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Privacy Policy

This Privacy Policy (this "Policy") for Kairos Studio Ltd., located in the BRITISH VIRGIN ISLANDS (the "Company", "we", "our", or "us") sets forth the basis on which we may process personal data we may collect from users of the Company's website, app.alphasec.trade, including any of its subdomains (the "Website"), in accordance with applicable law. For purposes of applicable data protection laws, the Company is the controller. For the purposes of this Policy, "you" and "your" refers to you as the user of the Website.

Read this Policy carefully so that you understand your rights in relation to your personal data and how we might collect, use, and process it. By accessing and using the Website, you expressly represent and acknowledge that you have read, understood, and agreed to be bound by this Policy. If you do not agree to this Policy, do not use, access, connect to or interact with the Website, or otherwise provide your information to us.

When you access, use, connect to, or interact with the Website, you agree that we may collect certain categories of information about you (the "Data"), including personal data, from a variety of sources.

Information you provide to us:

By accessing our services by connecting your digital wallet to the Website, you provide us with the following Data: (i) any digital-asset, smart-contract, or protocol address ("Wallet") information; and (ii) geolocation data.

Further to the foregoing, when you access and use the Website, we collect transaction data or history such as your public blockchain transaction history and other information associated with a linked address or Wallet and token holdings.

In the event you contact us, you will be required to provide your email address, which we will collect along with the content of our communications and any personal data contained therein.

Data we collect automatically:

While the following Data may not constitute personal information, when you visit certain pages on our Website, our servers save each access in a log file, and the following Data may be collected: (i) the date and time of access; (ii) the country from which the website is accessed; (iii) any API endpoints being accessed; (iv) user agent details; (v) the operating system of your computer and the browser you are using (provider, version, and language); and (vi) the transmission protocol used (e.g., HTTP/1.1).

Usage Data Collection:

We may use web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Website, including technologies collecting certain information about your access to, use of, connection to, or interaction with the Website ("Usage Data") that may be integrated with third-party service providers.

For your reference, a web beacon, also known as a clear gif, is a small, often invisible image embedded in a web page or online content to monitor user interactions on a website and track user behavior for analytical reporting purposes.

In our legitimate interests to provide effective services to you, we may also use this Usage Data to create aggregated, anonymized, or de-identified data.

Further to the foregoing, when you access, use, connect to, or interact with the Website, the Company and any of its third-party service providers may receive and record personal data that you may have provided and your digital signature.

By providing your digital signature in the course of your interaction with the Website, you explicitly agree to and approve the collection of your digital signature data, and you authorize the Company to store and process such data and use it to facilitate your access to and use of the Website. You further acknowledge and consent that such digital signature data may be disclosed and transferred to third-party service providers that you access through the Website.

Third-Party Wallet Connections and Disclaimer:

Certain features of the Website may require you to connect a compatible third-party digital Wallet. By using such Wallet, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet.

Wallets are not maintained or supported by, or associated or affiliated with, the Company. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

Legal Basis and Purposes for Processing Data:

We generally process the information we collect when we need to do so to perform our contract with you. For example, the processing of this Data is carried out for the purpose of enabling your access to, use of, connection to, and interaction with the Website, including: (i) to facilitate your connection to the Website; and (ii) to identify if you are likely to be a Restricted Person, as defined in our general Terms of Use, available at https://alphasec.trade/terms. Each case with respect to any of (i) or (ii) is in order for us to perform our contract with you and in our legitimate interests to provide access to the Website to you.

For the avoidance of doubt, the Company is not responsible or liable for verifying whether you are a restricted person; this remains your responsibility under the Terms.

Nonetheless, any information collected may assist the Company in verifying your eligibility if necessary.

Further, we may use any Data collected, including Usage Data, to tailor features and content to you and to ensure content is presented in the most effective manner for you and your device. We may also use and run analytics to better understand your user experience with respect to the Website.

