Last Updated: 07/06/2018
Information We Collect
Information You Provide to Us.
Registration Information. If you register for iCash Token Sale, we ask you to provide your email address, password, and information necessary to verify your identity or otherwise required by applicable law. This information may include identity verification information such as your full name, address, phone number, and date of birth, a copy of your government-issued identification (e.g., passport, driver’s license, or identity card), and investor accreditation information , to the extent permitted under applicable law.
Purchase Information. If you make a purchase through iCash Token Sale, we require that you provide certain financial information to facilitate the transaction. In addition, if you choose to make a Token Sale purchase as an entity, we ask for information such as the entity’s name, your position at the entity, and the date of purchase.
User Content. Our Services contain publicly accessible blog posts. If you choose to comment on our blog posts, we ask for your name and email address. Please be aware that your name, email address, and the content you post will always be visible to other iCash users. We are not responsible for other users’ use of such information, so you should carefully consider whether and what to post or how you identify yourself on our Services.
Communications. If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team or sign up to receive updates regarding new products and/or services, we will receive your email address, the contents of your message, and any attachments that you may send to us.
Information We Collect When You Use Our Services.
We may use this information, for example, to ensure that our Services function properly, to determine how many users have provided comments, or to prevent fraud. We also may use such technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.
Information from Other Sources.
You may direct us to retrieve information maintained online by institutions with which you have a pre-existing relationship. We work with one or more online service providers to access this information.
We may also process Personal Information about employees of our customers, vendors and partners (i.e., names and professional contact information) that those customers, vendors and partners provide to us in the context of our contractual relationships with them.
How We Use the Information We Collect
We use the Personal Information we collect for a number of reasons, including:
- To provide and maintain our Services, including Token Sale, which allows you to purchase iCash tokens;
- To comply with our legal obligations, including by verifying your identity;
- To understand and analyze how you use our Services;
- To improve and enhance our Services and develop new products, services, features, and functionality;
- To communicate with you, to provide you with updates and other information relating to our Services, to provide information that you request, to respond to comments and questions, and otherwise provide customer support;
- To the extent permitted by applicable law, for marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
- To send you text messages (including for two-factor authentication) and push notifications;
- To anonymize your Personal Information;
- To facilitate transactions and payments;
- To respond to trust and safety issues that may arise;
- To find and prevent fraud; and
- For compliance purposes, including enforcing our Terms & Conditions, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental authority.
When We May Use Your Information
If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:
- You have consented to the use of your Personal Information, for example, to receive electronic marketing communications or provide you with tailored advertising;
- We need your Personal Information to provide you with the Services, including for account registration or to respond to your inquiries;
- We have a legal obligation to use your Personal Information, such as the obligation to protect IP rights and restrict content available on the Services based on your location;
- We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to conduct business analytics, and otherwise improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.We, or a third party verification provider , may perform automated ID checks which may lead to an automated refusal of access to our Services. However, we will not subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, unless you explicitly consented to the processing, the processing is necessary for entering into, or performance of a contract between you and iCash, or when we are legally authorized to use your Personal Information in this way, for example to prevent fraud.
How We Share the Information We Collect
Internal Disclosures. We may share Personal Information with our headquarters, affiliates and subsidiaries. Personal Information will only be available to those who need such access for the purposes listed above or where required by applicable law.
Vendors and Service Providers. We work with third party service providers that perform services on our behalf, and we may share your Personal Information with such providers retained in the provision of our Services, including all of the information described in the “Information We Collect” Section above. For example, we work with Token Soft to deliver our iCash Token Sale platform, and payment processors to process financial transactions. In addition, we use third party analytics vendors, such as HubSpot and Google Analytics, to evaluate and provide us with information about your use of our Services.
