Privacy Policy

1. WHO WE ARE

Stratis Group Ltd. (“Stratis”, “we”, “us” or “our”) runs a blockchain development platform, offering solutions for testing and deploying blockchain applications (the “Services”). For more information about Stratis, please visit our website: https://www.stratisplatform.com/. To contact us, please use the following information:

Data protection officer: Krushang Patel
 Email address: [email protected]
Postal address: New Derwent House, 69-73 Theobald’s Road, London, England, WC1X 8TA
Telephone number: 020 7788 7783

2. PURPOSE OF THIS PRIVACY POLICY

We are committed to protecting and respecting the privacy of those who visit www.stratisplatform.com (the “Website”) and those who use, or who may in the future use, our Services (“you” or “your”). This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint. For the purpose of data protection legislation in the UK, we are the controller of personal data.

3. THE DATA WE COLLECT ABOUT YOU

When you access the Website or use our Services, you may provide us with personal data, and we may collect, use, store and transfer such personal data which we have grouped together as follows:

- Identity data including your first name, last name, title, username or other identifier;
-  Contact data including your residential address, billing address, delivery address, email address, telephone numbers;
- Financial data including your bank account and payment card details;
- Financial data including your bank account and payment card details;
- Technical data including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other details about the devices you use to access this Website;
- Usage data including information about how you use our Website and Services; and
- Marketing and communications data including your preferences in receiving marketing material from us and third parties and your communication preferences.

4. HOW YOUR PERSONAL DATA IS COLLECTED

We collect your personal data in different ways, including:

-  Direct interaction with you. You may give us identity and contact data by filling in forms on our Website or by communicating with us by post. This includes data you provide when you purchase our products or Services and use interactive features on our Website or social media applications.
- Automated technologies. When you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites using our cookies. Please see below for more information about cookies.
- Third parties and publicly available sources. We may receive personal data about you from other people and/or from public sources, as set out below:
  - technical data from analytics providers such as Google; and
  - identity and/or contact data from our partners such as Microsoft Azure Marketplace.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Our most common uses of your personal data will be:

- in order for us to perform a contract we are about to make or have made with you (or to take steps at your request before entering such a contract);
- if it is necessary for our legitimate interests and your interests and rights do not override those interests; and/or
- in order for us to comply with a legal or regulatory obligation.

The table below sets out all the ways in which we plan to use your personal data, which of the legal bases we rely on to do so and, where relevant, what the legitimate business interests are. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

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6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

When using the Website and/or our Services, we may need to disclose your personal data to selected third parties in the following limited circumstances:

- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency;
- in the event that we sell any part of our business, in which case we may disclose your personal data to the prospective buyer of that part of our business to the extent that such disclosure is directly relevant to the sale; and
- third party service providers which provide us with services, including IT providers, hosting service providers, analytics (and website analytics) providers, anti-money laundering and client verification providers, debt collection agencies, credit checking companies event hosting companies and marketing providers;

7. INTERNATIONAL TRANSFERS

You acknowledge that by posting or uploading any content on our Website, including any content you publish on our Website, that such content will be viewable and available worldwide by other users who view our Website.

Many of the third parties with whom we work are based outside both the United Kingdom (UK) and the European Union (EU), so their processing of your personal data may involve a transfer of this data outside both the UK and the EU. When we use cloud-based platforms to store personal data, this may involve the use of geographically-distributed data centres including data centres outside both the UK and the EU. You have the right to request copies of the transfer mechanisms that apply to your personal data by contacting us using the details above. We will not transfer your personal data outside the EU, except:

- To a country which has been found by the European Commission to provide an adequate level of protection, which can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personaldata-non-eu-countries_en;
- To an entity in the United States which is part of the EU-US Privacy Shield;
- To a company which has agreed to follow the same rules when processing your personal data;
- Where your personal data benefits from the same contractual protections as it would in the EU;
- Where the transfer is necessary to perform a contract between us; or
- With your explicit consent.

We are a multinational company and therefore when providing our Services there may be occasions when your Personal Data may be accessed by us outside of the European Union. Such access will always be subject to our physical, technical and organisational measures detailed in paragraph 10 below.

8. COOKIES

A cookie is a small file, typically of letters and numbers, placed on a computer or mobile device (“Device”) that uniquely identifies your browser or Device when you visit a website. Cookies collect information to help identify you, your Device, your use of the website and/or your general internet usage.

You can set your browser to refuse some or all browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or may not function properly.

We use the following categories of cookies:

(a) Strictly necessary cookies: These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to load webpages.

(b) Analytical/performance cookies: These cookies allow us to recognise and count the number of visitors to our Website and to see how visitors move around our Website. This helps us to improve the way our Website works, for example by ensuring that visitors can easily find what they are looking for.

(c) Targeting cookies. These are cookies that are placed by third party service partners, including advertising partners, to improve the relevance of the information we present on the Website to our users. The information collected by these cookies can be shared with other organisations outside Stratis. We have no control over these third-party cookies.

More information about the individual cookies we use and the purposes for which we use them is set out in the table below:

9. OUR WEBSITE AND THIRD PARTY WEBSITES

This Website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy policies. When you leave our Website, we recommend that you read the privacy policy of every website you visit and every plug-in or application you use.

10. DATA SECURITY

We have appropriate physical, technical and organisational security measures in place to safeguard your personal data, and protect it from being accidentally or unlawfully destroyed, lost or altered, or disclosed or accessed in any unlawful way. We limit access to your personal data to those who have a genuine business need to know it, and those processing your information will do so only in an authorised manner.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We store your personal data in line with legal, regulatory, financial and good-practice requirements. If you would like to find out more about how long we store your data for, please get in touch using the contact details above.

11. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you may have the following legal rights:

- to access personal data held about you;
- to request us to make any changes to your personal data if it is inaccurate or incomplete;
- to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
- to receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
-  to object to, or restrict, our processing of your personal data in certain circumstances;
-  if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
- if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
- to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
- to lodge a complaint with a data protection supervisory body. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/, although we would like the prior opportunity to respond to any complaint.

To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us using the contact details above.

12. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA

If you have any questions, comments and requests about this Privacy Policy or your personal data, please contact us using the contact details above. Please notify us with any changes to your personal data at any time.

13. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to this Privacy Policy in the future will be posted on www.stratisplatform.com. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

This Privacy Policy was last updated on 8 November 2021.