desktop and mobile applications (“Software Products”).
IF YOU DO NOT AGREE WITH THIS POLICY PLEASE LEAVE THE WEBSITE OR CEASE USING AND UNINSTALL SOFTWARE PRODUCTS IMMEDIATELY.
1. Our Status
- We will act as a data controller in relation to personal information about you that may be either provided by you or collected by us.
- As a data controller, we will solely determine the purposes and means of the processing of your personal information.
2. Information You Provide to Us
- We may collect information from you when you:
- visit the Website, register and/or sign in to the Website;
- use our Software Products;
- make any inquiry to us related to the Website, Software Products or any of our projects, products or services via the Website /email /Telegram /phone /live chats /contact form, etc.;
- reach our customer support services and/or submit a support ticket;
- sign up for newsletters; or
- provide us with your personal information in any other way (e.g. through webinars, user conferences, feedback sharing, etc.).
Please note that not all the information you provide to us is personally identifiable information according to the applicable law.
- Please be aware that our Software Products may allow you to transfer data and information directly to decentralised blockchain networks. Please be aware that once data has been added to decentralised blockchain networks it becomes public to anyone and cannot be deleted.
Information provided by you in the profile of your account, including your name or nickname, may be visible to the public and other users of the Website.
Use caution about the personal data you share with others.
- When you create an account with the Website we may ask you for the following information:
- Your name or nickname;
- Your email address.
- When you participate in the Token Sale and related identity verification, in addition, we may ask you for the following information:
- Your full name;
- Your phone number;
- Your address and country of residency;
- Your nationality;
- Your identification documents (for example, driving license or any other national ID, internal or international passport) and information contained therein;
- Documents proving your address and residency and information contained therein;
- Other documents and related information that we consider necessary for your identification.
- When you reach our support services or send us an inquiry related to the Website, Software Products and our services, in addition, we may ask you for the following information:
- Your account id with the Website;
- Any other information you provided to us from your request or inquiry
- Your email, or Telegram account id, or phone number that may become available to us.
- It is your sole decision whether to provide us with the requested information or not. However, if you choose to withhold requested information, we may not be able to provide you with access to the Website, Software Products, the possibility to use our services, we may reject your participation in the Tokens Sale or not allow you to purchase Tokens. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as optional.
- We may process provided information in the following ways:
- We will store your information in our database;
- We will use your information to provide you access to the Website, Software Products and/or our services;
- We will use your information to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- We will use your information to verify your identity;
- We will send you our newsletters when you consented or when we have a legitimate interest to do so;
- We will process your request, inquiry or support ticket;
- We will contact you regarding your request, inquiry or support ticket;
- We will store the history of our communication;
- We will contact you and/or use your information for quality control purposes;
- We will detect, prevent, or investigate security breaches, fraud, and other unauthorised or illegal activities.
We may process your personal information in other ways but these will be limited to processing your request or performance of the contract with you or handling our legal obligations to process your personal information.
- For the purposes of legitimate interest we may contact you about our new commercial offers, updates in our services or in the Website, Software Products, newsletters, content, and events we believe may be relevant to you.
3. Information We Collect From You
- When you visit the Website, use Software Products or our related services we may collect usage statistics and other data, which helps us to improve our Website, Software Products and related services, provide a better user experience, prevent or assess security risks, measure the performance of our marketing and advertising campaigns, detect and protect against fraudulent transactions and other suspicious activities.
- We may collect the following data while you visit or use our Website:
- IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, search terms, the links on the Website that you clicked on or used;
- cookies (as specified in the Section 4 of this Policy);
- local storage files (as specified in the Section 5 of this Policy).
- We may collect the following data while you use Software Products:
- IP address, geographical location, version, language, basic information about crashes and errors;
- your device number, device id or unique identifier, device type, and unique device token, operating system and applications used, application crash-data, application version, device identifiers such as IDFA (Identifier For Advertisers), Android ID (Android device), referrer URL (Playstore), Google Advertiser ID, device model;
- interactions with Software Products (number of open tabs and windows, number of decentralised pages visited, number and type of installed add-ons or plugins and session length) and features offered by us.
- Cookies make it easier for you to use our Website during future visits. They also allow us to monitor traffic and to personalize the content of our Website for you. Session-based cookies only last while your browser is open, and are automatically deleted when you close the browser. Persistent cookies last until you or your browser deletes them or until they expire.
- Some of our cookies are necessary for certain uses of the Website. These cookies allow us to make our Website usable by enabling basic functions like page navigation. The Website may not function properly without these cookies.
- We may also use functional cookies and cookies from third parties for analysis and marketing purposes. Functional cookies enable certain parts of the Website to work properly and your user preferences to remain known. Analytics cookies, among other things, collect information on how visitors use our Website, the content and products that users view most frequently, and the effectiveness of our third-party advertising.
- To recognise new or past users;
- To keep you signed in at the Website;
- To remember your user interface preferences and provide you with a suitable user interface of the Website;
- To improve our Website and to better understand your visits on the Website;
- To observe your behaviour and browsing activities;
- To better understand the interests of our users and our Website visitors.
- We use the following third-party services to monitor and analyse web traffic and user behaviour:
While we do our best to keep this list updated, please note that third parties who place cookies on your device may change from time to time, and there may be a slight delay updating the list.
Internet Explorer link
Safari (Desktop) link
Safari (Mobile) link
Android Browser link
For other browsers, please consult the documentation that your browser manufacturer provides.
You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance. Please consult http://www.aboutads.info/ for more information.
