Effective date: 25 May 2018
Table of contents
Definitions and interpretation
Token Group Limited, or us or we
Token Group Limited, a company incorporated in England and Wales with registered number 11098384 whose registered office is at One St Peter's Square, Manchester, M2 3DE;
collectively all information that you submit to Token Group Limited via the Website. This definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (2016/679);
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you
any third party that accesses the Website and is not either (i) employed by us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to us and accessing the Website in connection with the provision of such services; and
the website that you are currently using, tokencard.io, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
the singular includes the plural and vice versa;
a reference to a person includes firms, companies, government entities, trusts and partnerships;
"including" is understood to mean "including without limitation";
reference to any statutory provision includes any modification or amendment of it;
- We may collect the following Data, which includes personal Data, from you:
- Data you provide to us: The types of personal information that we collect directly from you may include:
- Contact Information such as email addresses and telephone numbers.
- Data from Website use: The Website automatically collects information about how you and your device interact with it, including:
- IP address (automatically collected);
- Web browser type and version (automatically collected);
- Operating system (automatically collected);
- A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
Our use of Data
For purposes of the General Data Protection Regulation (2016/679), Token Group Limited is the "data controller".
We will retain your personal Data for as long as necessary to provide the communication service and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or subsidiaries and / or associates.
All personal Data is stored securely in accordance with the principles of the General Data Protection Regulation (2016/679). For more details on security see the clause below (Security).
General Data Protection Regulation (2016/679) says that we can only use your personal information if we have a proper reason to do so. This includes sharing your data with third parties.
Any or all of your Data may be required by us from time to time to provide you with the best possible service and experience when using our Website. Specifically, Data may be processed by us for the following reasons:
Improvement of our products / services;
Transmission by email of promotional materials that may be of interest to you;
Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
Administer your interaction with us;
Responding to your enquiries;
Provide you with information about us;
Notify you about changes to our terms and conditions;
For research and statistical analysis;
Carrying out marketing activities;
To communicate with you via social media or through our community;
To respond to your complaints and seek to resolve them;
Grounds for processing
- When we collect from you any personal information within the scope of GDPR, we do so (a) with your consent; (b) where necessary for our compliance with a legal obligation; and/or (c) as necessary to fulfill our legitimate interests as described below, except where our interests are overridden by your privacy rights. Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you have the right to object.
- Our legitimate interests are to carry out marketing activities and communicate with you via social media or through our community.
Third party websites and services
- We may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by you when you use this Website.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Controlling use of your Data
Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include but is not limited to the following:
use of Data for direct marketing purposes; and
sharing Data with third parties.
The General Data Protection Regulation (2016/679) provides you other rights over your data including:
the rectification or erasure of personal data
the restriction of processing
the right to data portability
the right to object and automated individual decision-making
the right to object
Functionality of the Website
- To use all features and functions available on the Website, you may be required to submit certain Data.
Accessing your own Data
- You have the right to ask for a copy of any of your personal Data held by us (where such Data is held) free of charge, unless the requests are repetitive or excessive in which case a reasonable administrative charge may be requested. If you wish to exercise this right please contact us at the address included in this policy (Contact us).
- Data security is of great importance to us and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
- If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
- We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
Transfers outside the European Economic Area
- Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
- We may transfer your personal information to countries outside of the EEA (such as the United States of American) to carefully selected business partners that meet our standards. We do this for our data management and business purposes, in particular, for outsourced data processing by organisations on our behalf. We take reasonable steps to ensure your information is adequately protected. If you do not agree to this procedure you should not use our services.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- You may contact us by email at [email protected].
How to make a complaint
- We hope that we can resolve any query or concern you raise about our use of your Data but you may also lodge a complaint with the data protection authority in the applicable jurisdiction.
Details of the UK supervisory authority - The Information Commissioner's Office:
- Phone: 0303 123 1113
- Email: [email protected]
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF