This Privacy Policy will explain how our Company uses the personal data we collect from you
when you use our website.
At Soken we highly prioritize protecting your personal information and being transparent about
what we do with it. We are committed to using your personal information following all
applicable laws concerning the protection of personal information and ensuring that you
understand your data rights and freedoms.
Soken will be considered as the "controllers" of your data. We determine which personal data we
need to process and for what purpose and are responsible for the safe storage and handling of this
data.
First, we need to define, and it is important for you to understand, the expression: "Personal
Data" (PD). It generically represents any kind of information about a physical person, whose
particularities can lead, directly or indirectly, to its identification. Here you have, by way of
example, but not limited to: name and surname, geographical address, any identification number,
political orientation, sexual orientation, email address, any location information and any other
online identifier such as the device used to access the Internet, IP address, or cookie information.
With regards of your agreement on collection and use of personal data, we have taken all the
necessary technical measures to provide you with this detailed agreement, so you can have a
crisp clear experience, from the first to the last interaction with our website or our services.
Visitors and Users agree and accept that the use of our website is not possible without any
indication of personal data.
With regards of your agreement on collection and use of personal data, we have taken all the
necessary technical measures to provide you with this detailed agreement, so you can have a
crisp clear experience, from the first to the last interaction with our website or our services.
Visitors and Users agree and accept that the use of our website is not possible without any
indication of personal data.
In your relationship with us through the website, controller, for the purposes of the General Data
Protection Regulation (GDPR), other data protection laws applicable in Member states of the
European Union and other provisions related to data protection, is: Soken LTD a company
incorporated in United Kingdom, with registered office 128 City Road, London, EC1V2NX.
This Policy does not apply to other companies’ or Companys’ websites to which we may link to
or may link to us. You should carefully review the privacy policies of those sites in order to
determine how they treat your personal information.
If you do not agree to this Privacy Policy, please exit, and do not access or use our website.
Our data protection policy should be legible and understandable for the general public, as well as
for our Users and business partners. To ensure this, we would like to first explain the
terminology used. In this data protection declaration, we use, inter alia, the following terms:
In these terms and conditions, the following definitions apply unless otherwise stated:
The processing of personal data will be in line with these main international legislations:
We are able to provide our services worldwide. For the purpose of avoiding any compliance conflict with any terminology used by any particular legislation, in this document: “Users” are the “data subjects” or the “data principals” and Soken is the “data controller” or “data fiduciary” Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.
You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with any applicable data protection law. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy
Please take a moment to understand which use case(s) set out in this Privacy Policy apply to you:
• Website Visitor
You are a “Website Visitor” by definition when you visit our website https://soken.io/ and any
other eventual subdomains associated with our principal domain. As a website visitor, we use
your navigation statistical information for our own purposes, primarily for improving the use of
our website and to provide you with more relevant content.
• User
You become a “User” if you submit an inquiry on our website/platform in order to benefit of our
services. If you are a User, our primary purpose of using your personal data is for providing the
products and services to you. We retain your personal information for a limited time and for
limited purposes, such as to make it easier for you to re-join our service in the future or to wish
you offers for services that we think you may be interested in.
Upon acquisition of our services, we may ask for your full name and a valid e-mail address,
which will be included in our mailing list, for future maintenance, updates, and eventual
marketing promotions. In addition, we will ask you to provide us with secure payment data,
which will be used for processing the order. This particular set of data will be legally processed
by our payment processor, and will not be stored by us.
We may process data about your use of our website and services ("usage data"). The usage data
may include your IP address, geographical location, browser type, and version, operating system,
referral source, length of visit, page views and website navigation paths, as well as information
about the timing, frequency and pattern of your service use. The source of the usage data is our
analytics tracking system. This usage data may be processed for the purposes of analyzing the
use of the website and services.
We may process your personal data that are provided in the course of provision of our services
("service data"). The service data may be processed for the purposes of providing our services,
ensuring the security of our website and services, maintaining back-ups of our databases and
communicating with you.
We may process information contained in any inquiry you submit to us regarding services and/or
services ("inquiry data"). The inquiry data may be processed for the purposes of providing our
services, ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you.
We may process information relating to our User relationships, including User contact
information ("User relationship data"). The User relationship data may include your name, your
employer, your job title or role, all your contact details, and information contained in
communications between us and you or your employer. The User relationship data may be
processed for the purposes of providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you.
We may process information relating to transactions, including purchases of services, that you
enter into with us and/or through our services ("transaction data"). The transaction data may
include your contact details and the transaction details. The transaction data may be processed
for the purposes of providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you.
We may process information contained in or relating to any communication that you send to us
("correspondence data"). The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate the metadata associated
with communications made using the website contact forms. The correspondence data may be
processed for the purposes of providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you.