We may also process this Data in our legitimate interests to assist system security and stability for provision of the Website, to conduct troubleshooting, data analytics, testing, and research, and to enable optimization and internal statistical analysis with respect to the Website, as well as to maintain the safety and security of our users, the Website, and to improve and develop the Website.

In addition to the foregoing, we may use any of your information to comply with any applicable legal obligations, to enforce any applicable terms of use, and to protect or defend the Website, our rights, and the rights of our users or others.

Cookie Policy:

Cookies are small data files stored on your device that help the Website remember your preferences, improve functionality, and understand general usage patterns. We use cookies to enhance your experience when accessing and using the Website. The cookies we use are strictly necessary cookies, which help ensure compliance with our Terms of Use, and are otherwise integral to our ability to provide the best user experience and to help us understand general usage patterns. These cookies are not used for marketing purposes. By continuing to use the Website, you consent to the placement of these cookies.

If we introduce optional cookies (e.g., analytics or marketing cookies) in the future, you will be able to block or delete them using the following methods:

How to Block Cookies

Desktop Browsers

  • Chrome: Click the "⋮" icon at the top right > Settings >Privacy and security > Cookies and other site data > Block third-party cookies
  • Edge: Click the "…" icon at the top right > Settings > Cookies and site permissions > Manage and delete cookies and site data > Block cookies
  • Safari (Mac): Safari > Preferences > Privacy > Block all cookies

Mobile Browsers

  • Chrome (Mobile): Tap the "⋮" icon at the top right > Settings >Site settings > Cookies > Block cookies
  • Safari (iOS): Device Settings > Safari > Block All Cookies
  • Samsung Internet: Tap the "≡" icon at the bottom > Settings >Sites and downloads > Block cookies

How to Delete Cookies

Desktop Browsers

  • Chrome: Click the "⋮" icon at the top right > Settings >Privacy and security > Clear browsing data > Select "Cookies and other site data" > Delete
  • Edge: Click the "…" icon at the top right > Settings > Privacy, search, and services > Clear browsing data > Select "Cookies and other site data" > Delete
  • Safari (Mac): Safari > Preferences > Privacy > Manage Website Data > Select items > Remove

Mobile Browsers

  • Chrome (Mobile): Tap the "⋮" icon at the top right > Settings >Privacy > Clear browsing data > Select "Cookies and site data"> Delete
  • Safari (iOS): Device Settings > Safari > Advanced > Website Data > Remove All Website Data
  • Samsung Internet: Tap the "≡" icon at the bottom > Settings >Privacy and security > Delete browsing data > Select "Cookies and site data" > Delete

YOUR RIGHTS​

Under applicable data protection laws, you may have certain rights in relation to your personal data. These rights may include the following:

  • Access to your personal data that we hold, information on how we use it, and who we share it with;
  • Request the correction of inaccurate or incomplete personal data we hold about you, which we may verify as necessary before making changes;
  • Deletion or removal of your personal data, in certain circumstances;
  • Objection to the processing of your personal data, in certain circumstances;
  • Restriction of the processing of your personal data, to stop us from processing the personal data we hold about you other than for storage purposes, in certain circumstances;
  • Portability of your personal data; we will endeavor to provide you, or a third party, with a copy of the personal data that we hold about you and transfer it to a third party in a structured, commonly used, machine-readable format;
  • Withdrawal of consent, where we rely on consent to process personal data; this will not affect the processing of personal data carried out before consent is withdrawn or on legal bases other than consent.

You may submit a written request concerning the processing of your personal data to support@alphasec.trade. Please note that, prior to any response to such request, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case.

Note that these rights apply only in certain circumstances and all of these rights may be limited by law. Such limitations may apply, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.

To the extent required under applicable data protection laws, we will be responsive to your request without undue delay and where required under applicable data protection laws, at least within one month (though this may be extended by a further two months in certain circumstances).

