Block Technologies Privacy Policy
Last updated: October 30, 2023
Please note that this privacy policy will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
This Privacy Policy describes how Block Technologies (“we”,“us”, “our”, “ourselves”) collects and processes your personal information (“you”, “your”) through the Block Technologies websites and applications that reference this Privacy Policy. By using the services provided by Block Technologies (“Block Technologies Services”), you are consenting to the collection, storage, processing, and transfer of your personal information as described in this Privacy Policy.
Block Technologies Pte. Ltd. a company registered under the number 202126753E, at BUGIS JUNCTION TOWERS, 230 VICTORIA STREET, #15-01/08, 188024 SINGAPORE is a data processor for personal information collected and processed in connection with the provision of the Block Technologies Services.
1. What personal information does Block Technologies collect? Why does Block Technologies process my personal information? What is the legal basis for the processing activities?
| What information and personal data does Block Technologies collect and process? | Why does Block Technologies process my personal information? | Legal Basis for our use of personal information (EU and UK GDPR) |
|---|---|---|
| Information related to company Directors, UBOs and Authorised persons, including: - Email address - Name - Gender - Date of birth - Home address - Phone number - Nationality - Device ID - A video recording | - Communicate with you: We use your personal information to communicate with you in relation to Block Technologies Services. - We collect and process identity information and Sensitive Personal Data (as detailed in section 1) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations | Performance of a contract when we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. |
| - The Internet protocol (IP) address used to connect your computer to the Internet - Login, e-mail address, password and location of your device or computer - Block Technologies metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences) - Version and time zone settings | - Provide, troubleshoot, and improve Block Technologies Services : We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of Block Technologies Services | Our legitimate interests to ensure the proper functioning of our business operations. Legal requirements that we need to comply with concerning identifying customers, preventing fraud and/or abuse and avoiding non-compliance. |
| - Transaction history - Information from other sources: we may receive information about you from other sources, such as credit history information from credit bureaus | Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, Block Technologies Services and others. We may also use scoring methods to assess and manage credit risks.. | Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others. |
We firmly believe that where the above table states that we rely on our legitimate interests for a given purpose, this is not overridden by your interests, rights or freedoms. Therefore, If you wish to obtain further information on this balancing test approach, please contact dpo@blockcustody.com.
We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (for example, in case of a medical emergency) to do so.
Sensitive Data
The term “sensitive data” refers to the various categories of personal data identified by data privacy laws or regulations as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or generic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
Due to the type of services provided we might need to process certain types of sensitive data. In the limited cases where we do collect such data, we will do this in accordance with data privacy laws and regulations and/or ask for your consent.
2. Does Block Technologies share My Personal Information?
Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. Block Technologies shares users' personal information and Sensitive Personal Data for the Block Technologies services only as described below and with the subsidiaries or affiliates of Block Technologies that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.
Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and performing identity verification and other KYC functions. These third-party service providers have access to personal information and Sensitive Personal Data needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Policy and as only permitted by applicable data protection laws.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy . Also, in the unlikely event that Block Technologies or substantially all of its assets are acquired, user information will be one of the transferred assets.
Protection of Block Technologies and others: We release accounts and other personal information when we believe such release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Block Technologies, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction, and with regulatory agencies and law enforcement to comply with lawful requests.
3. International transfers of personal data
Block Technologies Services may transfer your data outside of the European Economic Area (“EEA”). Block Technologies puts in place suitable safeguards to ensure that such transfers are carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection.
Where Block Technologies transfers personal data to affiliates or service providers, Block Technologies relies on the latest standard contractual clauses of the European Commission.
4. How Secure is My Information?
We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you.
It is important for you to protect against unauthorized access to your account password. We recommend using a unique password for your Block Technologies account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer.
5. What Information Can I Access?
You can access your information, including your name, address, payment options, profile information, and transaction history by contacting us at dpo@blockcustody.com.
7. What Rights Do I Have?
If you have any questions or objections as to how we collect and process your personal information, please contact dpo@blockcustody.com.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose.
In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact dpo@blockcustody.com.
8. How Long Does Block Technologies Keep My Personal Information?
We keep your personal information to enable your continued use of Block Technologies Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. Additionally, identity information and Sensitive Personal Data may be retained for eight years to comply with Anti-Money Laundering laws.
8. Contact Information
Our data protection officer can be contacted at dpo@blockcustody.com, and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.
9. Conditions of Use, Notices and Revisions
If you choose to use Block Technologies Services, your use and any dispute over privacy is subject to this Privacy Policy and our Terms of Use. If you have any concerns about privacy at Block Technologies, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
Our business changes constantly, and our Privacy Policy will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing Block Technologies Services immediately. When an updated version of the Privacy Policy is released, your continued access to Block Technologies Services means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.