Privacy Policy

 

Introduction

This Privacy Policy is applicable to you as a Fungible customer using one of Fungible's customer facing platforms. These platforms provide you with access to our products and services. We are committed to inform you about how we handle your personal data, to give you control over how it is used, and to protect it. Here you will find details about the information we have about you, how and why we collect it, how we use it, and how we keep it secure. This Privacy Policy also tells you about your rights, how you can exercise those rights, and how the law protects you.

About Fungible

 

Fungible Network is a global group of companies that enable our customers to create and trade crypto tokens.

 

If at any time you have any questions about this Privacy Policy or the way we use your personal data please contact us at privacy@fngbl.io.

 

The data we collect about you

We collect the information that is necessary to conduct our business, to provide the services you have requested and to keep you informed. We may also use the information you provide to communicate with you about our products and services. We may share your information with third parties in order to expand or improve our services. Your data can also be used for market research and advertising.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: including first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data: including billing address, delivery address, email address, and telephone numbers.
  • Financial Data: including bank account and payment card details (we only use this data for payment processing purposes).
  • Blockchain Data: including details about your crypto wallets and smart contract addresses, passwords and transactions identified with these items.
  • Transaction Data: including details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data: including internet protocol (IP) address, your login data, traffic data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other communication data which gives us about how you accessed our website.
  • Profile Data: including your username and password, purchases or orders made by you, (your interests, preferences, feedback and survey responses).
  • Usage Data: including information about how you use our website, products, and services.
  • Marketing and Communications Data: including your preferences in receiving marketing from us (and our third parties) and your communication preferences.

We do not hold any "special category" data about you (such as data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, data about your health and genetic data).

How is your personal data collected?

Generally, we collect personal information related to you, when you decide to interact with us, or use one of our products or services or express an interest in them. We also look at how you interact with our websites so that we can offer you the best possible experience.

Data collection methodology includes:

 

  • Direct interactions: you may give us personal information by filling in forms or by corresponding with us by mail, phone, email, in person at events, as part of our contractual arrangement with you, by inputting that data into one of our customer’s facing platforms, or otherwise. This includes personal data you provide when you order or express an interest in our products or services; request marketing materials to be sent to you; enter a competition, promotion or survey; or give us some feedback.
  • Automated technologies or interactions: as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources: we may receive personal data about you from various third parties and public sources including social media platforms, our own corporate prospect/customer databases, KYC and AML service providers or online research referrals.

 

How we use your personal data

 

  • To verify your identity and entitlements to our products and services when you contact us or access our services.
  • To provide fraud prevention and detection.
  • To supply services to you and manage your subscriptions.
  • To send statements and invoices to you, and collect payments from you.
  • To provide commercial quotes to you.
  • For statistical analysis (e.g. on the use of our websites).
  • To operate and improve our websites and services.
  • To supply services to you and manage your subscriptions.
  • To notify you of any changes to our websites or our services and products which may affect you.
  • To provide you with technical and customer support.
  • To ask your opinion or feedback on our services or industry questions.
  • To ensure seamless access to all of our applications to which you have access.
  • To enforce our legal rights or comply with legal requirements.
  • To provide improved website and product experience and communications informed by your product subscriptions and/or data collected.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is in our legitimate interests, including our commercial interests in operating the Fungible customer-facing platforms. We make sure that we consider and balance any potential negative impact on you and your rights before we process your personal data.

 

How we share your personal data

We may share your personal data with companies within the Fungible Network and other parties detailed below. We may also transfer your personal data outside of the European Economic Area (EEA), but only when specific safeguards have been put in place in order to protect your personal data.

We may share your personal data with one or all of the following External Third Parties:

  • Suppliers who we engage to provide services on our behalf, for example, payment processors and marketing services companies.
  • Professional advisors including lawyers, accountants, and insurers were necessary to enable them to provide their services to us.
  • Authorities who require reporting of processing activities in certain circumstances.

