PRIVACY POLICY
This Privacy Policy (“Policy”) explains how Hyblock Capital L.L.C. (a limited liability company incorporated under the laws of State of New Jersey) (“Hyblock”, “we”, “us” or “our”) collects, uses, stores and disclose information from and about you (“you”, “your” or “User”) access and/ or use the website https://hyblockcapital.com (including any and all subdomains, collectively, the “Website”), and/ or use Hyblock’s services or any other features, technologies or features offered by Hyblock through the Website or through any other means (the “Services”).
PLEASE READ THE TERMS AND CONDITIONS AND ALL OF THE FOLLOWING TERMS OF THIS POLICY BEFORE USING THIS WEBSITE. BY CONTINUING TO ACCESS OR USE THIS
WEBSITE OR ANY SERVICE ON THIS WEBSITE, YOU SIGNIFY YOUR ACCEPTANCE OF THE TERMS OF THIS POLICY.
We will provide notice of any amendment to this Policy by posting any revised document to the Website and updating the “Last updated” field above accordingly, and we will notify you prior to such an amendment come into effect. We are not obligated to provide notice by any other means. Any change to this Policy will be effective immediately upon such notice and apply to any ongoing or subsequent use of the Website and Services.
The processing of your Personal data in relation to your use of the Website and/or use of the Services, will be subject to this Policy. If you disagree with any part of this Policy, you may not access the Website and/or use the Services. Should you disagree with any provision of this Policy you shall cease using the Website or any Services immediately. If you are using the Website or the Services in your own name or on behalf of any entity, you acknowledge this Policy on your or such entity’s behalf (when applicable).
1. INFORMATION WE COLLECT
We collect the following type of data and information from you:
1.1. Personal data: The information that identifies you as an individual or relates to an identifiable person.
1.2. [Non-Personal data: We retain some non-personally identifiable information, such as your approximate geo-location, your web request, browser type, browser language, web pages you visit before or after visiting our Website, URLs, platform type, click numbers, landing pages, viewed pages and the order of those pages and time spent on pages. This data is obtained with your consent where required by applicable law. Further, this information is collected and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates, and calculate payments to third parties.]
1.3. [Cookies: Non-Personal Information is collected, inter alia, through the use of cookies, so when accessing or using the Website, we may use one or more cookies. Cookies are small text files, placed on a user’s device, which enable a website to remember user preferences. Detailed information about cookies and how we use them on the Website and other websites implementing our web tools may be found in our [Cookie Policy], which also describes how you can turn off cookies or control them.]
1.4. [“Web Beacons” – We also use a software technology called “clear gifs” (also known as Web Beacons). Web Beacons are small pieces of code placed on a website to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a “cookie” to the browser of a visitor viewing that page.]
1.5. [Personal data we receive from third parties: To the extent permitted by applicable law, we may receive Personal data about you from third parties, such as our affiliates or social media services, commercially available sources, etc. The Personal data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. For example, if you access the Website through a social media service (or our affiliates) [or connect the Website to a social media service], the information we collect may also include your user ID and/or user name associated with that social media service, any information or content the social media service will share with us, such as your profile picture, or email address. The information we obtain depends on your privacy settings on the applicable social media service.]
2. USE OF THE PERSONAL DATA
2.1. We collect Personal data to:
(i) Provide our Services and improve them over time;
(ii) Allow you to purchase/ subscribe to our Services;
(iii) Personalize and manage our relationship with you, including introducing you to products or features that may be of interest to you or to provide customer support;
(iv) Investigate, respond to, and manage queries or complaints;
(v) Work with and respond to law enforcement agencies and regulatory authorities; and
(vi) Research matters relating to our business such as security threats and vulnerabilities.
2.2. Basis for Data Processing:
The data we collect and the data you provide to us is processed:
(i) For the [performance of the agreement between you and us and/or for taking steps, at your request, to enter into such an agreement]
(ii) For our legitimate interests, namely the proper administration of our business, the monitoring and improving of our Website and Services, and for the protection and assertion of our legal rights, your legal rights, and the legal rights of others; and
3. RETENTION OF DATA
We will retain your Personal data for the duration required to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable law, we will keep records containing Personal data, communications and anything else as required by applicable laws and regulations.
4. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal data. You have the right to:
(i) Request access to your Personal data: This enables you to receive a copy of the Personal data we hold about you and to check that we are lawfully processing it.
(ii) Request correction of the Personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(iii) Request erasure of your Personal data: This enables you to ask us to delete or remove Personal data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your Personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal data to comply with applicable law. However, it is pertinent to note herein that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(iv) Object to processing of your Personal data: In the event we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are
processing your Personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
(v) Request restriction of processing of your Personal data: This enables you to ask us to suspend the processing of your Personal data in the following scenarios: (a) if you want
us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(vi) Request the transfer of your Personal data to you or to a third party: We will provide to you, or a third party you have chosen, your Personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the
information to perform this agreement with you.
(vii) Withdraw consent at any time (where we are relying on consent to process your Personal data): However, this will not affect the lawfulness of any processing carried out before
you withdraw your consent. If you withdraw your consent, we may not be able to provide Services to you. We will advise you if this is the case at the time you withdraw your
consent. If you wish to exercise any of the rights set out above, please contact us.
5. DATA SECURITY
[Hyblock has put in place appropriate security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In
addition, Hyblock limits access to your Personal data to those employees, agents, contractors and other third parties who have a business relationship with Hyblock, on a need to know basis.
They will only process your Personal data on instructions of the Company, and they are subject to a duty of confidentiality. Hyblock has put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. All Hyblock’s data is fully encrypted at rest and in transit, and the Company employs state-of-the-art firewall and back-up technology. All Hyblock’s data is continuously backed up in several high security access-controlled data centres in different locations.]
6. SHARING DATA
We may share your information as follows:
(i) If we have aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
(ii) With our affiliates and partners (collectively, “Affiliates”) in order to provide you with specific Services that are offered or provided by us, our Affiliates;
(iii) With our Affiliates in order to provide you with the newsletters you have subscribed to at the Website;
(iv) With third party service providers who we use in delivering links to our Services and Website, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
(v) If required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process;
(vi) To protect the rights, property and safety of Company, our users and the public,
including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims; or
(vii) In connection with selling, merging, transferring, or reorganizing all or parts of our business.
7. CONTACT US
To keep your Personal data accurate, current, and complete, please contact us at support@hyblockcapital.com. We will take reasonable steps to update or correct Personal data
in our possession that you have previously submitted when using our Services. Please also feel free to contact us if you have any questions about our Policy.