Token Privacy Notice

Dear Tokenholder,

We make reference to the recently implemented Cayman Islands Data Protection Law, 2017 (the “DPL”), which establishes, among other matters, a framework of rights and duties designed to safeguard individuals’ personal data.

In view of the DPL, we have prepared a privacy notice (the “Privacy Notice”), which is attached hereto as “Exhibit A” for your full consideration.

The Privacy Notice explains the manner in which the Company collects, processes and maintains personal data about you pursuant to the DPL.


This privacy notice (the “Cayman Privacy Notice”) explains the manner in which the Company collects, processes and maintains personal data about you pursuant to the Cayman Islands Data Protection Law 2017, as amended from time to time, and any regulations or orders promulgated pursuant thereto (the DPL).

The Company is committed to processing personal data in accordance with the DPL. In its use of personal data, the Company will be characterised under the DPL as a “data controller”, whilst certain of the Company’s service providers, affiliates and delegates may act as “data processors” under the DPL. For the purposes of this Cayman Privacy Notice, we, us or our means the Company in its capacity as data controller of the personal data and you or your means the Tokenholder or relevant individual affiliated or connected with the Tokenholder receiving this Cayman Privacy Notice.

If you are a nominee Tokenholder or a corporate entity, this Cayman Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.

Personal data: By virtue of acquiring Tokens, the Company and certain other service providers and their respective affiliates and delegates (the “Authorised Entities”) may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. We may combine personal data that you provide to us with personal data that we collect from or about you. This may include personal data collected in an online or offline context including from credit reference agencies and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data.

Why is your personal data processed: The storage, processing and use of personal data by the Company will take place for lawful purposes, including:

  • (a) to comply with any applicable legal, tax or regulatory obligations on the Company or another Authorised Entity under any applicable laws and regulations;
  • (b) to perform a contract to which you are a party or for taking pre-contractual steps at your request;
  • (c) to operate the Company, including managing and administering the Tokens and the business of the Company on an on-going basis which enables the Company and its Tokenholders to satisfy their contractual duties and obligations to each other;
  • (d) to verify the identity of the Company to third parties for any purpose which the Company considers necessary or desirable;
  • (e) to assist the Company in the improvement and optimisation of advertising (including through marketing material and content) its services;
  • (f) for risk management and risk control purposes relating to the Company;
  • (g) to pursue the Company’s or a third party’s legitimate interests: (i) for direct marketing purposes; or (ii) to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity, and share this data with legal, compliance, risk and managerial staff to assess suspicious activities; and/or
  • (h) where you otherwise consent to the processing of personal data for any other specific purpose.

As a data controller, we will only use your personal data for the purposes for which we collected it as set out in this Cayman Privacy Notice. If we need to use your personal data for an unrelated purpose, we will contact you. In certain circumstances, we may share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory.

We may transfer your personal data outside of the Cayman Islands, as permitted under the DPL. We will not sell your personal data.

Your rights: You have certain rights under the DPL, including:

  • (a) the right to be informed as to how we collect and use your personal data;
  • (b) the right to access your personal data;
  • (c) the right to require us to stop direct marketing;
  • (d) the right to have inaccurate or incomplete personal data corrected;
  • (e) the right to withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing, of your personal data;
  • (f) the right to be notified of a data breach (unless the breach is unlikely to be prejudicial);
  • (g) the right to complain to the Data Protection Ombudsman of the Cayman Islands. You can access their website here:; and
  • (h) the right to require us to delete your personal data in some limited circumstances.

Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to hold or otherwise deal with the Company’s Tokens or remain as a holder of the Company’s Tokens as it will affect our ability to provide our services to you as a Tokenholder.

Retention of Personal Data: The personal data shall not be held by the Company for longer than necessary with regard to the purposes of the data processing.

Changes to Privacy Notice: We encourage you to regularly review this and any updated Cayman Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.

Contact us: Please contact the Company if you have any questions about this Cayman Privacy Notice, the personal data we hold about you or to discuss your rights under the DPL.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: [email protected]

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