Privacy policy

1. GENERAL INFORMATION

HASHINGDNA.COM, property of BLOCKCHAIN ENKI, S.L. (hereinafter, "HASHINGDNA.COM") has established this Privacy Policy in order to inform users (hereinafter, "User" singular and "Users" plural) of the treatment and protection we apply to their personal data when they visit and use our website hashingdna.com, and at the address blockchain.icu (hereinafter, "Web/Platform") and/or the certification application (hereinafter, the “App”), and to demonstrate our ongoing commitment to the protection of privacy.

Personal data means any numerical, alphabetical, graphic, photographic, acoustic or any other type of information concerning identified or identifiable individuals.

The collection of personal data, their processing and subsequent use, are subject to the legislation in force in Spain on data protection, established by the Organic Law 15/1999, of 13 December, on the Protection of Personal Data (hereinafter LOPD), its implementing regulations or any other that may result from application, and the Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Regulation on Data Protection, hereinafter GDPR.

HASHINGDNA.COM will only be responsible for and ensure the confidentiality and security of the personal data collected from the User, or provided by the User through the Web/Platform and the App.

2. COMPLIANCE

In compliance with the duty of information set forth in Article 10 of Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce (hereinafter, LSSI), we inform you that the Web/Platform and the App are owned by the company BLOCKCHAIN ENKI, S.L., with the CIF number B67231225 and with registered office at Rambla d'ibéria 97 Sabadell (Spain) and registered in the Barcelona Commercial Registry, T 46444 , F 42, S 8, H B 520208, I/A 1. You can contact us at the following email address [email protected]

3. SECURITY MEASURES

Article 5.1.f of the GDPR determines the need to establish adequate security measures against unauthorized or unlawful processing, loss of personal data, destruction or accidental damage.

The security measures have been designed for low-risk processing of personal data, establishing the technical and organizational measures aimed at ensuring the integrity and confidentiality of personal data.

In order to provide a better service and ensure the security, confidentiality and integrity of the personal data collected, HASHINGDNA.COM has adopted all the necessary technical and organizational measures, and maintains the security levels of personal data protection in accordance with the LOPD, its implementing regulations and the GDPR, preventing their loss, alteration and/or access by unauthorized third parties. HASHINGDNA.COM undertakes to comply with the duty of secrecy and confidentiality regarding the personal data contained in the automated file in compliance with the applicable legislation.

Specifically, in accordance with current regulations, we inform you that HASHINGDNA.COM complies with basic level security measures. We use an encryption method to protect sensitive information. We also use Twilio Verify, a phone verification API that validates Users via SMS verification codes, provided by our partner Twilio (You can check out their Privacy Policy for more information).

We implement a variety of security measures to maintain the security of your personal information when you place an order or enter, submit, or access your personal information. Access to the Database is only possible from our own servers in United Kingdom and we make daily backups of the Database.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database (ING Virtual TPV and/or BitPay) only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. You can check out their Privacy Policy for more information: ING Privacy Policy and BitPay Privacy Policy.

After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.

4. UNAMBIGUOUS ACCEPTANCE FOR THE PROCESSING OF PERSONAL DATA

When you register on any of the existing forms on HASHINGDNA.COM we will inform you that we treat the information you provide us with in order to provide you with the service requested, to bill you for it, and to send you advertising related to our products and services by any means (postcard, email or telephone) and invite you to events organized by the company.

Also, the forms will ask for your express authorization to offer you products and services related to those requested and to build customer loyalty. If you choose the NO option, no advertising will be sent to you.

These forms shall also indicate that the data provided will be retained for as long as you do not request that the activity be discontinued and that the data will not be passed on to third parties, except where there is a legal obligation to do so.

Finally, in the forms you will find your right to obtain confirmation as to whether we at BLOCKCHAIN ENKI, S.L. are processing your personal data and therefore have the right to access your personal data, rectify inaccurate data or request their removal when the data is no longer necessary for the purposes for which they were collected.

All fields of the forms that are mandatory for the purpose intended, will be indicated as mandatory.