SHARING OF PERSONAL DATA​

In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law, including, but not limited to:

  • service providers and vendors ("Data Processor"): we may share your personal data with third parties to process on our behalf. Such Data Processor could include blockchain analysis service providers, screening service providers, developers, content delivery service providers, and data analytics service providers. Such service providers may assist us with many different functions and tasks, including geo-blocking based on IP address and collecting anonymized device information for analytics purposes.
  • professional advisors, in our legitimate interests or as required by law.
  • for legal and security reasons and to protect our Website, in our legitimate interests or as required by law.

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), to help us analyze how users interact with our services. In this regard, certain personal data (such as IP address, device information, and usage data) may be collected by Google and processed on our behalf. Google may also combine such data with other information it has collected about you through its own services.

By using our services, you acknowledge and agree that your personal data may be transferred to and processed by Google for the purposes of providing analytics and improving our services.

In particular, we use Google Analytics, a web analytics service provided by Google LLC ("Google"), to better understand how users interact with the Website. In this context, certain data such as device information, and usage data, may be collected by Google and processed on our behalf. By continuing to use the Website, you acknowledge and agree that your Data, including personal data, may be transferred to and processed by Google for the purposes of analytics and service improvement.

Your personal information may be transferred to and stored or processed in countries outside the jurisdiction in which you live and reside, including outside the European Economic Area ("EEA") and United Kingdom ("UK"), and including to the United States of America, in order to provide the Website, in which case we will disclose the relevant provision in the Privacy Policy or obtain separate consent from you for the transfer. Your personal information may also be processed by staff operating outside the UK/EEA who work for us or for third-party service providers or partners. We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy. Should we transfer your personal information to third parties located outside the EEA/UK, we will seek to put in place appropriate safeguards to ensure that this transfer occurs in accordance with applicable laws. These measures include seeking entry into the standard contractual clauses ("SCCs") approved by the European Commission (for transfers outside the EEA) and/or an international data transfer agreement/addendum to the SCCs approved by the UK Information Commissioner's Office ("ICO") (for transfers outside the UK), unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals' rights and freedoms for their personal data.

RETENTION​

We will retain your Data only for so long as necessary to fulfill the purposes for which it was collected, but in any case no longer than [5] years, unless we are required to retain the Data to satisfy any legal, accounting or reporting requirements, or as otherwise required by law. The length of time we retain your Data will depend on the nature of the Data and the purpose for which it was processed.

Upon expiration of the retention period, we will delete your Data; however, if complete deletion is impractical, we will take reasonable measures, considering time, cost, and technology, to anonymize the personal data so that it can no longer be used to identify you.

CHILDRENS' PRIVACY AND DATA PROTECTION​

If we become aware that we have unknowingly collected information about any person under eighteen (18) years of age, we will make commercially reasonable efforts to delete such personal data and other information from our records.

SECURITY MEASURES TAKEN TO PROTECT PERSONAL DATA​

The Company implements reasonable measures to protect your personal data. However, be aware that despite our efforts to protect your personal data and other information, we cannot guarantee perfect security of your information transmitted through the Website. In addition, note that any information you send to us electronically, may not be secure while in transit. Any transmission is at your own risk.

We may provide links on the Website to other websites or online platforms operated by third parties, including social media or content platforms operated by third parties, such as X (formerly Twitter) or Medium (such platforms, generally, "Social Media Platforms"). We may also provide links to websites or online platforms operated by third-party contributors to the NitroX blockchain and ecosystem ("Contributors"). We do not own, operate, or control such third-party websites. If you follow links to sites not owned or operated by us, you should review their available privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy, security, or content of these sites, including the accuracy, completeness, or reliability of information and services found on these sites.

Note that third parties and Contributors may provide services, information, dashboards, websites, tools, functionalities, and applications, and these may be linked from time to time through the Website or through Social Media Platforms. Such third parties and Contributors are independent and as such, we do not own, operate, or control their services, information, dashboards, websites, tools, functionalities, and applications and cannot guarantee, and are not responsible for, the privacy, security, or content of these sites or the accuracy, completeness, or reliability of services, information, dashboards, websites, tools, functionalities, and applications found on these sites. Our inclusion of links, including through Social Media Platforms, does not, by itself, imply any endorsement of such services, information, dashboards, websites, tools, functionalities, and applications, or of their owners, operators, or publishers, except as disclosed on the Website.

