Privacy Policy
August 17, 2018, 2:43 PM UTC

This privacy policy applies between you, the User of this website http://initialindex.com/ (Website) and DAS Index Management Company LLC, that is the operator and the provider of this (Website) and the owner of the Website. As an operator, DAS Index Management Company LLC (Operator) takes the privacy of your information very seriously. This privacy policy applies to our use of all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

1.In this privacy policy, the following definitions are used:

Data

Collectively all information that you submit to the Operator via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws:

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below;

Data Protection Laws

any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR

the General Data Protection Regulation (EU) 2016/679;

DAS Index Management Company LLC

DAS Index Management Company LLC, a company incorporated in Cayman Islands  with registered number 335730 whose registered office is at 161 Shedden Road P.O Box 799 Grand Cayman, KY1-1103, Cayman Islands, Registered Office: Corporate Management Solutions (Cayman) Ltd. Two Artillery Court, 2nd Floor.

User or you

any third party that accesses the Website and is not either (i) employed by the Operator and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to the Operator and accessing the Website in connection with the provision of such services; and

Website

the website that you are currently using, http://initialindex.com/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. ACCEPTANCE OF PRIVACY POLICY

a.By accessing and using our services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Operator may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific services. These notices may supplement or clarify Operator’s privacy practices or may provide you with additional choices about how Operator’s processes your data.

b.If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our services.

c.CHANGES TO THIS PRIVACY POLICY

d.We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective.

e.OUR RELATIONSHIPS.

f. Operator is a limited company incorporated in Cayman Islands with company number 335730 and whose registered office Corporate Two Artillery Court, 2nd Floor, 161 Shedden Road P.O Box 799 Grand Cayman, KY1-1103, Cayman Islands.

The DAS Index Management Company LLC based in the Cayman Islands and handles  investments into the DAS indexes.

g.As data controllers, we determine the means and purposes of processing data in relation to e-wallet and cryptocurrency transactions. If you have any questions about your account, your personal information or this Privacy Policy, please direct your questions to privacy@initialindex.com.

PERSONAL INFORMATION COLLECTED

h.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.

i.For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our services, subscribe to marketing communications, request support, complete surveys, or sign up for a OPERATOR’S  event. 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 may collect the following types of information:

·     Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.

·     Formal Identification Information: Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.

·     Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.

·     Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.

·     Employment Information: Office location, job title, and/or description of role.

·     Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.

·     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. Please read our Cookie Policy for more information.

HOW YOUR PERSONAL INFORMATION IS USED

·     Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized 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:

·     To maintain legal and regulatory compliance

·     Some of our core services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, the Operator must identify and verify customers using our services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. When you seek permissions to raise Digital Currency buy and sell transactions associated with your OPERATOR’S Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the services in accordance with legal and regulatory requirements.

·     EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.

2.In Data that is collected automatically

3.To the extent that you access the Website, we will collect your Data automatically, for example:

a.we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b.we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

·       internal record keeping;

·       in each case, in accordance with this privacy policy.

·       We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

·       When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who we share Data with

4.We may share your Data with the following groups of people for the following reasons:

a.any of our group companies or affiliates - The information will be shared with KYC and AML providers, with banks lawyers, and Company registrations. ;

b.third party service providers who provide services to us which require the processing of personal data - In order to interact in with DAS indices;

c.relevant authorities - might be requested with applicable government authorities;

in each case, in accordance with this privacy policy.

Keeping Data secure

5.We will use technical and organizational measures to safeguard your Data, for example:

a.access to your account is controlled by a password and a user name that is unique to you.

b.we store your Data on secure servers.

c.payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

6.Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: artur@initialindex.com .

7.If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

8.Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or until you request that the Data be deleted.

9.Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

10.You have the following rights in relation to your Data:

a.Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b.Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

c.Right to erase - the right to request that we delete or remove your Data from our systems.

d.Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

e.Right to data portability - the right to request that we move, copy or transfer your Data.

f.Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

11.To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: artur@initialindex.com.

12.It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers outside the European Economic Area

13.Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

14.We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organization in receipt of the Data is based in the United States of America.

15.To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

16.This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Cookies

17.This Website may place and access certain Cookies on your computer. The Operator uses Cookies to improve your experience of using the Website and to improve our range of products and services. The Operator has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

18.All Cookies used by this Website are used in accordance with current International and EU Cookie Law.

19.Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling  the Operator to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

20.This Website may place the following Cookies:

Type of Cookie

Purpose

Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.


21.You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

22.You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.

23.It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

24.For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

25.You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

26.If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

27.Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

28.This Agreement will be governed by and interpreted according to the Cayman Islands Laws . All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Cayman Islands courts.

Changes to this privacy policy

29.DAS Index Management Company LLC reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact DAS Index Management Company LLC by email at artur@initialindex.com.

30 October 2018    

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