5. Local Storage
- You can clear local storage files from your browser by taking the following actions:
- In Firefox, localStorage is cleared when the following conditions are met: (a) user clears recent history, (b) cookies are selected to be cleared, and (c) time range is “Everything”;
- In Chrome, localStorage is cleared when the following conditions are met: (a) clear browsing data, (b) "cookies and other site data" is selected, and (c) timeframe is “from beginning of time.” In Chrome, it is also now possible to delete localStorage for one specific site;
- In Internet Explorer, to clear localStorage: (a) click on Tools--Internet Options, (b) General tab, (c) delete browsing history on exit, (d) ensure “Cookies and website data” (or “temporary internet files and website files”) is selected, and (e) consider unchecking "Preserve Favorites website data" at the top;
- In Safari, to clear localStorage: (a) click Safari, (b) then click preferences, (c) select the Privacy tab, (d) click Remove all website data and (e) click Remove Now.
6. Grounds for Processing Your Personal Information
- We process your personal information based on the following grounds:
- Processing of your personal information is necessary for the performance of a contract with us to which you are a party or in order to take steps at your request prior to entering into a contract with us; or
- Processing of your personal information is necessary for the purposes of legitimate interests pursued by us; or
- You give us your consent to process your personal information; or
- We have legal obligations to process your personal information.
- Processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract with us
We will use your personal information to provide you access to the Website or Software Products, to provide you our services, to identify you and allow you access to customer support services, to process any request by you for information, to manage your account, to deal with enquiries, complaints and feedback from you, to contact you for any issues related to the Website or Software Products.
We will use your personal information to verify your identity when you intend to participate in the Token Sale and/or intend to purchase Tokens.
- You give us your consent to process your information
We will use your personal information to keep you informed about our new services or products, services upgrades, special offers, and other services of us and/or selected third parties when you have consented to receive such communications.
We will also use your personal information to improve our Website, Software Products, to provide you better user experience.
- Processing is necessary for the purposes of legitimate interests pursued by us
We will use your personal information to contact you about special offers, webinars, events and promotions that may be of interest to you, to send any updates regarding services you have shown interest in or provide further information related to the topic you requested, to get your consent to further contacting you regarding any other services you might be interested in.
We will use your personal information to contact you with infrequent service alert messages to inform you of specific changes that may impact your ability to use the Website, Software Products or our related services.
We will use your personal information to develop and conduct our business. Some examples of how we use personal information include: improving our services, personalising communications with you, conducting market research, conducting customer surveys, engaging in more targeted, customer-specific advertising, to protecting against the contravention or unauthorized use of our Website or Software Products.
We will also use aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes to help improve our offerings to you, to help diagnose any problems with our server and administer the Website or to improve your browsing experience by personalising the Website.
- We have legal obligations to process your information
We may use and hold some of your personal information for complying with legal requirements and obligations, including but not limited to, requirements related to online purchases and payments (including payments in crypto assets), sale of crypto assets and anti money laundering. When we are required to we will store your information for the period that may exceed our general data retention period.
7. General Processing and Disclosure
- Our processing means any operation or set of operations which is performed on personal information, 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, support, maintenance, etc. We do not make automated decisions, including profiling.
- We may also disclose your personal information when we have a good faith belief that (i) we are required to do so by law, or in response to a subpoena, court order, or other legal mechanism, or (ii) it is necessary to: detect, prevent and address fraud and other illegal activity, to protect ourselves, you and others, including as part of investigations.
- We have implemented measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration, and disclosure.
8. How Long We Store Your Personal Information
- We only retain your personal information for as long as is necessary for us to use your information as described above or to comply with our legal obligations and legitimate interests. For instance, we may retain your data as necessary to meet our legal obligations, such as for tax and accounting purposes.
- We will retain your personal information no longer than 2 years from: i) your last sign in to the Website, ii) your last use of Software Products, iii) the last delivery of our services to you, or iv) our last interaction with you related to your inquiry, whichever is later.
- We will store your personal information that is used to send you promotional e-mails and/or newsletters or used in relation to your support tickets. Such information will be stored and processed solely for this purpose until you withdraw your consent, where applicable, or unsubscribe from newsletters, but not longer than for 2 years after your last interaction with us.
- Otherwise, we either delete or anonymise personal information collected. In case personal information was transferred to a backup storage and, therefore, cannot be deleted, we continue to store it in a secure fashion, but do not use it for any purpose. In all the other cases, we proceed with the deletion of personal information.
9. Third Parties
10. Rights of European Users
If you located in the EEA zone, UK, Switzerland as a data subject (a person whose personal information is collected, stored and processed) you have several rights under data privacy laws:
- Right of access. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (i) the purposes of the processing; (ii) the categories of personal information; (iii) to whom the personal information has been or will be disclosed; (iv) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.
If you would like to have a copy of your personal information from us, we will provide it if (i) you prove your identity, (ii) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, for any further copies we may charge a reasonable fee based on administrative costs.
- Right to rectification. You have the right to demand that we correct without undue delay your personal information which we have in our systems if it is inaccurate or incomplete.
- Right to erasure (“right to be forgotten”). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (i) this personal information is no longer necessary in relation to the purposes for which it was processed; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) your personal information has been unlawfully processed; (v) your personal information has to be erased for compliance with a legal obligation.
- Right to restrict processing. You have the right to restrict us in the ability of processing of your information where one of the following applies: (i) you contest the accuracy of your personal information and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your personal information, but you need it for establishment, exercise or defence of legal claims; (iv) you have objected to processing and we are verifying whether legitimate grounds override your request.
- Right to data portability. You have the right to receive your personal information which you provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (i) the processing is based on your consent or on a contract; and (ii) the processing is carried out by automated means.
Where technically feasible, you can demand that we transmit those data directly to another company.
- Right to object. You have the right to object to the processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.
Where personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing.
- Right to withdraw consent. You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
12. Contact details
Last Updated on 9 June 2021.