NRG TOKENS SALE PRIVACY POLICY
Last updated:15.12.2020
This Privacy Policy (the «Policy») defines how NeuroG Ltd, a company incorporated in the Republic of Seychelles with Company Number 225020 (registration address Suite 1, Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles) (hereinafter referred as "Neurogress", "Company," "we," "us") the owner of the website available on the Internet via https://Neurogress.com (hereinafter – the "Site"). Before you start using the Site, please read the Privacy Policy carefully. Using any functions, services and Site features, including just browsing, you (the Visitor / User), regardless of registration and participation in Stake Program, declare that you have read, understood and agreed to abide by Privacy Policy conditions, including any mentioned therein special conditions and rules without any exceptions and reservations. This Privacy Policy forms part of the General Terms & Conditions of Neurogress Services. In cases not regulated by this Policy, the General Terms & Conditions of Neurogress Services shall apply to the relationships that arise hereunder.
If you have any questions, please contact: [email protected]
It is presumed that by the fact of the Site use and participation in Stake Program or by providing Neurogress the Personal Data directly on its request, the User has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should refrain from using the Site and/or participation in Stake Program.
Throughout this Policy, Neurogress use the term "Personal Data" to describe information that can be associated with a specific person (the "User") and can be used to identify that person (including the information about the User's activities, such as information about your use of the Site, when directly linked to personally identifiable information, including automatically collected). Neurogress does not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.
This Policy is an integral part of General Terms & Conditions of Neurogress Services. The definitions set forth herein and mentioned with capital letter shall have the meaning as described in General Terms & Conditions of Neurogress Services.
The purpose of Personal Data collection, storage and processing within the Neurogress projects shall only be the identification of the Stake Program Users.
1. Technical Data Collection
Neurogress collect Technical Data from your usage the Site and Personal Data, provided to Neurogress by you. When the User visit the Site or use our Program, Neurogress collects the Personal Data sent to Neurogress by your computer, mobile phone, or other access device.
This Technical Data includes:
If the User want to participate in Stake Program, Neurogress may collect and store the following types of Personal Data about the User:
In certain cases (when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or "Know-Your-Customer" (KYC) policies) Neurogress may require you to provide additional information, and namely:
4. Direct Marketing
We can also use your e-mail for sending some marketing materials. Subscription to our marketing mailing is entirely voluntary and requires a proactive action including expressed consent on the part of the individual. We include an unsubscribe link in all electronic messages we send you. You may withdraw your consent to receiving these at any time. Should you do so, we will update our database and will not send your further messages of this nature. We may continue to contact you to the extend necessary for the purposes of any other Services you have requested.
5. Grounds for Processing Personal Data
The Company may process the User's Personal Data if there are one or more of the following reasons:
a. The performance of the contract (General Terms & Conditions of Neurogress Services);
b. Personal identification;
c. Legitimate interest and compliance with legal regulations;
d. Consent.
6. Cookies Use
When the User access the Site or use Neurogress Services Neurogress (or Google Analytics or similar service provider on our behalf) may place small data files called "cookies" on the User's computer or other device. You may control the use of cookies within your internet browsers' settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Site and Services may be partly not available.
Cookies are small files that are stored on the hard drive of Users. A cookie file is stored in web browser and allows the Site or third parties to recognize User and make it easier to use the Site while subsequent visits. These cookies allow the Company to track the usage of the Site and its functions. Using them allows us to better and more effectively serve Users and personalize the Site for a specific User.
The Company may use cookies to recognize repeated User visits, the type of content viewed and other sites to which the User was redirected from the Site, the time when each page and section of the Site was opened, and the functions used. All Personal Data that may be contained in cookies are processed based on the consent of the relevant subject in accordance with the Privacy Policy.
We use both persistent and session cookies, as well as their varieties for the operation of the Site.