When you open a link to any Social Media Platform from the Website, a direct connection may be established between your browser and the server of the Social Media Platform. This provides the Social Media Platform with information that you visited the Website and accessed the link. If you access a link to a Social Media Platform while logged-in to your account on the Social Media Platform concerned, the content of the Website may be linked to your profile on the platform (i.e., the Social Media Platform may link your visit to the Website directly to your user account). If you want to prevent this, you should log out before clicking on the relevant links. In any case, an association takes place when you log-in to the relevant Social Media Platform after clicking on the link.

You understand and agree that it is your sole responsibility to connect to third-party Social Media Platforms through our Website. You further agree to indemnify, defend, and hold the Company harmless from any loss, damages, liabilities, or expenses incurred in connection with your use of any third-party services accessed via the Website.

GOVERNING LAW AND DISPUTE RESOLUTION​

This Policy takes into account the requirements of British Virgin Islands' privacy policy and general privacy principles, and shall be governed by and construed in accordance with the laws of the British Virgin Islands. Individuals located in the European Union ("EU") and the United Kingdom ("UK") may have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, respectively (collectively, the "GDPR").

You and the Company agree to waive the right to have any and all disputes or claims arising from this Policy ("Disputes") resolved in a court. Instead, all Disputes will be resolved through binding arbitration. All arbitration proceedings will be conducted solely on an individual basis. No Dispute may be brought as a class action or representative action, whether in arbitration or any other forum.

You agree to notify us, in writing, of any Dispute within thirty (30) days of when it arises so that the parties can attempt, in good faith, to resolve the Dispute informally. Notice to the Company shall be provided by sending an email to support@alphasec.trade. Your notice must include: (1) your name, postal address, and email address; (2) a description of the nature or basis of the Dispute; and (3) the specific resolution or action that you are seeking. If the Dispute cannot be resolved informally within thirty (30) days of receipt, either party may commence arbitration.

Any Dispute that remains unresolved after the informal resolution process will be finally resolved by arbitration under the rules of the London Court of International Arbitration (LCIA), as amended from time to time, which are incorporated by reference into this clause. Arbitration will be conducted in English, in London, United Kingdom, by a single arbitrator appointed under the LCIA Rules. Each party shall bear its own costs, unless otherwise determined by the arbitrator. For the avoidance of doubt, neither you nor the Company may bring a Dispute in any court located in the United States of America.

PERIODIC REVIEWS AND UPDATES TO POLICY​

We may review and update this Policy from time to time. While the Company shall not be liable for any such modifications, suspensions, or discontinuance, the Company will use reasonable efforts to provide prior notice of changes. In principle, notice of at least seven (7) days will be given before any changes to this Policy take effect, and in the case of material changes, notice of at least thirty (30) days will be given. If advance notice is not reasonably practicable, notice will be provided promptly by posting the revised Policy on the Website. For the avoidance of doubt, posting the revised Policy on the Website shall be deemed to constitute valid and sufficient notice of such changes.

Updates to this Policy will apply only to information collected after the date of the change. If we make changes, we will update the "Last updated" date at the top of this Policy. If you continue to participate in the Interface in any way after a change to these Terms, you will be deemed to have read, understood, and unconditionally consented and agreed to such changes. You should review this Policy and applicable policies and guidelines frequently to understand the terms and conditions that apply to your provision of Data. If you do not agree to the revised Policy, you must immediately cease using the Website and contact us if you wish to have your personal data deleted before the end of the prescribed retention period.

CONTACT​

Should you have any questions or complaints about our privacy or data-protection practices, your personal data, or this Policy, you can email us at support@alphasec.trade.