5. COLLECTION AND PROCESSING OF PERSONAL DATA

HASHINGDNA.COM collects the following personal data, provided by the Users of the Web/Platform and the App by email and/or through the completion of the forms enabled:

• Name and Surname

• E-mail Address

• Telephone

• Credit Card Information

• Invoicing Data (VAT number, Company name, direction and telephone number

• CV

Note: It is forbidden to submit any kind of information that discloses in the CV:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Union membership

• Genetic data

• Biometric data for the purpose of uniquely identifying an individual

• Data relating to health or sexual life and/or sexual orientation

For more information on other third-party registration forms we may use, you can visit the following links:

• Facebook Privacy Policy

• Google Privacy Policy

• Twitter Privacy Policy

HASHINGDNA.COM also collects other data/information automatically, such as, but not limited to, IP address, browser, type of mobile device, country of access, encrypted emails, cookie ID and advertisement ID.

All the data that the User provides in the informed sections of the Web/Platform and/or the App (collected by email and/or filling in the forms of the Web/Platform and/or the App), we will incorporate them into internal and automated files under the responsibility of HASHINGDNA.COM. Such data will be processed for the following purposes:

• Register as a Web/Platform and/or App User and/or to have CVs available for the selection of employees in present or future recruitment and selection procedures.

• Management, administration and control of the services and products contracted through the Web/Platform and/or the App (provide you with the services you have requested; reply to your communication; respond to your request for information; send you the necessary documentation or information requested).

• Personalize your experience (your information helps us to better respond to your individual needs).

• Improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).

• Improve our Web/Platform and App (we continually strive to improve our Web/Platform and App offerings based on the information and feedback we receive from you).

• Process transactions.

• Order processing (send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.).

• Administer a contest, promotion, survey or other site feature.

• Sending of commercial or promotional communications (in the event that the User expressly authorises it at the appropriate time), either from HASHINGDNA. or from third parties collaborating with HASHINGDNA.COM, related to the products and services offered on the Web/Platform and the App, by letter, telephone, e-mail, SMS/MMS, or by other equivalent electronic means of communication.

Your data may also be used for the segmentation of the same, as well as for statistics to know the traffic and use of the Web/Platform and the App by Users, such as the determination of their tastes and preferences, to send promotional information or advertising according to their interests.

Nevertheless, your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.

HASHINGDNA.COM allows registration on the Web/Platform and the App through synchronization with third party services (e.g. Log-In with Facebook, Google and Twitter accounts), using social media buttons and/or plugins on the Web/Platform and/or the App that allows you to connect with your Facebook, Google and Twitter accounts. For these to work, the Facebook, Google and Twitter accounts will set cookies through our Web/Platform and/or our App which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective Privacy and Cookies Policies (Facebook Privacy Policy and Cookie Policy, (Google Privacy Policy and Cookie Policy and Twitter Privacy Policy and Cookie Policy). HASHINGDNA.COM cannot ensure the identity of registered Users, therefore, it will not be responsible for the use of the identity of a registered User by unregistered third parties.

By registering, you are accepting the conditions described herein, as well as authorizing HASHINGDNA.COM and associated companies, to send you by e-mail or any other means, advertising, communications and/or any other type of notification that HASHINGDNA.COM deems appropriate.

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

6. SOCIAL NETWORKING POLICY

HASHINGDNA.COM has a corporate profile and uses the social networks Facebook, Twitter, LinkedIn, Google+ and Instagram. Under the provisions of the regulations on the Protection of Personal Data, HASHINGDNA.COM is "Responsible for the processing of your data" for the reason of the existence of such profiles on social networks and the fact that you follow us and we can follow you.

If you join our corporate profile as a follower or give a "Like" to our content or profile, you agree to this policy, where we explain what data we collect, for what purpose and for how long.

As data controllers, we ensure confidentiality in the processing of your data and compliance with your rights, under the provisions of the above-mentioned regulations.

We inform you that we use social networks to advertise relevant information related to the services we offer, or on topics that we consider of interest to you. Using the functionalities of these platforms, you may receive news with this type of information on your profile.

