Last updated: 05/02/2023
We (“We”, “Us” or “Our“) are committed to securing your Personal Data and your privacy.
This privacy policy (the “Policy”) has been created to inform you about how We manage, collect, stores and uses the information you provide in connection with the website www.ainutoken.net (the “Website”).
We will uphold the following principles:
- To be transparent in respect of the collection and processing of Personal Data about you:
It is important to Us that you have at all times all the information required for you to make educated decisions about the processing of Personal Data about you when you visit our Website. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing.
In addition, if We find you are required to be provided with specific information, We will provide it to you in the appropriate time and place.
We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: [email protected]
- To process Personal Data about you solely for the purposes outlined in the Policy:
The purposes for which We may process Personal Data about you include, inter alia, to make the Website available to you and provide you with the services involved therein , to enhance the user experience in the Website, to improve the Website and the services involved therein, to protect Our rights and interests, to perform business and administrative activity that supports the Website, and/or to uphold any legal and/or regulatory requirements.
- To invest significant resources in order to respect your rights in connection with Personal Data about you:
We apply significant resources to allow you to exercise your rights as a data subject. Therefore, you may approach Us any time you wish to review Personal Data about you, have Us amend it, erase it, cease using it for specific purposes or in general, or transfer it to you or to a third party, all as described in the Policy. We will fulfill your wishes in accordance with the law and the Policy.
- To secure Personal Data about you:
While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures aimed at ensuring that the Personal Data about you is secured.
Our Complete Privacy Policy
1. The Scope of this Policy
This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, process it, etc.
In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
The Website is intended for general audience and are not directed at children under the age of 18. We do not knowingly collect or solicit information from anyone under the age of 18 or knowingly allow such persons to access the Website. If We learn that information about a child was collected, We will take reasonable steps to delete such information as soon as possible.
2. When Do We Collect Personal Data About You?
We collect Personal Data about you whenever you use the Website or interact with Us in any manner. In some instances, you will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about you by way of observation of your use of the Website.
3. No Obligation To Provide Personal Data To Us And Its Implications
You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with some or all of the services involved in the website, will prevent your use of the Website, and/or will cause the malfunctioning of the services involved in the Website.
4. What types of Personal Data do We collect? Personal Data We collect upon each browsing onto the Website:
- Website activity information – We automatically gather certain data out of your use of the Website. The information that We gather about you in this context includes any interaction that you will make with the Website, including the Website’s pages that you will visit, Your interaction with such pages, the content that you will view, and the like.
- Technical usage and log information – as you navigate through and use the Website, We may also use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns. This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used, information regarding the device you used. Some of this information may not identify you personally, and therefore not constitute Personal Data.
- Communication information – when you contact us, including via the Website, you may provide Us with your name, certain contact information (such as email address) and the content of your communication with Us.
5. The Purposes Of The Processing Of Personal Data And Their Legal Basis
We processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
We will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which We may process Personal Data about you are as follows:
- Processing is necessary for the purposes of the legitimate interests pursued by the Us or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.
- Processing is necessary for compliance with a legal obligation to which We are subject.
If you wish to receive more information detailing how processing is being necessary for the purposes of the legitimate interests pursued by Us or by a third party, you may approach Us by sending a notice to info@ainutoken.net at any time.
The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:
| Purpose | Legal Basis | |
| 1 | In order to make the Website available to you and provide you with the services involved therein | Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party |
| 2 | In order to respond to your queries, requests, and/or complaints Processing of Personal Data about you is required in order to respond to queries you have concerning your use of the Services. | Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party. |
| 3 | In order to comply with any legal obligations or judicial or administrative orders We process Personal Data about you in order to comply with Our various legal obligations. | Processing is necessary for compliance with a legal obligation to which We are subject to. |
| 4 | In order to improve the Website and the services involved therein We may use Personal Data about you in order to improve the Website and/or the services involved therein. Such processing will include, inter alia, any crash logs or other malfunction reports obtained in respect of the Website. | Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party. |
| 5 | In order to perform and maintain various activities supporting the provisions of Our Services Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc. | Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party. |
| 6 | In order to perform analysis, including statistical analysis We use various analytical measures (including statistical ones) to make decisions on various issues. | Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party. |
| 7 | In order to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims We may process Personal Data about you in order to protect Our interests, rights, and assets, or those of third parties, according to any law, regulation, or agreement, including any of Our terms and conditions and policies. | Processing is necessary for the purpose of the legitimate interests pursued Us or by a third party. |
6. Transfer Of Personal Data To Third Parties
We may share Personal Data about you with third parties that provide Us services, such as storage and hosting providers, IP address information, analysis of user experience and research, analytical, technical, and diagnostic services.
We may share Personal Data about you with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims.
In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the We are a part of, or in the event of any similar transaction (including the sale of Our assets and/or of any company within the group of companies of which We are a part of), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of Us and/or of any company within the group of companies of which We are a part of.
7. Cookies and Third Party Services
We may use certain third party services, such as analytics companies or companies delivering advertisements in our Website, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.