“Automatically Collected" Information: The website collects a series of general data and
information when a data subject or automated system calls up the website. This general data and
information are stored in the server log files, and it is collected regardless of your quality:
Website Visitor or User
Collected may be:
• the ISP,
• the operating system used by the accessing system
• the website from which an accessing system reaches our website (so-called referrers)
• the sub-website
• the date and time of access to the website
• an Internet Protocol address (IP address)
• screen Resolution
• locale Preferences
• web page visited before you came to our website
• information you search for on our website
• date and time stamps associated with transactions
• system configuration information and other interactions with the website.
• social networking information (if we are provided with access to your account on social
network connection services);
• any other similar data and information that may be used in the event of attacks on our
information technology systems.
When using these general data and information, we do not draw any conclusions about the data
subject. Rather, this information is needed to:
• deliver the content of our website correctly;
• optimize the content of our website as well as its advertisement;
• ensure the long-term viability of our information technology systems and website
technology;
• provide law enforcement authorities with the information necessary for criminal
prosecution in case of a cyber-attack;
In addition to the specific purposes for which we may process your personal data set out in this
Section, we may also process any of your personal data where such processing is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Obviously, the access to our website for website visitors is free; however, we inform you that for
the use of the website via mobile device the charges and the standard tariffs provided in the
service contract that you have stipulated with them will still be applied by the telephone
operators
You directly provide Soken with most of the data collected. We collect data and process data when you avail our products and services.
Our commercial purpose, by reference to the subject matter of our business, is provision of cryptocurrency services. Reports in the financial domain and other complementary services, and the new rules of personal data protection (GDPR, CCPA, etc.) are part of this context.
To improve our services.
We always want to offer you the best online experience and for this we can collect and use
certain information about your behavior and preferences when using the website and platform, or
we can conduct market research directly or through partners.
To improve your marketing activity
We may want to keep you informed about the best offers for the services you may be interested
in. In this sense, we may send you any type of message (such as: email / SMS / phone / mobile
push / web push / etc.) containing general and thematic information about products or services,
information on offers or promotions, as well as other commercial communications.
To defend our legitimate interests
There may be situations in which we use or transmit information to protect our rights and our
commercial activity. These situations may include:
- measures to protect the website and platform Visitors and Users against cyber-attacks;
- measures to prevent and detect fraud attempts;
- transmission of information to the competent public authorities;
- other risk management measures.
We therefore commit ourselves:
- to protect the privacy of your data, which is a top priority for our company’s
management;
- to use this data for the sole purpose of providing you with a personalized experience
on our website as well as on the online platforms that we promote our products and
services (Facebook and Google, etc.).
Soken securely stores your data at third-party dedicated server located in Canada.
We do not use the information you provide to make any automated decisions that might affect
you.
Our legal basis for collecting and processing your personal data when you buy request our services is based on the necessity for the performance of a contract or to take steps to enter into a contract.
If you do not provide us with enough Personal Data, we may not be able to provide you with our services. However, you can access and use some parts of our website (not our platform) without giving us your Personal Data.
Soken would like to make sure you are fully aware of all of your data protection rights. Every
user is entitled to the following:
The right to be informed – You have the right to be informed about the personal data we collect
from you, and how we process it.
The right to access – You have the right to request Soken for copies of your personal data. We
may charge you a small fee for this service.
The right to rectification – You have the right to request that Soken correct any information you
believe is inaccurate. You also have the right to request Soken to complete the information you
believe is incomplete.
The right to erasure – You have the right to request that Soken erase your personal data, under
certain conditions.
The right to restrict processing – You have the right to request that Soken restrict the
processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Soken’s processing of your
personal data, under certain conditions.
The right to data portability – You have the right to request that Soken transfer the data that we
have collected to another Company, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of
these rights, please contact us
• Email us at: info@soken.io
We do not sell or rent your PD to third-parties for marketing purposes. You understand, and we undertake, that we will provide your PD through our platform strictly to the corporate stakeholders that are using our platform. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may provide your PD to third-party service providers we hire to provide services to us. These third-party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centres, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
We only retain the personal information collected from a User for as long as the User is active on
our platform, or otherwise for a limited period of time as long as we need it to fulfill the purposes
for which we have initially collected it, unless otherwise required by law. In some cases, it is not
possible for us to specify in advance the periods for which your personal data will be retained. In
such cases, we will determine the period of retention based on the 2-year criteria, after your
relationship with us ends.
We may retain your personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital interests
of another natural person.
Cookies are text files placed on your computer to collect standard Internet log information and
visitor behaviour information. When you visit our websites, we will collect information from you
automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
Soken uses cookies in a range of ways to improve your experience on our website, including:
• Keeping you signed in
• Understanding how you use our website
• To authenticate you
There are several different types of cookies, however, our website uses:
• Functionality – Soken uses these cookies so that we recognise you on our website and
remember your previously selected preferences. These could include what language you
prefer and the location you are in. A mix of first-party and third-party cookies are used.