We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with contractual obligations which ensure adequate protection for your personal data.

International transfers

We may share your personal data with entities within the Fungible Network and into marketing partners used by the Fungible Network. Given that we are an international organization with our headquarters in the U.S., this may involve transferring your personal data outside of the European Economic Area (EEA). Some of the third parties to whom we transfer your personal data are also based outside of the EEA, so their processing of your personal data will likewise involve a transfer outside the EEA.

How we protect your personal data?

We are committed to protecting your personal data. We put in place safeguards including appropriate technologies, policies, and contractual arrangements so that the data we have about you is protected from unauthorized access and improper use, and we will not keep your personal data for longer than necessary.

 

How long will we use your personal data?

We will keep your personal data only for as long as is necessary for the purposes set out in this privacy notice and to fulfill our legal obligations. We will not keep more data than we need. While you remain a customer, we shall retain your data in order to keep providing services to you. If you do not wish to use Fungible's services we will keep your personal data for a period required by law before deleting it. We are required to keep some basic information about our customers for a longer period in accordance with applicable tax and regulatory laws. In some circumstances, you can ask us to delete your data.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, and the right to object.

Under EU data protection laws you have a number of rights in relation to your personal data. These rights are not absolute – in some cases, they will not apply to you, or to the particular use that we are making of your data. There are exceptions, for example, if we have to process the data to comply with our own legal obligations; if that is the case we will let you know.

Your rights include

  • Access to your personal information (by what is commonly known as a "data subject access request").
  • Require us to correct any mistakes in your information which we hold.
  • Require the deletion of personal information concerning you in certain situations.
  • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit that data to a third party in certain situations.
  • Object at any time to processing of personal information concerning you for direct marketing.
  • Object to decisions being taken by automated means (including profiling) which produce legal effects concerning you.
  • Object in certain other situations to our continued processing of your personal information.
  • Otherwise restrict our processing of your personal information in certain circumstances.

 

For further information on each of these rights, including the circumstances in which they apply, See the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

 

You also have the right to take your concerns at any time to the Data Commissioner's Office (ICO, the UK supervisory authority for data protection issues (www.ico.org.uk).

EU Supervisory Authority list

 

European Union General Data Protection Regulation (GDPR)

On May 25, 2018, the EU GDPR came into effect and impacted the way businesses collect and hold data on EU subjects. The GDPR is a new privacy law that harmonizes and modernizes all EU countries’ data protection requirements and is designed to improve the way organizations handle personal data. It is a law aimed at protecting the rights of the EU citizen.

Although there are many new or enhanced requirements, core principles are unchanged. New rules have expanded the definition of personal data and expanded the reach to affect any company, even those outside the EU, that collects personal information of individuals in the EU. Our position, obligations and responsibilities are articulated in the data privacy notices and policy, all held on this site.

Fungible's commitment to data privacy

Fungible welcomes this opportunity and is committed to protecting personal data that is used within the Fungible products that you use, and to ensure that we and our customers comply with our obligations regarding data.

What to do now as the customer?

If you are a customer please review our Privacy Policy to ensure that we and our customers are complying with our respective obligations under GDPR.

Dedicated GDPR resources

We have a specialist team working globally with key functional areas to ensure GDPR preparations are being put in place. We are managing and protecting your data effectively and working to a strategic ambition of privacy by design. Key areas we’re working on include:

  • Updating data processing agreements with suppliers and ensuring key processors are aligned with our privacy policies.
  • Formally documenting privacy practices that we have in place, so we can comply with the enhanced record keeping requirements.
  • Updating and refreshing terms and contracts with our clients.
  • Enhancing processes, services and products with supporting privacy initiatives to help us fulfill our obligations.

 

This site provides information on GDPR and how it affects customers, prospects, influencers and all subjects in our business domain. If you find you have more specific inquiries not addressed on here, please contact privacy@fngbl.io.