Snow White Holding AG
Managing Director: John Michael Burns
Registered office: Zug, Switzerland
Legal form: Aktiengesellschaft
Companies Register No: Handelsregisteramt des Kantons Zug, record CH-170.3.045.359-1
Last updated: April 23, 2019
BlockState AG is a private limited company incorporated in Switzerland with company number CHE-301.798.106 and whose registered office is Baarerstrasse 10 in 6300 Zug Switzerland. BlockState is the name of the brand. BlockState AG is the legal entity that is the sole owner of BlockState brand and all its intellectual property.
We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.
For example, we collect personal information which is required under the law to open an ac- count, or add a payment method. We also collect personal information when you use or re- quest information about our Services, subscribe to marketing communications, request sup- port, complete surveys, or sign up for a BlockState events. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Policy.
We collect the following types of information:
Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, financial information, online identifiers, and/or usage data in certain ways.
BlockState handles very sensitive information, such as your payment information, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we can- not perform our Services in accordance with our terms.
We process your personal information in order to provide the Services to you.
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
We process your personal information for quality control and staff training tomake sure we continue to provide you with accurate information. If we do not process per- sonal information for quality control purposes, you may experience issues on the Ser- vices such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to com- ply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
We process your personal information to better understand the way you use and inter- act with BlockState’s Services. In addition, we use such information to customise, measure, and improve BlockState’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.
We process your personal information to provide a personalised experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate trans- actions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.
Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Services and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or BlockState Services may not be available to you.
We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hard- ware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activityandhardwaresettings,browsertype,browserlanguage,thedateandtimeofyourrequest and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted withourwebsite,includingpagesaccessedandlinksclicked.Wemayuseidentifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third party site.
We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. BlockState will never sell or rent your personal information. We will only share your information inthe following circumstances:
We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.
If you establish a BlockState Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a BlockState website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.
Please note that merchants you interact with may have their own privacy policies, and BlockState is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those thirdparties.
If you authorise one or more third-party applications to access your BlockState Account, then information you have provided to BlockState may be shared with those third parties. Unless you provide further authorisation, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using BlockState Services.
We understand how important your privacy is, which is why BlockState maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safe- guards to protect the security and confidentiality of the personal information you entrust to us.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the Switzerland and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to BlockState staff.
However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
We store your personal information securely throughout the life of your BlockState Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, BlockState will require the user to close his or her account and will not allow the user to continue using the Services of BlockState. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
While BlockState AG is based in Switzerland (which is not within the EEA), our service providers may store, transfer, and otherwise process your personal informationin countries outside of the country of your residence, including the United States, the Philippines, and possibly other countries. We use approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland, or require that any third party located in the U.S. receiving your personal information is certified under the E.U.-U.S. and/or the Swiss-U.S. Privacy Shield Frameworks and require that the third party agree to at least the same level of privacy safeguards as required under applicable data protection laws.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please contact us at [email protected]
If you are a resident of the EEA, BlockState is a controller with respect to your personal information.
Our legal bases for processing under EEA Data Protection Law are described above in the sections entitled “How Your Information Is Used” and “Information From Third Party Partners.” We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of BlockState, our customers or others.
If you are a current customer residing in the EEA, we will only contact you by electronic means (email or SMS) with information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.
If you are a new customer and located in the EEA, we will contact you if you are located in the EU by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to use your personal information in this way, or to pass your personal information on to third parties for marketing purposes, please go to the Privacy Rights Dashboard in your account to opt-out or contact us at [email protected] You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services
EEA Residents have the following rights, which can be exercised by going to your Privacy Rights Dashboard or contacting us at [email protected] so that we may consider your request under applicable law.
Our Privacy Rights Dashboard allows you to set your communication preferences and make individual rights requests relating to your personal information. We encourage you to make any individual rights requests through the Privacy Rights Dashboard because it ensures that you have been authenticated already. Otherwise, when we receive an individual rights request via email we may take steps to verify your identity before complying with the request to protect your privacy and security.
(b) The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
(d) You have objected to processing, pending the verification whether the legitimate grounds of BlockState’s processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
3003 Bern, Switzerland
You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place. In Switzerland, the relevant data protection authority is the Eidgenössischer Datenschutz- und Oeffentlichkeitsbeauftragter (EDÖB).
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter