‍POKT NETWORK FOUNDATION PRIVACY POLICY

‍

Last Revised on November 19, 2024

NAVIGATION

INTRODUCTION

CHANGES TO THIS PRIVACY POLICY

CATEGORIES OF PERSONAL DATA

PNF’S PROCESSING OF INFORMATION

DISCLOSURE OF PERSONAL DATA

SECURITY AND RETENTION

CHILDREN’S PRIVACY

CONTACT US

YOUR RIGHTS AND CHOICES

REGIONAL SUPPLEMENTS

INTRODUCTION

This Privacy Policy for Pocket Network Foundation (“Pocket Network Foundation”, “PNF,” “we,” “us,” or “our”) describes how we collect, use, and disclose information about users of (i) the Company’s website (www.pokt.network), applications, APIs, and online services (“Sites”), (ii) the POKT Network (the “Platform”), (iii) the POKT Gateway Accelerator Tour (“PGAT”), and (iv) our other services including but not limited to offerings, and interactions such as community events, surveys, user conferences, and customer service inquiries (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access, or download any of the Services.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our Site (“Third Party Services”), or any other third party products, services, or businesses.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will post an updated version of the Privacy Policy on our Site.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.

CATEGORIES OF PERSONAL DATA

When you access or use the Services, we may collect certain categories of information about you (collectively, “Personal Data”), which may include:

  • Audio/Visual Data: Recordings such as audio files and records (e.g., voice mails, call recordings, and the like).
  • Biographical Data: Data relating to professional and employment history, qualifications, and similar biographic information.
  • Contact Data: Personal and business contact information (e.g., postal addresses, email addresses, telephone numbers, or other identifiers used for communication).
  • Content: Unstructured or free-form content that you post on our Sites or Platform that may include Personal Data (e.g., text, images, photographs, messages, comments, feedback, and correspondence).
  • Commercial Data: Information relating to transactions and purchases, registrations through our Sites, and related information (e.g., pricing and ticket quantity).
  • Company Data: Information you provide to us regarding your company (e.g. financial data, pitch decks, investors, etc.)
  • Device/Network Data: Information regarding your interaction with Sites, applications, or advertisements (e.g., IP Addresses, MAC Addresses, SSIDs, online user IDs, web server logs, application logs, cookie data, web beacons, clear GIFs, pixel tags, browser versions, and OS versions).
  • Identity Data: Information such as your name; address; email address; telephone number; gender; date of birth, age and/or age range; photo/avatar; account login details (e.g., username and password); and information such as unique IDs and online identifiers.
  • Inference Data: Information such preferences, characteristics, predispositions, behavior, demographics, household characteristics, market segments, and other data (e.g. preferences for marketing communications and details about how you engage with them).
  • Sensitive Data: Personal Data deemed “sensitive” or “special categories of Personal Data” under GDPR, CCPA, or other laws. We collect the following categories of Sensitive Personal Data:some text
    • “Government ID Data” Data relating to official government identification, such as driver’s license or passport numbers, including similar Identity Data protected as Sensitive Data under applicable law.
    • “Health” data relating to your health.
    • “Payment Data” Information such as bank account details, payment card information, including similar data protected as Sensitive Data under applicable law, and relevant from a Payment transaction.
    • “Race or Ethnic Origin” data relating to your race, ethnic, or national origin.
    • “Sexual Orientation” data relating to your sexual orientation or identity.
    • “Religion” data relating to your religious or philosophical beliefs.

PNF’S PROCESSING OF INFORMATION

Events, Programs, and Recordings

You may give us Personal Data when you apply for a PNF program such as PGAT, register for an account, or otherwise submit information to use through the Services or other communications with us. For example:

  • We my collect Identity Data, Contact Data, Biographical Data, and Content when you create a profile on our Platform or Site (“Profile Data”).
  • We may collect Commercial Data, Contact Data, Identity Data, and Payment Data when you register for an Event or enter into a commercial transaction (“Transaction Data”).
  • We may collect Identity Data, Contact Data, Biographical Data, Content, Government ID, Protected Class Data, or Sensitive Data when you submit an application to one of our programs (“Application Data”).

In certain cases (such as in connection with our Diversity & Inclusion efforts), we may collect and share with parties you authorize, Sensitive Data such as Race or Ethnic Origin, Religion, Health, or Sexual Orientation. Additional information regarding these programs, how your Personal Data will be shared, and the parties that may receive it, are available within program descriptions we provided at the time you agreed to participate in the program.

We process this Personal Data to create and maintain your account, to operate our Events and programs, to provide the products and services you request, or to perform or initiate a transaction with you. Our Platform, Events, and programs are designed to connect you with founders, investors, and the broader community, and we will disclose Personal Data we collect in these contexts with partners, mentors, and other user groups with which you interact or direct us to disclose data through our Services.  

As part of our Services, we host community events, Startup Weekend competitions, demo days, mentor sessions, and other events where you may engage with PNF, founders, teams, sponsors, investors, and other community members (“Events”). At these Events, we may generate records such as photographs, audio and visual recordings, interviews and surveys, and similar activities (“Event Recordings”).

We may process or publish certain video, images, etc. without your consent, such as when we publish on an Event page certain Event Recordings that include images of groups or crowds in attendance at an Event. You may object to the processing of your Personal Data in connection with Event Recordings during the Event by speaking with its organizers, or afterwards, by contacting us using the information below. The processing of Personal Data in connection with Event Recordings may be subject to additional terms and conditions to which you are a party (e.g. a release or consent) that will supersede the nature of processing or individual rights described in this Privacy Policy to the extent in conflict. If required, we may seek your consent or release.

Where legally permissible, we may use or share your Personal Data with your consent, such as when you consent to participate in additional surveys on gender and race/ethnicity, let us post your testimonials or endorsements on our Sites, instruct us to take a specific action with respect to your Personal Data, or opt into third party marketing communications.

Use of our Sites and Platform

We process Device/Network Data, Contact Data, Identity Data, and Inference Data when you access and use our Services. We use this Personal Data as necessary for the Services including but not limited to:

  • improving our Services (e.g., keeping you logged in and delivering pages; monitoring navigation patterns to make improvements);
  • ensuring the security of our Services and other technology systems; and
  • delivering messages to partners, mentors, and user groups at your request.

Except as described in the Cookies and Similar Technology section below, we do not sell, or “share” Personal Data collected in this context.

Cookies, Similar Technologies, and Social Networking Services

We process Identity Data, Device/Network Data, Contact Data, Content, and Inference Data you agree to share when you connect with social networking services (“SNS”) through our Services. We process this data to add information to your account/profile and populate your bio for Events. You may revoke our access to this information at any time by amending the appropriate account settings on the SNS.

Further, we process Identity Data, Device/Network Data, Contact Data, and Inference Data, in connection with our use of cookies and similar technologies on our Sites. We and authorized third parties may use cookies and similar technologies for the following purposes:

  • For “Essential” purposes - to provide you with the Services and enable use of its features (e.g. to keep you logged in as you navigate between web pages).
  • For “Functional” purposes – to provide you with features or functionality of the Services (e.g. to allow a customer to maintain an online shopping cart).
  • For “Analytics” purposes – to help us operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
  • For “Advertising” purposes - to enable “retargeting” and other forms of Targeted Advertising.
  • For “Social Media” purposes - to allow you to share information using a social media sharing button or “like” button on our Sites, link your SNS account to the Services, or engage with our content on or through a SNS. The SNS may record that you have done this and may collect additional Personal Data about you or link it to other Personal Data they hold about you, as described further by the SNS. Please see the applicable SNS privacy policy for more detail.

Personal Data processed for purposes of Targeted Advertising and SNS may involve a sale or "sharing" of Personal Data.

Marketing Communications

We, our third-party partners, mentors, and members of the PNF network process Identity Data Contact Data, Device/Network Data, Biographical, and Inference Data to send you updates, newsletters, surveys, offers, and other promotional materials. Where allowed by law, or with your consent, you may receive marketing communications if you request information from us, register on our Site, or participate in our surveys, promotions or events.

We process this Personal Data to contact you about relevant products or services and for our Business Purposes. We may tailor marketing communications based on your Profile, publicly available information, or information obtained through the PNF network, Events you have attended, or your participation in PNF Services. You will have the ability to opt out of such communications.