7. Personal Data Transfer
Neurogress is the only data controller and processor, except for the cases when there is an objective Neurogress need to control/process or store Personal Data at Neurogress' counterparties or agents. Should such counterparty or agent be engaged by the Neurogress, Neurogress shall notify you in advance. Neurogress may transfer Users Personal Data to the following persons:
a. contractors who interact with the Company's token sales process;
b. contractors of the Company for Site operation and maintenance (including identification service providers for fraud prevention purposes);
c. government agencies and / or law enforcement officials, if required for the above purposes, if required by law or required for the legal protection of their own legitimate interests in accordance with applicable law.
Sharing will be carried out for the purposes set out above, or in accordance with specific legal regulations governing the Processing procedure.
8. User's Rights
8.1 Right of access. You have the right to obtain from the controller confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the processing; the categories of Personal Data concerned; the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Personal Data or restriction of processing of Personal Data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer.
The Company will also provide a copy of the Personal Data undergoing processing if requested. For any further copies requested by the data subject, the Company may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form.
8.2 Right to rectification. You have the right to have inaccurate Personal Data rectified or completed if it is incomplete under request for rectification made verbally or in writing. The Company has one calendar month to respond to a request.
8.3 Right to erasure ('right to be forgotten'). The User has the right to require Neurogress to delete Personal Data provided by the User to Neurogress or revoke his (or her) consent for collection, processing and storage of his (or her) Personal Data by Neurogress at any time. If you decide to do this, you should send the respective notification to the Neurogress. Neurogress shall delete Your respective Personal Data from any sources within 1 month from the moment Neurogress receive such request from you.
8.4 Right to object You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you. We will no longer process your Personal Data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where your Personal Data are processed for direct marketing purposes, you may also object at any time to processing of your Personal Data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
9. Personal Data Safeguarding
We take the privacy and security of your Personal Data very seriously. We have implemented technical and organizational security measures designed to ensure that data protection is integral to all processing activities and to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and any other unlawful or unauthorized forms of processing in accordance with applicable law.
We do not disclose this information to third parties except with your consent, in accordance with the provisions of this Policy, or if we believe that such disclosure is necessary (if there is a legitimate purpose: for example, in the event of a threat against you or others) in accordance with applicable law.
Neurogress protects your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards Neurogress use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Neurogress also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, Neurogress will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
10. Personal Data Storage
10.1 Territory. We store your information primarily within the European Economic Area. However, some features and requirements of the service, involve transferring your information to third-party service providers outside the European Economic Area. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, we utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the other countries.
10.2 Period. We process and store your Personal Data as long as it is necessary for the performance of our contractual and statutory obligations. In this regard, it should be noted that our business relationship is a continuing obligation designed to last for several years.
If the Personal Data are no longer required for the performance of our contractual and statutory obligations, they are regularly deleted, unless their further processing (for a limited time) is necessary for special purposes.
In particular, the Company may store special information after fulfilling its obligations under contracts, if this is necessary to comply with legal requirements, resolve disputes, prevent fraud or abuse, and to ensure compliance with the provisions of this Privacy Policy. Personal Data of Users are stored for 12 months to analyze the behavioral activity of Users in depersonalized form.
The storage period for the required data can be extended for tax compliance purposes. In particular, information about the ETH staked may be stored by the Company for the period set forth by applicable law for tax audit or until the tax audit is completed, depending on what happens later.
We will stop processing your Personal Data if you object to such processing of data or if you have withdrawn your consent to processing that was previously received by the Company.
11. Third-Parties' Sites
The Site may contain links to websites maintained by third parties whose information and privacy practices differ from ours (for example, when processing payments). We are not responsible for the information or privacy practices used by such third parties. We recommend that you read the privacy policies of all third-party websites before using such websites or providing any Personal Data or any other information on or through such websites.
12. Policy Amendments
We'll notify you before we make changes to this Policy and give you the opportunity to review the revised policy before you choose to continue using the Site.
This Privacy Policy (the «Policy») defines how NeuroG Ltd, a company incorporated in the Republic of Seychelles with Company Number 225020 (registration address Suite 1, Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles) (hereinafter referred as "Neurogress", "Company," "we," "us") the owner of the website available on the Internet via https://Neurogress.com (hereinafter – the "Site"). Before you start using the Site, please read the Privacy Policy carefully. Using any functions, services and Site features, including just browsing, you (the Visitor / User), regardless of registration and participation in Stake Program, declare that you have read, understood and agreed to abide by Privacy Policy conditions, including any mentioned therein special conditions and rules without any exceptions and reservations. This Privacy Policy forms part of the General Terms & Conditions of Neurogress Services. In cases not regulated by this Policy, the General Terms & Conditions of Neurogress Services shall apply to the relationships that arise hereunder.
If you have any questions, please contact: [email protected]
It is presumed that by the fact of the Site use and participation in Stake Program or by providing Neurogress the Personal Data directly on its request, the User has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should refrain from using the Site and/or participation in Stake Program.
Throughout this Policy, Neurogress use the term "Personal Data" to describe information that can be associated with a specific person (the "User") and can be used to identify that person (including the information about the User's activities, such as information about your use of the Site, when directly linked to personally identifiable information, including automatically collected). Neurogress does not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.
This Policy is an integral part of General Terms & Conditions of Neurogress Services. The definitions set forth herein and mentioned with capital letter shall have the meaning as described in General Terms & Conditions of Neurogress Services.
The purpose of Personal Data collection, storage and processing within the Neurogress projects shall only be the identification of the Stake Program Users.
1. Technical Data Collection
Neurogress collect Technical Data from your usage the Site and Personal Data, provided to Neurogress by you. When the User visit the Site or use our Program, Neurogress collects the Personal Data sent to Neurogress by your computer, mobile phone, or other access device.
This Technical Data includes:
- your IP address;
- device information including, but not limited to, identifier, name, and type, operating system;
- mobile network information;
- standard web log information, such as your browser type, and the pages you accessed on Neurogress Site. When the User uses a location-enabled device to access the Site, Neurogress may collect geographical location data or use various means to determine the location, such as data from the User's device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots. However, Neurogress will not release your personally identifying information of such kind to any third party without your consent, except as set forth herein.
If the User want to participate in Stake Program, Neurogress may collect and store the following types of Personal Data about the User:
- Your first and second name;
- Your e-mail.
In certain cases (when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or "Know-Your-Customer" (KYC) policies) Neurogress may require you to provide additional information, and namely:
- Your address;
- Date of birth;
- Passport or driver license details;
- Numbers that You may use or have registered with your local tax authority;
- Utility bills;
- Photographs of you;
- Confirmation of proceeds sources;
- Sworn statements.
4. Direct Marketing
We can also use your e-mail for sending some marketing materials. Subscription to our marketing mailing is entirely voluntary and requires a proactive action including expressed consent on the part of the individual. We include an unsubscribe link in all electronic messages we send you. You may withdraw your consent to receiving these at any time. Should you do so, we will update our database and will not send your further messages of this nature. We may continue to contact you to the extend necessary for the purposes of any other Services you have requested.
5. Grounds for Processing Personal Data
The Company may process the User's Personal Data if there are one or more of the following reasons:
a. The performance of the contract (General Terms & Conditions of Neurogress Services);
b. Personal identification;
c. Legitimate interest and compliance with legal regulations;
d. Consent.
6. Cookies Use
When the User access the Site or use Neurogress Services Neurogress (or Google Analytics or similar service provider on our behalf) may place small data files called "cookies" on the User's computer or other device. You may control the use of cookies within your internet browsers' settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Site and Services may be partly not available.
Cookies are small files that are stored on the hard drive of Users. A cookie file is stored in web browser and allows the Site or third parties to recognize User and make it easier to use the Site while subsequent visits. These cookies allow the Company to track the usage of the Site and its functions. Using them allows us to better and more effectively serve Users and personalize the Site for a specific User.
The Company may use cookies to recognize repeated User visits, the type of content viewed and other sites to which the User was redirected from the Site, the time when each page and section of the Site was opened, and the functions used. All Personal Data that may be contained in cookies are processed based on the consent of the relevant subject in accordance with the Privacy Policy.