We hereby inform you that there is no link between HASHINGDNA.COM and these platforms or social networks, therefore you agree to be bound by their terms and conditions of use once you access them and/or accept their warnings during the registration process. HASHINGDNA.COM will not be liable for the use or processing of your data outside the strict relationship and services indicated in this Privacy Policy.

For more information on the Privacy Policies of the social networks we may use, you can visit the following links:

• Facebook Privacy Policy

• Google Privacy Policy

• Twitter Privacy Policy

• LinkedIn Privacy Policy

• Instagram Privacy Policy

7. TRANSFER OF PERSONAL DATA

Your data will not be disclosed to third parties except where there is a legal obligation to do so.

HASINGDNA.COM does not sell, trade, or otherwise transfer your personal data to third parties. However, the User expressly consents that all the data provided in the informed sections of the Web/Platform and/or the App (collected by e-mail and/or filling in the forms on the Web/Platform and/or the App) may be communicated and accessed by employees of HASINGDNA.COM, associated companies and/or external collaborators, for the purpose of management, administration and control of the services and products contracted through the Web/Platform and/or the App, meaning trusted third parties who assist us in operating our Web/Platform and App, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

We may also release your personal information when we believe release is appropriate to comply with the law, enforce our site policies, protect our own and third-party rights, or for security reasons. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Nevertheless, HASINGDNA.COM ensures the safeguard of the confidentiality and security of the personal data at all times, having adopted the legally required security measures, which allow us to reasonably ensure the protection of your personal data and prevent the loss, misuse, alteration, processing or unauthorized access of them.

Likewise, notwithstanding the above, by accepting this Privacy Policy, the User expressly consents that the personal data that he/she provides us with may be transferred, when required, to associated companies for the provision of the services that the User may have requested.

8. RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OBJECTION

• Access: Through the exercise of this right, you can find out which of your personal data is being processed by BLOCKCHAIN ENKI, S.L.; its purpose, origin or possible transfer to third parties.

• Rectification: It consists of the possibility of modifying your personal data which is inaccurate or incomplete, and you must specify in the application which data you wish to be modified.

• Cancellation: It allows the cancellation of your personal data for inappropriate or excessive.

• Objection: With the right to object, you may object to the processing of your data in cases such as: advertising and commercial prospecting activities or when the purpose of such processing is the adoption of a decision concerning you based solely on automated processing of your personal data.

The User may exercise his or her rights of access, rectification, cancellation and opposition, as well as his or her rights of limitation and portability, by sending a written communication to the address Rambla d'ibéria 97 Sabadell (Spain), or by sending a copy of his or her national identity card or passport to [email protected]

• Such communication shall contain the following information:

• Name and surname of the User.

• Petition in which the request is based.

• Address for notification purposes, date and User's signature.

• Documents certifying the request made, if applicable.

HASINGDNA.COM informs Users that the exercise of these rights is very personal, so that only the User himself may exercise these rights with respect to the personal data of which he is the legitimate owner. Nevertheless, and in the cases in which it is exceptionally admitted, the legal representative of the User may exercise the rights of the User in the terms set out above, provided that he accompanies the aforementioned communication with the document certifying such representation.

By providing their personal data, the User states and ensures that they are accurate, complete, truthful and up to date, leaving HASINGDNA.COM free from any liability that may arise as a result of the breach of such obligation.

If the User is a minor or incapable, HASINGDNA.COM warns of the need to have the consent of their parents, guardians or legal representatives for the communication of their personal data, so HASINGDNA.COM forbids a minor or incapable to provide their data or use the Web/Platform and/or the App if he/she does not have the consent of their parents, guardians or legal representatives, not being otherwise HASINGDNA.COM responsible for the actions of the minor or incapable.

Except in the fields in which it is expressly determined otherwise, the answers to the questions on personal data are voluntary, without the lack of an answer to such questions implying a decrease in the quality of the services you request. Failure to fill in the fields identified as mandatory or the provision of incorrect data will make it impossible for HASINGDNA.COM to provide the services requested.

Also, in the search for total transparency in its relationship with the User, HASINGDNA.COM informs you of the use of other computer mechanisms related to personal data, such as cookies and logs on this Web/Platform and the App.