Cookie (which is a small text file) is installed on the device via which you visit or access the Website. The cookies shall allow to collect information about you and your behavior, in order to improve your user experience, to remember your preferences and settings, and to customize and offer you products and services that may interest you. Cookies may also be used to collect statistics and perform analytics.
Some of the cookies We may use are session cookies, which are downloaded temporarily to your device and last until you close your web browser, while others are persistent cookies, which last on your device after you cease browsing the Website and can be used to help the Website remember you as a returning visitor when you return to the Website.
Types of cookies:
The cookies We may use are classified according to their functionality, as follows:
| Type of Cookie | Purpose | Additional Information |
| Strictly Necessary Cookies | These cookies are strictly necessary to enable you to navigate the Website and use features you have requested. They are used to provide you with Our content, products, and services that you have requested. Such cookies are essential to help your device download or stream information so that you can navigate around the Website, use its features, and return to pages you have previously visited. | These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Website. These cookies are deleted when you close your web browser (session cookies). |
| Functionality Cookies | These cookies are used to recognize you when you return to the Website and allow Us to remember your choices and preferences. | These cookies survive the closing of your web browser, and last until their applicable expiry time. |
| Performance Cookies | These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website. | These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period. |
The Cookies incorporated in our Website are as follows:
| Party | Name | Retention | Type | Function |
| Tracking of statistical data (anonymized) | _ga | 2 years | Non-functional | Analytics and Performance Related Cookies |
| Tracking of statistical data (anonymized) | _gid | 24 hours | Non-functional | Analytics and Performance Related Cookies |
| Tracks which elements are clicked most on a website (anonymized) | _gat_gtag_* | 1 minute | Non-functional | Analytics and Performance Related Cookies |
| Hotjar web analytics | _hjSessionUser_{site_id} | 365 days duration. | Non-functional | Analytics and Performance Related Cookies |
Blocking and removal of cookies
You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note, however, that if you do so, some or all of the Website’s features and functionalities might not perform as intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
8. Retention Of Personal Data About You
We shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us.
In order to ensure that Personal Data about you is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.
9. Protection Of Personal Data About You
We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.
We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of your Personal Data, and We will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Data about You including, but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.
We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties.
Any transfer of Personal Data via the internet cannot be fully secured. Therefore, We cannot ensure the protection of Personal Data about you when transferred via the internet to Us.
10. Links To Websites of Third Parties
The Website may provide links to other websites and/or applications. Some of these websites and/or applications are owned or operated by Us, and some of them are operated or owned by third parties. In the latter case, We do not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities.
This Policy only applies to this Website and not to any other website or application referred to in this Website. Whenever you access such websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you.
11. Your Rights In Respect Of The Personal Data
Generally, you have the right to request that We provide you with confirm whether Personal Data about you is being collected by us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict you consent to certain processing of your Personal Information.
Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: [email protected]
Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
At any time, You may approach Us by sending a notice to the email address [email protected], in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
The Company may provide You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Our’s or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests.
Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials are tailored to offer You products and services which We think may be of more interest to You.
In addition, You may withdraw Your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: [email protected]. or by clicking the unsubscribe option in any marketing material sent to You. You can withdraw Your consent from receiving marketing materials via push notifications in Your mobile device’s settings page.
Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our services or for other legitimate non-marketing reasons.
| Right | Scope | |
| 1 | Right to know | You have the right to receive the following information: The specific pieces of Personal Data We have collected about You.What types of Personal Data collected;categories of personal data collected;What are the types of sources of the Personal Data collected;the purpose of collecting the Personal Data;Types of third parties with whom We share Personal Data, if any; and |
| 2 3 | Right of Erasure Right to non selling or sharing | You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Website or Services otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information. You may ask Us to not sell or share Your Personal Data. |
| 4 | Right to Non-Discrimination for the exercise of Your privacy rights | You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA. |
| 5 | Right to designate an authorized agent to submit CCPA requests on Your behalf | You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below. |
In order to exercise Your rights, please contact us using the following details: [email protected]
If You are an EEA resident, please read this section below:
You are entitled to the following rights in respect of the Personal Data about You. To exercise such rights, You may send a request to exercise Your rights to the following email address: [email protected]
We will grant Your right to receive information how Personal Data about You is processed by Us; to rectify any inaccuracy in Your Personal Data; to erase Your Personal Data processed and stored by Us; to restrict the processing thereof or object thereto if applicable under the circumstances; the right to receive the Personal Data about You, which You have provided to the Company, in a structured machine readable manner and the right to withdraw Your consent when such is the legal basis of our processing.
We may reject Your requests where the request harms the rights and freedoms of others or comply with legal requirements applicable to Us. We may also charge a reasonable fee where applicable.
You will also have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
Please note that We may need to receive Personal Data from You in order to verify Your identity prior to allowing You to exercise Your rights.
12. Transfers Of Personal Data To A Third Country Or An International Organization
Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, We shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
If you are an EEA (European Economic Area) resident, please note that these safeguards and protection will be available if any of the following are met:
- The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR“).
- The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
- The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
You may request that We will provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: [email protected]
14. Changes To This Policy
We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify you of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our Website.
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