Support

When you contact us through the Services for support, we process Identity Data, Contact Data, and Content. If you call us, we may collect Audio/Visual data from the call recording (subject to any required consents).

We process this Personal Data to respond to your request, and communicate with you, as appropriate, and for our Business Purposes. If you consent or if permitted by law, we may use Identity Data and Contact Data to send you marketing communications and for our Commercial Purposes. We do not sell or “share” Personal Data collected in this context.

Feedback and surveys

We process Identity Data, Contact Data, Preference Data, and Content collected in connection with Event or partner surveys or questionnaires. We process this Personal Data as necessary to respond to guest requests/concerns, for our Business Purposes, and other legitimate interests, such as:

  • analyzing participants experiences satisfaction; and
  • to allow our corporate partners to communicate with participants.

We may share Feedback/Survey data relating to third party partners with those partners, who may use it for their own purposes. We do not sell or “share” Personal Data collected in this context.

Business Purposes

If you use our Services, we will process your Personal Data you give us or that we receive from relevant parties as necessary or appropriate for us to provide those Services. For example, we may process your Personal Data as follows:

  • Service Provision: to operate, administer, and deliver our Services such as showing content, processing transactions, and authenticating users.
  • Account Management: to create and manage your account, including sending you service announcements, updates, security alerts, and support messages.
  • Internal Processing and Service Improvement: to improve the design of our Services, understand how our Services are used, for internal research, technical or feature development, debugging, audits, customer service use, and similar purposes.
  • Compliance, Fraud Prevention, and Safety: to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) detect security incidents, and (e) protect against and respond to deceptive, fraudulent, or illegal activity.
  • Personalization: to personalize our Services such as but not limited to displaying (i) your name, (ii) preferences, and (iii) content you have interacted with in the past or that we think may be of interest to you based on past interactions with our Services.

Commercial Purposes

We and certain third parties process Personal Data to further our commercial or economic interests (“Commercial Purposes”) depending on the context of collection and your rights and choices. For example, we may process your Personal Data as follows:

  • Customer Profiles: to create profiles for individuals that may be interested in our Services, programs, local events, and attendance at other similar events.some text
    • We may personalize marketing communications based on your Profile. If applicable law requires consent to Consumer Profiling or Targeted Advertising, we will seek your consent.
  • Targeted Advertising, Data Sharing, Data Sales: We engage in retargeting and interest-based advertising  ("Targeted Advertising") on our Sites, which may be a sale, "sharing" of Personal Data, or use for Targeted Advertising under applicable law. This form of advertising involves various parties and service providers, including third party data controllers, engaged in the processing of Personal Data to deliver and tailor ads you see. These parties may collect Personal Data such as unique IDs, IP addresses, device information, OS/browser type, and other similar data, as well as information about the ads you see and view to develop and assess aspects of a profile about you to deliver more relevant advertisements and offers, and determine whether and how ads you see are effective, or can see advertisements from us on other websites. These third parties may augment your profile with demographic and other preferences data derived from these observations, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or service you were shown in an advertisement. These parties may be able to identify you across sites, devices, and over time. You can control how these third parties use your data, and the ads you see on these platforms, using the tools described in the Your Rights and Choices section below.

DISCLOSURE OF PERSONAL DATA

We may disclose Personal Data with the following recipients:

  • Advertisers, and Social Media Platforms: - We may share certain Personal Data with social media platforms and advertisers that act as service providers in support of our Business Purposes and Commercial Purposes. We may allow these third parties to operate through our Services.
  • Affiliates: We may disclose your Personal Data to our parent company, subsidiaries, joint ventures, or other corporate affiliates for purposes consistent with this Privacy Policy.
  • Business Transfers: We may sell, transfer or otherwise share some or all of our business or assets, which may include your Personal Data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
  • Legal Disclosures: PNF may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • Partners, Mentors and User Groups: We may disclose your Personal Data to our partners, mentors, and other groups with whom we have contracted to sponsor and deliver industry-focused accelerator and startup programs, and to other users of our Services, for the purpose of providing our products and services, including sharing with other members of the groups for which you are registered (e.g. founders, mentors). For example, when you participate in an accelerator program, we may share your Personal Data with the identified accelerator partners to organize and deliver the accelerator. Also, when you register for an event through our Services, we may share your Personal Data with the Event organizers and sponsors in order to communicate with you about the Event. Finally, you may request to join certain programs, initiatives, projects, or promotional opportunities operated by or in connection with third parties where we will share your information with the parties you choose or that operate the relevant program.
  • Professional Advisors: We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
  • Service Providers: We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, and email delivery and database management services). We may also disclose your data in connection with certain other business and operational purposes, such as data security monitoring, service analytics, internal research, quality control, etc. We generally share your Personal Data as you request, or in accordance with certain business purposes.

