Privacy Policy
This Privacy Policy sets out the way in which Humans Token AG (the “Company”, “we” or us““) collects and processes personal data.
When you visit our website [friction.humans.ai] (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information.
This Privacy Policy is designed to inform you about how we collect, use, and share your personal data through our Website or when you interact with us, and we encourage and recommend that you read it in full. We understand that people have busy lives though, and so wanted to help you by providing a brief overview of how and why we process your personal data.
By using our Website, you acknowledge that we will process your Personal Information in accordance with this Privacy Policy, including for the purposes set out in Section 2 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website forms, or otherwise provide us with any of your Personal Information. However, if you do not provide your Personal Information, we may not be able to provide support regarding your queries.
This Privacy Policy is effective from [1 March 2023]. We may change this Privacy Policy at any time, and if we do so will post the changes to this page as well as the date that the changes take effect.
1. HOW DO WE COLLECT YOUR PERSONAL DATA AND WHICH CATEGORIES OF DATA DO WE USE?
1.1. Generally, we collect your data directly from you through the online registration form and subsequent electronic or postal communication. However, it may also be necessary at times to process personal data that we receive from other companies, authorities or other third parties such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties.
1.2. Personal data may include:
- your name and surname
- address, telephone number, email address and other contact data
- date of birth and country of residence
- intent data (or user behavior data)
- Internet Protocol (IP) addresses
- social media profiles, social media URLs and custom profiles
- verification and authentication data (e.g. companies register excerpts, ID data, signature sample, data for due diligence)
- data in the context of our business relationship (e.g. payment data, bank account or cryptocurrency address)
- and other data comparable with the above-mentioned categories
1.3. You always have the choice whether you want to communicate with us by e-mail or by post. For technical reasons, communication via e-mail may be unencrypted.
1.4. We also collect information from you in the course of your use of the Website through cookies and similar technologies:
1.5. We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Website, and to improve your experience.
1.6. We also use information collected through "Cookies" and other similar technologies to detect any abuse of our Website and Services.
1.7. To find out more about "Cookies" and similar technologies please see Section 9 of this Privacy Policy.
1.8. If you do not wish to provide us with your information, that’s entirely your choice. Please bear in mind that if you don’t provide us with the information we require for the reasons we have stated (e.g. entering, executing and terminating a business relationship and for fulfilling related legal obligations, or if it is justified by legitimate interests for us to collect your data), it is unlikely that we will be able to work with you as a business partner.
2. PURPOSE AND LEGAL BASIS FOR PROCESSING
2.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are:
a) To fulfil our contractual obligations
b) To comply with our legal obligations
c) To fulfil our legitimate interests, and/or
d) Based on your consent
| Purpose | Basis for processing |
|---|---|
To ensure that we are able to fulfil our regulatory obligations regarding
your Account, including by verifying the accuracy of any information you
provide us, for due diligence purposes (identification / verification)
|
Necessary to comply with a legal or regulatory obligation
|
To investigate, and assist with the investigation of, suspected unlawful,
fraudulent or other improper activity connected with our Website and
Services.
|
Necessary to comply with a legal or regulatory obligation
|
To set-up, administer and manage your Account and records (including
processing affiliate payments)
|
Necessary for the performance of a contract
|
To receive and respond to your communications and requests, including but
not limited to receiving rewards
|
Necessary for the performance of a contract where such communication relates
specifically to our Services, otherwise consent
|
3. WHO RECEIVES THE PERSONAL DATA YOU HAVE PROVIDED?
3.1. We may, for the identified stated purposes, disclose your Personal Information to any of the following recipients:
a) any company within our Group (including to its employees and sub-contractors) which assists the Company in fulfilling the stated purposes or which otherwise has a need to know such information;
b) any third party which assists the Company in fulfilling the stated purposes, including (but not limited to) providing support through Human Resources, Commercial team, Compliance team or our Information Security team;
c) any third party which assists the Company in verifying the accuracy of your Personal Information;
d) any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising the Company;
e) any law enforcement body which may have any reasonable need to access your Personal Information;
f) any regulatory body or authorised entity which may have any reasonable requirement to access your Personal Information; and
g) any potential purchaser of our business or any investors in it or in any company within our Group (including in the event of insolvency).