We use both persistent and session cookies, as well as their varieties for the operation of the Site.
7. Personal Data Transfer
Neurogress is the only data controller and processor, except for the cases when there is an objective Neurogress need to control/process or store Personal Data at Neurogress' counterparties or agents. Should such counterparty or agent be engaged by the Neurogress, Neurogress shall notify you in advance. Neurogress may transfer Users Personal Data to the following persons:
a. contractors who interact with the Company's token sales process;
b. contractors of the Company for Site operation and maintenance (including identification service providers for fraud prevention purposes);
c. government agencies and / or law enforcement officials, if required for the above purposes, if required by law or required for the legal protection of their own legitimate interests in accordance with applicable law.
Sharing will be carried out for the purposes set out above, or in accordance with specific legal regulations governing the Processing procedure.
8. User's Rights
8.1 Right of access. You have the right to obtain from the controller confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the processing; the categories of Personal Data concerned; the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Personal Data or restriction of processing of Personal Data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer.
The Company will also provide a copy of the Personal Data undergoing processing if requested. For any further copies requested by the data subject, the Company may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form.
8.2 Right to rectification. You have the right to have inaccurate Personal Data rectified or completed if it is incomplete under request for rectification made verbally or in writing. The Company has one calendar month to respond to a request.
8.3 Right to erasure ('right to be forgotten'). The User has the right to require Neurogress to delete Personal Data provided by the User to Neurogress or revoke his (or her) consent for collection, processing and storage of his (or her) Personal Data by Neurogress at any time. If you decide to do this, you should send the respective notification to the Neurogress. Neurogress shall delete Your respective Personal Data from any sources within 1 month from the moment Neurogress receive such request from you.
8.4 Right to object You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you. We will no longer process your Personal Data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where your Personal Data are processed for direct marketing purposes, you may also object at any time to processing of your Personal Data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
9. Personal Data Safeguarding
We take the privacy and security of your Personal Data very seriously. We have implemented technical and organizational security measures designed to ensure that data protection is integral to all processing activities and to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and any other unlawful or unauthorized forms of processing in accordance with applicable law.
We do not disclose this information to third parties except with your consent, in accordance with the provisions of this Policy, or if we believe that such disclosure is necessary (if there is a legitimate purpose: for example, in the event of a threat against you or others) in accordance with applicable law.
Neurogress protects your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards Neurogress use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Neurogress also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, Neurogress will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
10. Personal Data Storage
10.1 Territory. We store your information primarily within the European Economic Area. However, some features and requirements of the service, involve transferring your information to third-party service providers outside the European Economic Area. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, we utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the other countries.
10.2 Period. We process and store your Personal Data as long as it is necessary for the performance of our contractual and statutory obligations. In this regard, it should be noted that our business relationship is a continuing obligation designed to last for several years.
If the Personal Data are no longer required for the performance of our contractual and statutory obligations, they are regularly deleted, unless their further processing (for a limited time) is necessary for special purposes.
In particular, the Company may store special information after fulfilling its obligations under contracts, if this is necessary to comply with legal requirements, resolve disputes, prevent fraud or abuse, and to ensure compliance with the provisions of this Privacy Policy. Personal Data of Users are stored for 12 months to analyze the behavioral activity of Users in depersonalized form.
The storage period for the required data can be extended for tax compliance purposes. In particular, information about the ETH staked may be stored by the Company for the period set forth by applicable law for tax audit or until the tax audit is completed, depending on what happens later.
We will stop processing your Personal Data if you object to such processing of data or if you have withdrawn your consent to processing that was previously received by the Company.
11. Third-Parties' Sites
The Site may contain links to websites maintained by third parties whose information and privacy practices differ from ours (for example, when processing payments). We are not responsible for the information or privacy practices used by such third parties. We recommend that you read the privacy policies of all third-party websites before using such websites or providing any Personal Data or any other information on or through such websites.
12. Policy Amendments
We'll notify you before we make changes to this Policy and give you the opportunity to review the revised policy before you choose to continue using the Site.
