Effective Date 01.07.2019

Hypersphere OÜ, located in Estonia, 10152, Estonia, Tallinn, Vesivärava 50-201 is a provider of various services  (hereinafter, “Hypersphere”,  “we”, “us”). This Privacy Policy (hereinafter, “Privacy Policy”) and our Terms and Conditions (together referred to as “Agreement”) explain how we collect, use, disclose, transfer, store or otherwise process your personal information and tells you about your privacy rights and how the law protects you.

1. Privacy Policy

1.1. In order to become User, you should provide your personal data required for the Account registration or any other form solely determined by Hypersphere.

1.2. Personal data or personal information refers to any information, about an individual from which that person can be identified directly or indirectly (not including anonymous data).

1.3. Hypersphere understands that your privacy is important. Hypersphere is strongly committed to protect your privacy and the personal data that you may provide to us. Hypersphere commits to disclose your personal data only when it is required by Terms and Conditions or applicable law.

1.4. Information that you submit to Hypersphere in response to any email request for information or other outreach from Hypersphere, or through the Hypersphere employment application processes, will also be treated in accordance with this Privacy Policy.

1.5. Hypersphere may use your personal data for direct marketing purposes if you give your consent in the registration form. You can withdraw the above consent at any time by reaching us via email.

1.6. Hypersphere may, in its discretion, amend this Privacy Policy from time to time. Any material changes to Privacy Policy will be reflected on this page.

1.7. Only correct data should be provided in every required form and that afterward, when changing or adding any data at the Website, you will enter only correct data. You shall bear any losses that occur regarding the submission of invalid/incorrect data.

1.8. The Website and the App may contain links to external Sites, which are not governed by this Privacy Policy, and Hypersphere does not take responsibility for the Privacy Practices of any third-party Sites to which we link. We encourage you to review the Privacy Policies of such Sites before you submit information there.

2. Your data privacy with Hypersphere

2.1. We use the personal information you give us in various ways but primarily to allow us to provide you with the products and services you’d like to use as well as offer our support services. We do not sell or make available your data to any third parties for marketing, advertising or related purposes.

2.2. Depending on what services you want to use or products you want to buy or trade in we will ask you for various information. This could be your email address or contact number so we can communicate with you or be some form of proof of identity such as an ID (Identification Document) card, driving license or passport, and a photo. To help us get to know you as a customer and comply with applicable laws and regulations – such as anti-money laundering, fraud or sanctions – we may require a proof of address and when trading or investing, proof of banking details.

So the types of information we may collect and process are as follows:
– first and last name;
– address, postal code, city, country of residence;
– nationality;
– contact information, such as your email address and telephone number;
– copy of your ID together with metadata (e.g. document number,
document type, issue date, and expiration date).

We may also receive personal data about you from various third parties and public sources. For example, we may collect details about your transactions as published on blockchain networks, as well as any other information from providers of compliance, technical and payment services we may need to obtain in order to achieve the purposes of use set out in Section 3 below. However,
please note that we do not control how the third parties process your personal data.

2.3. We need and are permitted to have your information for three reasons – either because you have agreed to give it to us or to be able to provide our products and services to you, or because we are legally required to obtain it. In each case, we will only ask for, store and use information that we reasonably require and we will only hold on to if for as long as we need to or that the law requires us to do.

2.4. All our data and your information are held in secure servers. We do use a number of different operating systems that are subject to strict security measures and legal obligations.

2.5. We use a number of technical and procedural measures to ensure the safety of your data. Your personal data is primarily stored and processed inside the European Economic Area (EEA), but may also be transferred, processed and stored on servers located in countries outside the EEA in order to carry out the activities specified in this Privacy Policy. Your personal data can, therefore, be subject to privacy laws that are different from those in your country of residence. However, if we do transfer personal data collected within the EEA to third parties outside the EEA, such transfer will be based on the safeguards either of the standard contractual clauses issued by the EU Commission.

2.6. We may collect the email addresses at the point of subscription of users who wish to receive email notification of publications and press releases in identified subject areas of interest, and of those who send us email messages or express interest regarding our services or employment opportunities, or register for conferences and other UNIQUES-sponsored events. We will not, however, share any email addresses with any third party or send unsolicited email to any of the addresses we collect, except in very limited circumstances as set forth in this Privacy Policy.

