PRIVACY POLICY

TRILITECH KANVAS LIMITED

We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data.

This Privacy Policy aims to give you information about how we collect and process your personal data when you visit our website(s) – including subdomains of our website(s) and websites through which we make our products/services available (together, “our site”) – regardless of where you visit these from, including any data that you may provide through our site, when you purchase our products/services, or when you otherwise interact with us.

Please read this Privacy Policy carefully and ensure that you understand it. By using our site or products/services, you agree to be bound by this Privacy Policy and consent to the collection, use, processing, and disclosure of your personal data as described in this Privacy Policy.

It is important you read this Privacy Policy together with any other Privacy Policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

References to “you” or “your” are to you as an individual using our site or otherwise contacting us (whether on behalf of yourself, or another individual or organisation).

1. INFORMATION ABOUT US

1. Our site is owned and operated by TRILITECH KANVAS LIMITED, a business company incorporated with company number 2097653 under the laws of the British Virgin Islands with its registered address at Trinity Chambers, Ora et Labora Building, Wickhams Cay II (PO Box 4301), Road Town, Tortola, British Virgin Islands (“Trilitech”, “we”, “us”, or “our”). We are the controller and are responsible for this site.
2. We are responsible for your personal data when you use our services or visit our website directly. However, if you use our services through a relationship with one of our clients (for example, as an employee or customer of that client), we will process your personal data on behalf of that client. In this case, the client's privacy policy will apply, and they are responsible for your personal data.
3. Where we process your personal data because you use our products/services as a result of your relationship with a client who we supply our products/services to, we are not the data controller as we would be processing personal data on behalf of our client as a data processor.
4. Where we are processing your personal data on behalf of our client, the privacy policy that you should be referring to would be our client’s privacy policy. Our client’s privacy policy should inform you as to how your personal data will be processed.
5. We are bound by applicable data protection laws in respect of the handling and collection of your personal data.

2. DATA WE COLLECT

1.  When you visit our site, and where you have given your consent, we automatically collect certain information about your device. This includes:

• Web Browser Information: Type and version.
• IP Address
• Time Zone
• Cookies installed for analytics via Google Analytics

We collect this information using technologies such as:

• Cookies: Data files placed on your device or computer that often include an anonymous unique identifier.
• Log Files: Track actions occurring on our site and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• Web Beacons, Tags, and Pixels: Electronic files used to record information about how you browse our site.

Additionally, as you browse our site, with your consent, we may collect information about:

• Individual web pages or products viewed.
• Websites or search terms that referred you to our site.
• How you interact with our site.

We refer to this automatically collected information as “Device Information”.

We also use Google Analytics to help us understand how our customers use our site. You can read more about how Google uses your personal information here: Google Privacy Policy. You can also opt-out of Google Analytics here: Google Analytics Opt-Out.

We do not alter our site’s data collection and use practices when we see a Do Not Track signal from your browser.

2. We may ask you to provide data to access certain services on our website. We will inform you why we need this data. Your data will be managed according to this Privacy Policy.
3. We may obtain certain personal data about you from third parties, publicly accessible sources, or our affiliates and partners, as permitted by law. This data may include:

• Information from public registers and court proceedings.
• Details related to your professional role and activities.
• Correspondence and discussions with third parties.
• Credit rating information (if necessary for business transactions).
• Information provided by individuals associated with you for contract purposes (e.g., consultants, legal representatives).
• Bank details and insurance information.
• Data from distributors and business partners related to orders or services (e.g., payments, previous purchases).
• Information found in media or online sources relevant to our interactions (e.g., job applications, media reviews, marketing).
• Your address, interests, and socio-demographic data (with your consent, for marketing purposes).

3. THIRD PARTY LINKS

1. Our site may include links to third party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you.  Third-party sites are not under our control, and we are not responsible for its content.  When you leave our site, we encourage you to read the privacy policy of every website you visit.

2. Our site neither collects nor receives any of the information entered into third-party sites when making a purchase. Any purchases made on our site are made through your personal Tezos-compatible wallet.

4. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, or pursuant to a service that we have been asked to supply to you, and you fail to provide that data when requested, we may not be able to perform the applicable contract or service. In this case, we may have to cancel any arrangement you have with us. We will notify you if this is the case.

5. PURPOSES FOR PROCESSING PERSONAL DATA

1. We will only use and process 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 provide services or information to you or to perform the contract we are about to enter or have entered with you.
  

• Where we have a legal or regulatory obligation we must comply with.
  

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  

• Where we have your express consent to process your data.
  

1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. For instance, we may use your personal data to contact you in the future with press releases, news and updates about Tezos. In each case where we believe that this may be in your interest. “Tezos” means the open-source distributed ledger and blockchain software technologies known as the Tezos protocol and the peer-to-peer permissionless blockchain computer networks powered by the Tezos protocol.  Tezos does not exist as a legal person, and no single entity owns, manages, or controls Tezos.

2. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  

6. HOW WE MAY SHARE YOUR PERSONAL DATA

1. Professional Advisors and Authorities. We may share your personal data with professional advisors (e.g., lawyers, bankers, auditors, and insurers) and with HM Revenue & Customs, regulators, and other authorities as required by law.
2. Service Providers. We may share your personal data with third parties that provide services to us, such as IT service providers, payment processors, and analytics providers, to support our business operations and improve our services. These providers are bound to protect your data and use it only for the specified purposes in accordance with our instructions.
3. Business Transfers. If we choose to sell, transfer, or merge parts of our business or our assets, or if we seek to acquire other businesses or merge with them, we may share your personal data with the third parties involved in the transaction. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Policy.
4. Third-Party Data Protection. 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. They are only permitted to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers. We may transfer your personal data outside the UK and/or EEA. Whenever we do so, we ensure a similar degree of protection by implementing at least one of the following safeguards:

• Adequacy Decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  
• Legal Basis and Safeguards: If the country to which we transfer your personal data does not have an adequacy decision, we will ensure that there is a legal basis for the transfer and, if required, implement appropriate safeguards to ensure your data is protected.
  
• Standard Contractual Clauses: Where we use service providers outside the UK and/or EEA, we may use specific contracts approved for use in these regions, which give your personal data the same protection it has in the UK and/or EEA.

7. RETENTION OF YOUR PERSONAL DATA

1. We shall hold on to your data for an initial period of 2 years or longer where necessary. If you have any further questions, please contact us at contact@trili.tech

8. CHANGES TO THIS PRIVACY POLICY

1. We keep this Privacy Policy under regular review and may update it from time to time. We reserve the right to make amendments to our Privacy Policy at any time. Historic versions can be obtained by contacting us.

2. Any changes we may make to this Privacy Policy will be posted on our website.

3. Unless otherwise provided in this Privacy Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.