Soken uses these cookies to collect information about your visit to our website, the
content you viewed, the links you followed, and information about your browser, device,
and your IP address.
• Strictly Necessary cookies– let you move around the website and use essential features
like secure areas. Without these cookies, we cannot provide the requested services.We use
these strictly necessary cookies to:
• Identify you as being logged in to the website and to authenticate you
• Make sure you connect to the right service on the website when we make any
changes to the way it works
• For security purposes
• 'Performance' cookies – collect information about how you use the website, e.g. which
pages you visit, and if you experience any errors. These cookies do not collect any
information that could identify you and are only used to help us improve how the website
works. We use performance cookies to:
• Help us improve the website by measuring any errors that occur
• Test different designs for the website
You can set your browser not to accept cookies, allaboutcookies.org tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
The Soken website/platform contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
In addition to the rights provided for above, if you are a California or US resident, you have the
right to request information from us regarding whether we share certain categories of your
personal information with third parties for the third parties' direct marketing purposes. To the
extent we share your personal information in this way, you may receive the following
information:
(a) the categories of information we disclosed to third parties for the third parties' direct
marketing purposes during the preceding calendar year; and
(b) the names and addresses of third parties that received such information, or if the nature of
their business cannot be determined from the name, then examples of the products or services
marketed.
Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”),
California residents have certain rights in relation to their personal information, subject to limited
exceptions. Any terms defined in the CCPA have the same meaning when used in this California
Privacy Rights section.
• For personal information collected by us during the preceding 12 months that is
not otherwise subject to an exception, California residents have the right to access
and delete their personal information. Soken will not discriminate against those
who exercise their rights. Specifically, if you exercise your rights, we will not
deny you services, charge you different prices for services or provide you a
different level or quality of services.
• To the extent we sell your personal information to third parties, you also have the
right to request that we disclose to you: (i) the categories of your personal
information that we sold, and (ii) the categories of third parties to whom your
personal information was sold. You have the right to direct us not to sell your
personal information. Soken does not sell your personal information in its
ordinary course of business and will never sell your personal information to third
parties without your explicit consent.
Should Soken engage in any of the activities listed in this section, your ability to exercise these
rights will be made available to you in your account settings. You can exercise your rights by
going contacting us via email so that we may consider your request.
If you are a US resident, you may designate an authorized agent to make a request to access or a
request to delete on your behalf. We will respond to your authorized agent's request if they
submit proof that they are registered with the California Secretary of State to be able to act on
your behalf, or submit evidence you have provided them with power of attorney pursuant to
California Probate Code section 4000 to 4465. We may deny requests from authorized agents
who do not submit proof that they have been authorized by you to act on their behalf, or are
unable to verify their identity.
PD that we collect from you may be stored, processed, and transferred between any of the countries in which we operate. The European Union and the UK has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and users, with your consent, your PD may be transferred outside the European Union to the United States and or other countries. We will use your PD to provide the services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights. Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our website, services, or products, you agree to the transfers of your PD described within this section.
Roles and Customer responsibility
Parties' Roles. To the extent that Soken processes Personal Data in the course of provision of
Services, it will do so as a Controller and in accordance with the requirements of the Service
Agreement.
Purpose Limitation. Soken will process the Personal Data only for the purpose of providing the
Services and in accordance with users’s lawful instructions.
Scope. Within the scope of this Covenant and in its use of the services, the Controller shall be
responsible for complying with the statutory requirements relating to data protection and privacy,
but not regarding the disclosure and transfer of Personal Data to other Processors. For the
avoidance of doubt, Controller’s instructions for the Processing of Personal Data shall comply
with the Data Protection Law, but subsequent Processors will bear direct responsibility towards
the user, with regards to the data privacy compliance. This Covenant is the user’s complete and
final instruction to Soken in relation to Personal Data and that additional instructions outside the
scope of this Covenant would require prior written agreement between the parties. Instructions
specified in this Covenant and may, from time to time thereafter, be amended, amplified or
replaced by Controller in separate written instructions (as individual instructions).
Compliance. Soken, as Controller, shall be responsible for ensuring that: a) it has complied, and
will continue to comply, with all applicable laws relating to privacy and data protection,
including EU Data Protection Legislation; and b) it has, and will continue to have, the right to
transfer, or provide access to, the Personal Data to other processors, for processing in accordance
with the terms of the Agreement and this Covenant.
We reserve the right to change this privacy notice at any time. If our company decides to change
this privacy notice, we will post those changes on our website so that our users and customers are
always aware of what information we collect, use, and disclose. If at any time we decide to
disclose or use your PD in a method different from that specified at the time it was collected, we
will provide advance notice by email (sent to the email address on file in your account).
Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy
notice in effect when the information was collected. In all cases, your continued use of our
website, services, and products after any change to this privacy notice will constitute your
acceptance of such change.
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