As Required By Law and Similar Disclosures. We and our vendors and services providers may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; (c) find and prevent fraud; and (d) protect your, our or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation, receivership, sale of our assets, or transition of our Services to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
Aggregate Data. Where legally permissible, we may share information about you with our partners in aggregated or de-identified form,
Consent. We may also disclose your Personal Information with your permission.
Your Choices and Rights
You can view and edit your account information, including your email address and password, at any time by visiting “Account Information” in your iCash Token Sale profile settings. You can unsubscribe from our commercial emails via the link provided in these emails. Even if you opt-out of receiving such emails from us, you may continue to receive service related messages from us. Note, there is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals at this time.
If you are located in the European Economic Area (“EEA”) or Switzerland, you may have the following additional rights:
- Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. If we subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, you may have a right to obtain human intervention, to express your point of view and to contest the decision.
- You may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
- Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us at the contact information provided below.
Third Party Services
We are committed to protecting your Personal Information. Even though we use certain safeguards that are designed to ensure the integrity and security of Personal Information that we collect and maintain, please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our safeguards. The foregoing may be subject to requirements under applicable law to ensure information security.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the EEA, Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. Also, we may transfer your Personal Information from the U.S. to other countries or regions in connection with storing and processing Personal Information, fulfilling your requests, and operating our Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.
When we transfer Personal Information outside of the EEA or Switzerland, we comply with applicable EU data protection laws. We may transfer your Personal Information to countries which provide an adequate level of protection under EU data protection laws, or we may use contractual protections for the transfer of Personal Information, such as the European Commission’s Standard Contractual Clauses. We may also rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area.
- The information on this website and any such information as may have been provided to you or made available by the Company in the UK (the “Information”) has not been approved by a person authorised under the Financial Services and Markets Act 2000 (“FSMA”) for the purposes of section 21 of FSMA (an “Authorised Person”). Accordingly, no person (other than an Authorised Person) may communicate this Information, or cause it to be so communicated in the United Kingdom (or, in the case of outgoing electronic communications, in the European Economic Area) except in the circumstances described in, and to persons who fall within, one of more of the exemptions contained in the FSMA (Financial Promotions) Order 2005, as amended from time to time (the “Financial Promotion Order”).
- In particular, this Information is directed only at:
- Investment Professionals: Persons with professional experience in matters relating to investments as described in article 19 of the Financial Promotion Order. Please see paragraph 5 for further details; and
- High net worth companies, unincorporated associations etc.: Persons of the kind described in article 49(2) of the Financial Promotion Order. Please see paragraph 6 for further details, (together “Eligible Recipients”).
- The Tokens described in the Information are only available to Eligible Recipients and will only be offered to Eligible Recipients. Persons who are not Eligible Recipients should not act or rely on the Information. Before your application is accepted the Company will ask you for supporting information confirming your status as an Eligible Recipient.
- If you do not fall within the meaning of an Eligible Recipient but consider you may be a certified sophisticated investor as described in article 50 of the Financial Promotion Order, we may consider marketing to you once you have demonstrated this status. Please contact IR@icash.io for more information. Potential investors who are uncertain of their status should refer to the relevant articles indicated in the Financial Promotion Order for their full terms and effect.
- Full details of persons who are investment professionals are set out within article 49 of the Financial Promotion Order, but generally include Authorised Persons, or businesses that are exempt from carrying on regulated activities. Where you are investing as an individual, you will not be an investment professional unless:
- your ordinary activities involve you carrying out buying, selling, subscribing for or underwriting securities for the purpose of a business carried on by you, or
- it is reasonable to expect you will carry on such activity for the purposes of a business carried on by you.
- Broadly speaking you will not be a high net worth company or unincorporated association unless you have £5 million of assets, or if you are a body corporate with more than 20 members, £500,000 of assets. Full details are set out in Article 49(2) of the Financial Promotion Order.
- The Information does not constitute a prospectus and accordingly has not been approved or prepared to the standards required by the EU Prospectus Regulation 2017.
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Hamilton HM 11 Bermuda