2.7. We may also disclose certain personal data to our current or future affiliates, subsidiaries, and other related entities, as well as to our operational and business partners and sub-contractors when this is necessary for the performance and execution of any contract we enter into with them or you. We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

2.8. You have various rights such as the right to ask us what information we hold about you, ask us to correct or delete information about you or to restrict our use of it. You also have the right to request us to export or transfer data to other companies. And you have the right to complain about our use of your data and submit a complaint to the relevant data protection authority. You can reach us at any time via email.

2.9. If you opted in to receive information about our product, updates, and offers, we will use your name and email address to send this information to you. If you no longer wish to receive these communications, you can unsubscribe by following the instructions contained in the emails you receive or on our Website. Please note that we may send you transactional and relationship messages, even if you have unsubscribed from our marketing communications. For instance, if our service is going to be temporarily suspended for maintenance, we might send you an email to update you.

3. Cookie policy

3.1. Cookies are small files that contain data and are stored on your computer or mobile device. They contain information that lets the website you are accessing remember you on the site and know your preferences.

3.2. Like all websites and customer facing service providers nowadays we use cookies to make your use of the Website easier and offer you better user experience. For example, it allows to logon without having to re-enter the password. It also lets us understand what our customers are interested in and make improvements to our Website and the services we offer.

3.3. We use “Session Cookies”, “Persistent Cookies” and “Third Party Cookies” on our Website. Session Cookies are temporary files on your computer that allow a website to identify your actions and choices during a browsing session. They expire when you leave the site and close your web browser. Persistent Cookies are stored on your computer and remain there after you close your browser or switch off your computer. They are then used next time you log on to our Website to help us identify you and your preferences. Third Party Cookies let us connect with another provider, such as Google to provide links to functionality or analytics. We use Google Analytics for this purpose. The information generated by the cookie about your use of the site (including your IP address) is stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. If you do not wish to allow the use of Third Party Cookies you can erase or block them.

4. Compliance with law

4.1. Hypersphere complies with all applicable privacy laws and regulations. Hypersphere may be compelled to surrender personal or customer information to legal authorities without the consent of the user if demanded with a court, legal or administrative order, or as required or permitted by the laws, rules, and regulations of any nation, state, or other applicable jurisdictions. Also, in the event of a violation of the Terms and Conditions of use of the Website and the App or a violation of any restrictions on the use of materials provided in or through the Site, we may disclose personal user information to our affected business partners or legal authorities.

Your personal data is collected and processed in compliance with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR). We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

4.2. If you fail to provide personal data when requested, we will not be able to perform the contract we have or are trying to enter into with you.

4.3. You may access, correct, update, and/or delete, as the case may be, any personally identifiable information that you submit to Hypersphere through the Website or the App or through other means. To do so, please either follow instructions on the page on which you have provided such information or subscribed or registered or contact us.

4.4. We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  We limit access to your personal data to those employees and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. If you wish to get an explanation as to what is the purpose of processing your personal data, or how the processing for the new purpose is compatible with the original purpose, or what is our lawful basis to do so, please contact us via email.

4.5. Occasionally we may, in our discretion, make changes to Privacy Policy by posting a revised version and updating the Effective Date above. The revised version will be effective on the Effective Date listed. Except if and when such notice is required by law, we will do so without any notice to you. Where your explicit consent will not be needed, your continued access or use of our Website and/or services constitutes your acceptance of our latest Privacy Policy. Please, therefore, make sure you read any such notice carefully. If you disagree with our Privacy Policy and you do not wish to continue using the website and/or services under the new version of Privacy Policy, you must stop using our website and/or services.

4.6. Hypersphere  understands the importance of protecting children’s privacy, particularly in their online interactions. The Website and the App are not designed for and do not intentionally target or solicit to persons under 18 years of age.

It is important that you read this Privacy Policy together with our Terms and Conditions and any other privacy notice we may provide on specific occasions when we are collecting or processing data about you so that you are fully aware of how and why we are using your data.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS AGREEMENT AND UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN.