1.1 This Privacy Statement ("Statement") sets out the basis on which Sarl Ransoft trading as NFTON ("we", "our", "us" or " NFTON") of 20, AV. De Fontvieille C/o Sam Mimusa – Le Coronado 98000 Monaco, uses any personal data detailed below ("Personal Data") we collect from you or that you provide to us. The information provided by you will be held by us as a data controller.
1.2 This Statement (together with our terms of use as set out at https://nfton.market/terms-of-services, the "Terms") and any additional terms of use incorporated by reference into the Terms, applies to your use of the Platform (the "Platform") once you connect your wallet to access the Platform.
1.3 Capitalised and undefined terms in this Statement cross refer and draw their meaning form the Terms.
1.4 We may collect and process the following data about you:
| Information you give us |
|
| Device Information | If you use the Platform on your mobile device, we may collect your phone number and the unique device id number. |
| Log Information | Details of your use of the Platform including, but not limited to, traffic data, weblogs, analytical SDKs and other communication data and the resources that you access. |
| Location Information | We collect data indicating your location while you are using the Platform. |
| Information we receive from other sources | We are working closely with third parties (including, for example, MetaMask, Coinbase, the Ethereum network, analytics providers, search information providers, social media platforms such as Facebook, Instagram, Google+ and Twitter) and may receive information about you from them. We will update this Statement when we receive information about you from them and the purposes for which we intend to use that information. |
2.1 The following table details how ("Legal Basis") and why ("Purposes") we process your Personal Data:
| LEGAL BASES AND PURPOSES | ||
|---|---|---|
| Legal Basis | Purpose(s) | Personal Data Processed |
| Contract It is necessary to process this Personal Data to enter into and perform our contract with you regarding your use of the Platform as set out in the Terms of Service. | Access to the Platform To provide you with access to the Platform and to enable you to use the Platform including engaging in transactions for the purchase/sale of NFTs. | Account Information (i.e. Third-Party Extension wallet address) and username if appropriate. |
| Legitimate Interests We process certain of your Personal Data in pursuit of purposes which are within our legitimate interests. Before we process your Personal Data in pursuit of such legitimate interests, we determine whether such processing is necessary to achieve these objectives and we carefully consider the impact of such processing on your fundamental rights and freedoms. We only proceed with such processing when we have decided that, on balance, the legitimate interests we are pursuing are not outweighed by any adverse impact on your rights and freedoms. | Improving Platform Functionality and Efficiency To provide, improve, test and monitor the effectiveness of the Platform. To monitor metrics such as total number of visitors, traffic data and demographic patterns. Responding to Queries and Complaints To process and respond to any queries or complaints you submit to us. User Profiling To build up a profile of you as a user to assess credentials for acceptance onto the approved user programme. Advertising and Marketing To provide you with advertising and marketing material from ourselves and our third-party partners. | Account Information Device Information Query and Complaint Information Comment and Community Information Third Party Information |
| Compliance with a Legal Obligation We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject. | To comply with our obligations under consumer and applicable laws. | Account Information Device Information Query and Complaint Information Comment and Community Information Third Party Information |
| To Defend, Establish or be a Party to Legal Claims We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party. | To file legal proceedings. To investigate, establish, exercise or defend a legal claim. To settle legal claims. | Account Information Device Information Query and Complaint Information Comment and Community Information Third Party Information |
3.1 We may disclose your Personal Data to some or all of the following recipients:
| RECIPIENT(S) |
|---|
|
4.1 Your Personal Data will be stored and transferred outside the European Economic Area ("EEA"). We only transfer your Personal Data outside the EEA where the European Commission has decided that the third country in question ensures an adequate level of data protection in line with EU standards (i.e. that an adequacy decision has been granted in the country's favour) or there are appropriate safeguards in place to protect your Personal Data. Your personal data may be transferred to India for the purposes of information technology maintenance and support. Further, your personal data may be entered onto the Ethereum mainnet at which point that personal data will be sent immediately to several jurisdictions which may not all be traceable for the purposes of verification on the Ethereum mainnet. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us by filling in the webform at the following address: https://nfton.market/contact-us.
4.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to or from the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5.1 The Website contains links to other websites ("Linked Websites"). We are not responsible for the privacy statements or practices on Linked Websites. This Notice governs only information collected on the Website. When accessing Linked Websites, you should read the privacy statement published on the relevant Linked Website. The terms of our Notice do not apply to Linked Websites. Please check the statements on those Websites before you submit any Personal Data to Linked Websites.
5.2 The Website contains links to other websites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered into with any third party on or through a Linked Website. We have no control over the content of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.
6.1 In general, we expect to keep your Personal Data for as long as is necessary for the purposes for which it was collected. However, please note that in certain circumstances we may hold certain of your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data. The criteria we will use to determine the period for which we will hold your personal data include: (a) the length of our relationship with you; (b) whether we are under a legal obligation under Irish or European Union law which requires the retention of your Personal Data; (c) whether the retention of your Personal Data is required in light of our legal position.
6.2 A Users data, and personal data if applicable, may be stored on the Ethereum blockchain indefinitely. The Company does not control this data. Similarly, royalties on sales of Collectibles may still accrue and become payable to a user on account closure.
You have a number of rights in relation to your Personal Data as set out in the table below.
Note that in certain circumstances these rights might not be absolute.
| Right | Further Information |
|---|---|
| Right of Access | You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will charge you for making such an access request where we feel your request is unjustified or excessive. |
| Right to Rectification | You have the right to have any outdated or inaccurate Personal Data which we hold about you updated or corrected. |
| Right to Erasure | In certain circumstances, you may also have your Personal Data deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes set out in this Notice. |
| Right to Restriction of Processing | You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or that our use of your Personal Data is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved. |
| Right to Data Portability | You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where we process your Personal Data on the legal bases of your consent or where it is necessary to perform our contract with you. |
| Right to Object | You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests. |
7.1 You can seek to exercise any of these rights by filling in the webform at the following address: https://nfton.market/contact-us.
7.2 We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises.
7.3 Our lead regulatory Authority is the Irish Data Protection Commission which is based in Ireland. You have the right to lodge a complaint with the Irish Data Protection Commission with regards to us processing your Personal Data. You can contact the Data Protection Commission as follows:
| Data Protection Commission 21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland | Phone: Email: | +353 57 868 4800 +353 761 104 800 info@dataprotection.ie |
8.1 Children under the age of 16 should not use the Platform and must not attempt to sign-up to the Platform and/or submit any personal information to us. We do not knowingly collect personal information from any person who is under the age of 16 or allow them to register. If it comes to our attention that we have collected Personal Data from a person under the age of 16, we will delete this information as soon as reasonably possible. If you have reason to believe that this has occurred, please fill in the webform at the following address: https://nfton.market/contact-us.
9.1 We may amend this Statement on occasion, in whole or part, at our sole discretion. Any changes will be posted on this page which will be kept up to date. Please check this policy regularly for changes.
9.2 If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Statement, or otherwise disclosed to you at the time it was collected, we will change this policy, and you will have a choice as to whether or not we use your Personal Data in the new manner.
10.1 Questions, comments and requests regarding this Statement are welcomed and should be addressed to the webform at the following address: https://nfton.market/contact-us.