4. Transfer of your Personal Information and your express agreement
4.1. The transfer of the your Personal Information may be necessary for using the Services, to provide updates and to respond to your inquiries. As the internet operates in a global environment, the use of the internet to collect and process personal data necessarily involves the transmission of data on an international or cross-border basis. By using the Services or by communicating with us, you acknowledge and expressly consent to the Company’s processing and disclosure of your Personal Information in this way. By using the Website, communicating with us, and using our Services, you provide your express consent to the Company’s disclosure of your personal data to third-party intermediaries (if applicable) for the purposes described in this Privacy Policy.
5. YOUR RIGHTS
5.1. You have the following rights in relation to your Personal Information:
a) a right to access your Personal Information as held by us (also known as a subject access request);
b) a right to receive certain Personal Information in machine-readable format;
c) a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
d) a right to have inaccurate Personal Information rectified;
e) a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent, where you have objected, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;
f) a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
g) a right to complain, if you have any complaints regarding the use of your Personal Information.
h) where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and
i) a right to object to direct marketing, which can be done by opting out of direct marketing via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
5.2. If you would like to exercise any of your rights, then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights; they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
5.3. Where you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
6. RETENTION OF YOUR PERSONAL INFORMATION
6.1. We will retain your Personal Information for the period necessary for us to provide you with our Services and to comply with our legal and regulatory responsibilities. Where it is no longer necessary for us to process your Personal Information, we will delete it. If you request that you should not be able to access our Services, we will retain this information for a maximum of 3 years, from request, before deletion.
6.2. Where we process your Personal Information on the basis of your consent, such personal data will only be processed for the duration of your consent, which you may withdraw or restrict at any time. If you do so, we will stop processing the personal data for which you have withdrawn your consent.
7. SECURITY
7.1. We understand that online security and data protection is an area of vital importance, so it is important for us to have confidence in the security of personal data before a user registers an account. We are actively involved in using security measures to protect information from unauthorised access and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. Our security technology solutions are highly advanced and are managed by a mature framework. Our approach is focused on risk prevention. To help us do this, we adopt robust procedures and technologies to reduce the impact of potential incidents. Because the security of some internet communications is not completely secure, we cannot guarantee the complete security of the information you disclose using your internet connection. You accept the Internet security implications of using the Internet, and the Company will not accept any liability for any direct, consequential, incidental, indirect, punitive or punitive loss or damage resulting from such events
8. CONTACT
8.1. If at any time you believe that we have not adhered to this Privacy Policy, please contact our privacy team at hello@humans.ai.
9. ADVERTISING AND OUR USE OF COOKIES
9.1. We may collect anonymous information about your use of the Website using “cookies”, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of this website. For these purposes, Cookies are placed on your device to identify you in the future when you visit our website or connect with any of our applications.
9.2. The cookies used on this Website are either set by us or by our third-party service providers, and fall into the following categories:
a) Strictly Necessary - these cookies are essential in order to enable you to move around the Website and use its features. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Websites or benefit from all our security features.
b) Performance - these Cookies collect information about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website.
c) Functionality - these Cookies are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our Website to meet your preferences for content layout, text size etc. You can manage these Cookies using your browser settings. However, if you block them we may not be able to offer you certain services that you have chosen.
d) Targeting - these Cookies record the fact that you have visited our Website, including which web pages you have accessed, which device you have accessed them from, and which links you have followed. We use this information to make our Website relevant to your interests and for fraud and website abuse detection purposes, including detecting players who have abused bonus schemes or other promotions.
9.3. Some of these are "session cookies", which stay in place only for the duration of your visit to our website and are deleted at the end of your browsing session. Others are "persistent cookies", which remain on your device for a period of time after you have left the Website.
9.4. Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the 'options' or 'preferences' menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.
9.5. As part of the Website's operation, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website.
9.6. While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.