SECURITY AND RETENTION

Security. Please be aware that, despite our organizational, technical, and physical measures to protect the Personal Data we collect, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

Retention. We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider, for example, the amount nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through outer means, applicable legal requirements, industry best practices, IT systems design, and relevant costs.

Anonymized, Aggregated, and Deidentified Data. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you. We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.

CHILDREN’S PRIVACY

Children under the age of 18 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. Ifw e become aware about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us using the contact information below.

CONTACT US

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at legal@pokt.foundation, or write to us at:

Pocket Network Foundation

P.O. Box 31489

2nd Floor Whitehall House

238 North Church Street

George Town, Cayman Islands, KY1-1206

Your Rights and Choices

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. See the following sections below for more information regarding your rights/choices in specific regions: 1) US States/California; and 2) EEA/UK/Switzerland.

Your Rights

You may have certain rights and choices regarding the Personal Data we process. See the “Regional Supplements” section below for rights available to you in your jurisdiction. To submit a request, contact our Data Privacy Team. We verify your identity in connection with most requests, as described below. All account holders may review, update, correct, or delete the Personal Data in their registration profile by logging into their account. You may also contact us at legal@pokt.foundation to submit requests or if you have any questions.

Verification of Rights Requests

If you submit a request, we must verify your identity to ensure that you have the right to make that request, reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. We may require that you match personal information we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Personal Data to you if prohibited by law.

Your Choices

  • Email communications. You may opt out of newsletters and marketing-related emails from us by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at legal@pokt.foundation. You may continue to receive transactional and other non-marketing emails. If you authorized the sharing of your contact information with a third party, contact that third party directly to opt out of receiving any communications they may send.
  • Withdrawing consent. If you gave us consent to use your Personal Data, but wish to update or delete it, please contact us at legal@pokt.foundation.
  • Cookies and similar technologies. You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies or similar technologies, you may not be able to use certain features or services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site. You may opt out of other third party technologies directly via the third party, or you may use our cookie management system. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.
  • Do Not Track Signals. Some Internet browsers may support “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
  • Retargeting and Behavioral Advertising. When we share your information with third parties for retargeting purposes, or for behavioral advertising, you have a right to revoke your consent (if provided) or otherwise opt-out of such services. Where a third party processes data on our behalf, (e.g. Custom Audiences, or Customer Match) you may contact us to opt out. However, to the extent the third party processes your information for its own purposes, you should opt out with that third party directly. You can control your Facebook (and Instagram) privacy settings here, Google’s ad settings here, and LinkedIn’s privacy settings here. You may also opt out of Targeted Advertising/”sharing” using our cookie management system, or by enabling the Global Privacy Control (e.g. through your browser or a browser extension).
  • User Generated Content. We may make available through our Services features that allow you to share information online (e.g., message boards, chat areas, file uploads, and events). Please be aware that whenever you voluntarily disclose Personal Data online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, or dissemination of such publicly disclosed Personal Data.

REGIONAL SUPPLEMENTS

  1. California’s Consumer Privacy Act

Under the California Consumer Privacy Act  as updated(“CCPA”) and other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.

