We are committed to protecting and respecting your privacy in accordance with our obligations under the Privacy Act 1993 (Act).
How we collect your personal information
Personal information you provide to us
We collect personal information you provide to us when you:
- register to participate in any distribution of VALE tokens – we may collect information such as your name, contact information, addresses and cryptographic signatures;
- provide any required identity, address or other information for compliance with anti-money laundering (AML) or know-your-customer (KYC) regulations – we may collect documentation such as your passport or domestic citizenship identification document or equivalent, tax identification or registration number (in certain cases document conveying such registration), bank account information, photographs, and/or proof of address in the form of government issued documents;
- provide feedback or contact us – we may collect your name, contact information as well as any other content included in the communication in order to respond to you;
- purchase VALE tokens – we collect your billing details as necessary in order to process the transaction;
Personal information we may collect automatically
We may collect the following personal information automatically when you:
- access our website or the platform – we may collect technical information about your equipment, browsing actions and patterns. This includes internet protocol (IP) address, browser type and version and time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use. We collect this personal information by using cookies and other similar technologies;
- access our website and the platform through a location enabled device, such as your mobile phone – we collect and process real time GPS-based information about your device’s location. If you do not consent to us collecting location based information you can either:
- disable the GPS or other location tracking functions from your device if your device allows you to do this; or
- cease accessing the website and platform.
How we use information we collect
We will use information we hold about you in the following ways:
- assessing your eligibility to receive VALE tokens;
- providing you with VALE tokens and access to the platform;
- dealing with your questions or concerns and other user care related activities;
- ensuring that content on our website is presented in the most effective manner for you and for your computer;
- helping us understand your needs and interests and provide you with better services. Specifically, we use your information to communicate with you, to provide service and support and to update you on relevant services and benefits;
- allowing you to participate in interactive features of our website and the platform, when you choose to do so; and
- notifying you about changes to our website, terms and the platform.
Data collected online by us may also be combined with information you provide us through other sources.
Non-personal information is collected for reporting about our website usability, performance, and effectiveness. It is used to improve the user experience, usability and website content.
Who we share it with
We may disclose or share your personal information with third parties in the following circumstances:
- With your consent. We may share your personal information with third parties when you have provided your consent or requested us to do so.
- Third party service providers. We may share your personal information with companies who provide us services (such as information processing, delivering products to you, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys) so that we can administer the platform. We require such service providers to contractually commit to protect the security and confidentiality of personal information they process on our behalf.
- Commercial partners. We may disclose your personal details to our commercial partners where you have consented or requested us to do so.
- Legal purposes. Where it is required by a third party or law enforcement authority in any jurisdiction.
- To protect the platform. Where it is needed to detect, prevent or address fraud, security or technical issues.
- Aggregated or de-identified information. We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with business prospects or partners.
- to estimate our audience size and usage pattern;
- to store information about your preferences, and so allow us to customise our website according to your individual interests;
- to speed up your searches; and
- to recognise you when you return to our website.
Where we store your personal information
Our services are expressly restricted to users 18 years or older. We will never knowingly request or solicit personally identifiable information from anyone under that age without verifiable parental consent. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should get in touch using the contact information provided on our website. In the event that we receive actual knowledge that we have collected such personal information without the requisite verifiable parental consent, we will delete that information from our database as quickly as is practical.
Third Person Data
You have the right to ask us not to process your personal information for marketing purposes. We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You also have the right to ask us not to contact you about product and service updates. You can exercise your right to prevent such processing by checking certain “opt out” boxes on the forms we use to collect your information. You can also exercise the right at any time by getting in touch using the contact information provided on our website. You will not be able to opt out of service-related communications (e.g. registration verification, purchase confirmations and changes/updates to features of the platform).
Access to information
The Act gives you the right to access information held about you so that you can update or correct it. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
Last updated: 27 November 2018