Cookies are a message sent by the server to the User's computer, consisting of text files that are stored in the computer's memory and collect information regarding the pages visited, the time of Internet connection, etc. Cookies are sent back to the server each time the User enters that page. This Web/Platform will adapt the information managed and its purpose to the provisions of article 22 of the LSSI 34/2002, in accordance with RDL 13/2012, of 30 March.

The purpose of HASINGDNA.COM's cookies is to personalize the services we offer, providing you with information that may be of interest to you. If you do not want a cookie to be installed on your hard drive, you can set your computer's browser not to receive them. However, we would like to point out that, in any case, the quality of the Web/Platform and the App operation may decrease.

Cookies are only associated with an anonymous User and his or her computer, and do not by themselves provide the personal data of the customer, nor can they read data from his or her hard drive, nor read cookie files created by other providers. You can find more information about the cookies we use, their purpose and other information of interest at the following link: Cookies Policy.

Logs are files stored on the HASINGDNA.COM's server that record data about your browsing and whose main purpose is to gather information about the operations carried out by you. They also allow us to continue providing you with the services you request, to better understand your preferences and to offer you other services that may suit your tastes. They also help us to analyze the functioning of the system, locate incidents and problems that may arise, and resolve them as quickly as possible.

9. RIGHTS OF RESTRICTION OF PROCESSING, ERASURE AND DATA PORTABILITY

The User also has a right to limit/restrict the processing of personal data, a right to delete/erase and a right to transfer personal data provided to the data controller.

• Restriction of Processing: You shall have the right to obtain from the data controller restriction of processing. For example, when the data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

• Erasure (“right to be forgotten”): You may request the erasure of personal data without delay in the event of any of the cases referred to above. For example, unlawful processing of data, or when the purpose for which the data was processed or collected has ceased to exist.

• Data Portability: You will be able to receive your personal data in a structured format, of common use and mechanical reading, and to be able to forward it to another person in charge, whenever it is technically possible.

HASINGDNA.COM informs that it will treat the data in a lawful, fair, transparent, adequate, relevant, limited, accurate and up-to-date manner. That is why HASINGDNA.COM commits itself to take all reasonable steps to ensure that these are deleted or rectified without delay if they are inaccurate.

10. DURATION OF THE STORAGE OF THE DATA

In compliance with current legislation, HASINGDNA.COM informs that the data will be kept for the period of time strictly necessary to comply with the above-mentioned provisions, for as long as the business relationship is ongoing, or for as long as it is necessary to comply with legal obligations.

Unless you inform us otherwise, we will understand that your data has not been modified, that you agree to notify us of any changes and that we have your consent to use your data for the purposes mentioned above.

For the case of resumes received by the company, we will keep the data for a maximum period of one year from the beginning of the processing.

11. THIRD PARTY LINKS

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

12. SUGGESTIONS TO USERS

HASHINGDNA.COM advises Users to use the latest versions of the software, given the integration of greater security measures.

HASHINGDNA.COM also advises Users to use the security mechanisms available to them (secure Web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data as necessary.

HASHINGDNA.COM reminds Users that the Internet is not always safe and they must take the necessary and appropriate technical measures to prevent unauthorized processing of their data.

13. MODIFICATIONS AND UPDATES

HASHINGDNA.COM reserves the right to review this Privacy Policy and the possibility of modifying this Privacy Policy to adapt it to the applicable legislation and case-law, or to the criteria or guidelines issued by the Spanish Data Protection Agency. In this case, the Users will be informed. All of this, notwithstanding the fact that Users must regularly check the content of this Privacy Policy.

This Privacy Policy may also be amended by any other general clauses or conditions of access to certain services, in the event that such access involves a specific area of expertise in the protection of personal data. In any case, these special features will not be applicable to your personal data as long as the User does not accept the above clauses or statements.

14. SUPPORT

If you have any questions or concerns regarding our Privacy Policy, please email us at [email protected], we will be happy to assist you.

NOTE: All the above is reported to you in compliance with the regulations of the General Data Protection Regulation (GDPR) of the European Union and the Personal Data Protection Act (LOPD), as well as the Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce (LSSI).