  • Confirm:  Right to confirm whether we process your Personal Data.
  • Access/Know: Right to request any of following: (1) the categories of Personal Data we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/shared your Personal Data; (4) the categories of third parties to whom we have sold/shared your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
  • Portability: Right to request that we provide certain Personal Data in a common portable format.
  • Deletion: Right to delete certain Personal Data that we hold about you.
  • Correction: Right to correct certain Personal Data that we hold about you.
  • Opt-out: Right to opt-out of the following: some text
    • If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
    • If we engage in Targeted Advertising (aka "sharing" of Personal Data or cross-context behavioral advertising), you may opt-out of such processing.
    • If we engage in certain forms of profiling, you may opt-out of such processing using our cookie management system, or by enabling the Global Privacy Control (e.g. through your browser or a browser extension).
    • The processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data. some text
      • This right does not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.
  • Opt-in/Opt-out of Sale/Sharing of Minors’ Personal Data: To the extent we have actual knowledge that we collect personal information of a minor under age 16 in California, those minors must opt in to any sales/sharing of personal information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales/sharing of personal information. All minors have the right to opt-out later at any time. We do not have actual knowledge that we process the personal data of minors under age 16.
  • Non-Discrimination: California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
  • List of Direct Marketers: California residents may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
  • Remove Minors’ Content: Residents of California under the age of 18 can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through the Services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, contact us using the information below. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the Services.

Business Purposes. For purposes of the CCPA, we have disclosed to Service Providers for “business purposes” in the preceding 12 months the following categories of Personal Data, to the following categories of recipients:

  • Category of Personal Data: Audio / Visual Data, Biographical Data; Contact Data; Content; Device / Network Data, Identity Data; Inference Data; Transaction Data
  • Category of Recipients: Partners; Mentors and User Groups; Affiliates; Legal Disclosures; Business Transfers; Service Providers & Business Purposes; Advertisers, and Social Media Platforms
  • Category of Personal Data: Payment Data; Government ID Data; Sexual Orientation; Race or Ethnic Origin. Category of Recipients: Partners; Affiliates; Legal Disclosures; Business Transfers; Service Providers & Business Purposes

Commercial Purposes. For purposes of CCPA, we have "sold" or "shared" in the preceding 12 months in the following categories of Personal Data, to the following categories of recipients:

  • Category of Personal Data: Biographical Data; Contact Data; Device/Network Data; Identity Data; Inference Data; Transaction Data
  • Category of Recipients: Sponsors, Advertisers, and Social Media Platforms

Sensitive Personal Data. For purposes of CCPA, we may have used or disclosed the following categories of Sensitive Personal Data: Government ID Data; Payment Data; Race or Ethnic Origin; and Sexual Orientation.

Submission of Requests. If you have any requests. Questions, or wish to appeal any refusal to take action in response to a rights request, please contact us at: legal@pokt.foundation.

California’s Shine the Light Law. California Civil Code Section 1798.83 permits California residents to request and obtain a list of what personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.  Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to: legal@pokt.foundation.

  1. EEA/UK/Switzerland

Controller & Representative. PNF is the controller of your Personal Data for purposes of European data protection legislation. To contact us in the European Union for purposes of Article 27 of EU GDPR you may email legal@pokt.foundation with the subject line “Article 27 Correspondence.” Alternatively, you can contact us at:

Pocket Network Foundation

P.O. Box 31489

2nd Floor Whitehall House 238

North Church Street George Town,

Cayman Islands, KY1-1206

International Data Transfers. Your information, including Personal Data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. Whenever we transfer your Personal Data out of the EEA/UK/Switzerland to countries not deemed by the European Commission to provide an adequate level of Personal Data protection, the transfer will be subject to one of the following safeguards:

  • The Standard Contractual Clauses;
  • Certifications recognized by the European Commission or ICO (as appropriate); or
  • Binding Corporate Rules that have been approved by the European Commission/ICO and deemed to ensure that a given processor or controller provides adequate protection of data.

If none of these transfer bases are available, we may transfer subject to appropriate derogations under applicable data protection law. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA/UK/Switzerland, including the then-current transfer basis used to authorize transfers to specific third parties.

Data Privacy Framework. PNF complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. PNF has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. Our affiliated entities as follows also adhere to the EU-U.S. DPF Principles in accordance with their compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF: PBTS LLC and TS Startup LLC. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit **https://www.dataprivacyframework.gov/**.

We are responsible for the processing of Personal Data received under the DPF and subsequent transfers to third parties acting as agents on our behalf. PNF complies with the DPF Principles for all onward transfers of Personal Data from the EU and the UK, including the onward transfer liability provisions. With respect to Personal Data received or transferred pursuant to the DPF, PNF is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. We commit to cooperate with the EU or UK data protection authorities and comply with advice given by such authorities with respect to any human resources data transferred from the EU or UK in the context of the employment relationship. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, PNF commits to resolve DPF Principles-related complaint about our collection and use of your Personal Data. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact PNF at legal@pokt.foundation. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, PNF commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction please visit **https://www.jamsadr.com/DPF-Dispute-Resolution** for more information or to file a complaint. Such services of JAMS shall be provided at no cost to you.

In addition, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, PNF commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Officer (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU- U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship. Under certain conditions, more fully described on the DPF website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Legal Bases for Processing Personal Data

  • Legal Basis: Performance of a contractsome text
    • Description of Basis & Relevant Purposes: The processing of your Personal Data is strictly necessary in the context in which it was provided, e.g. to perform the agreement you have with us, to provide products and services to you, to open and maintain your user accounts, to deliver ticket you have purchased, or process requests.
    • Relevant Contexts some text
      • Contexts where Personal Data (excluding Sensitive Personal Data) is processed for purposes listed below.
      • Cookies and other tracking technologies as described above.
    • Purposes: The provision of the Services.
    • Disclosures: Partners, Mentors, User Groups, and Professional advisors
  • Legal Basis: Legitimate interestssome text
    • Description of Basis & Relevant Purposes: This processing is based on our legitimate interests. For example, administering, analysing, and improving our Services. See the Business Purposes of Processing section above for more information regarding processing performed based on our legitimate interests.
    • Contexts: where Personal Data (excluding Sensitive Personal Data) is processed for specified legitimate interests or purposes listed below
    • Purposes: Internal Processing and Service Improvement; Security and Incident Detection; Personalization; Aggregated Data; Profiles; and Personalized Marketing Communications.
    • Disclosures: Affiliates; Service Providers; Advertisers and SNS platforms; Business Transfers; and Legal Disclosures.
  • Legal Basis: Consentsome text
    • Description of Basis & Relevant Purposes: This processing is based on your consent. You are free to withdraw any consent you may have provided, at any time, subject to your rights/choices, and any right to continue processing on alternative or additional legal bases. Note: Withdrawal of consent does not affect the lawfulness of processing undertaken prior to withdrawal.
    • Contexts: Cookies and other tracking technologies (except strictly necessary); Processing of Sensitive Personal Data; and Marketing communications.
    • Purposes: Targeted Advertising.
    • Disclosures: Partners, Mentors and User Groups; Professional Advisors; and Advertisers, and SNS platforms.
  • Legal Basis: Compliance with legal obligationssome text
    • Description of Basis & Relevant Purposes: This processing is based on our need to comply with legal obligations. We may use your Personal Data to comply with legal obligations and process. See the Disclosure of Personal Data section above for more information regarding the nature of processing performed for compliance purposes.
    • Business Purposes: Compliance; Fraud Prevention; and Safety.
    • Disclosures: Legal Disclosures.
  • Legal Basis: Performance of a task carried out in the public interestsome text
    • Description of Basis & Relevant Purposes: This processing is based on our need to protect recognized public interests. We may use your Personal Data to perform a task in the public interest or that is in the vital interests of an individual. See the Disclosure of Personal Data section above for more information regarding the nature of processing performed for such purposes.
    • Business Purposes: Compliance; Fraud Prevention; and Safety.
    • Disclosures: Legal Disclosures

Your Rights

While applicable law may provide exceptions and limitations to all rights, residents of the EEA, UK, and Switzerland have the following rights:

  • Access: You may have a right to access the Personal Data we process.
  • Rectification: You may correct any Personal Data that you believe is inaccurate.
  • Deletion: You may request that we delete your Personal Data. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you.
  • Data Export: You may request that we send you a copy of your Personal Data in a common portable format of our choice.
  • Restriction: You may request that we restrict the processing of Personal Data to what is necessary for a lawful basis.
  • Objection: You may have the right under applicable law to object to any processing of Personal Data based on our legitimate interests. some text
    • We may not cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests.
    • In addition to the general objection right, you may have the right to object to processing: for Profiling purposes; for direct marketing purposes (we will cease processing upon your objection); and involving automated decision-making with legal or similarly significant effects (if any).
  • Regulator Contact: You have the right to file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority. You can find your data protection regulator here.

Submission of requests. You can submit these requests by email to legal@pokt.foundation or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Data or response to your requests regarding your Personal Data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

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