Introduction

At Blockbonds we are deeply committed to respecting the privacy of our Customers. We ensure that your data is safe by using sophisticated security measures. We want to make sure that you understand the information we set out here.

By creating an account in the SPENN Agent Application and accepting the Terms & Conditions, you consent to Blockbonds collecting and storing your data, which are necessary to provide you with the services of your choice. This Privacy Policy governs the collection, storage, and processing of your data.

This policy applies to your use of all our services and products. Your personal information is kept in our business records only for as long as it is needed to provide you with our services, and afterwards, only as it is required for tax or other legal obligations.

We reserve the right to update this policy from time to time. In case our Privacy Policy will be updated, we will notify you of such updates.

Scope

The policy applies to all SPENN Agent Application users and SPENN Customers and it covers all matters that are related to how we collect, use, share and protect your data. All our partners with whom we share your information must meet the requirements set out in this policy. We explain how we share data in further chapters of this document.

Collecting Information

To deliver to you our services we may collect your personal information, such as your name, address, personal number, telephone number, and e-mail address that you provide to us while creating your SPENN Agent account. We also collect your IP address, transaction history, information about the device you use to utilize our services, the name of the WEB browser you use, your location information or your user behaviours.

Most of the information listed above and any other information that you provided us with can be accessed via your SPENN Agent Account by clicking on your profile.

We collect this information when you download the SPENN Agent Application, during the registration process when you subscribe to our newsletter or from public sources.

The Controller of your data, that is, the entity that decides how your data will be used is:

Blockbonds AS, a Norwegian registered limited company, with company nr 915 912 028, registered office address: Andoyfaret 33D, 4623 Kristiansand, Norway. Blockbonds AS is the owner of the source code and all intellectual property rights of the SPENN Agent Application, that you download to your mobile phone.

If you have any questions regarding this privacy policy or our processing of personal data or want to contact us regarding your data, please contact [email protected].

The reason we collect this information is to enable you to use our services, but also to make your user experience as good as possible. Thanks to this data, we can comply with all the relevant legal requirements that govern our relationship with you, as well as customize our services to match your needs, respond to your questions, ensure the safety of all our Agents and Customers, and the integrity of our product.

We collect and process your data to:

provide you with the online services of your choice, including sending and receiving funds.

• ensure that transactions are performed smoothly, and provide troubleshooting services.
• realise Agent transactions and maintain records of sales.
• enable Customers and other Agents to contact you [TM1] [MH2]
• make it possible for us to answer your questions and requests or contact you regarding the services that we provide.

Additionally, we are obliged to collect and store your data, including your transaction data, for security reasons, in accordance with the Anti-Money Laundering and Counter-Terrorist Financing laws (AML/CTF) that are in force in the country you reside.

We also collect and process your data according to our legitimate interest, especially to:

ensure the security of our services, adherence to our internal procedures, and prevention of fraud and other financial criminal activities.

• analyse the functionality of our services and the SPENN application, and tailor them to the specific needs of our Agents.
• resolve Agents and Customers queries, especially those sent to our Customer Service Teams.
• perform statistical analyses.
• for archiving and auditing purposes.
• to ensure compliance with local and global laws and regulations.

Only if you agree to it and based on your consent, can we retrieve the information from cookies and other tracking technologies to assist with navigation and your ability to provide feedback, analyse your use of our products and services, assist with our promotional and marketing efforts, and provide content from third parties.

If you do not provide us with the required information, we will unfortunately not be able to provide you with our services or parts of our services.

You have the right to access your data and correct them, if necessary, by contacting us through the email below and describing the nature of your request. Please note, that you may also view part of your data in the SPENN application under the “Me” tab. You can also modify your data, but this may require further authentication to be completed.

Your rights according to your data

We guarantee that we adhere to the requirements of the data protection regulations, including GDPR and we will proceed with any request that stems from your rights, namely the right to access, rectify your data, right to be forgotten, right to data portability, right to object and automated individual decision making, right to restriction of data processing, right to refuse further data processing and right to information, in line with the corresponding laws and regulations imposed on us by authorities of the country you reside.

You can exercise these rights when:

according to data rectification – you find out that your data are incorrect or incomplete

• according to data rectification – you find out that your data are incorrect or incomplete
• according to data erasure – where one of the following grounds applies:
  1. Personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
  2. You withdraw consent on which the processing is based or object to further data processing, where there is no other legal ground for the processing or no overriding legitimate grounds for the processing.
  3. The personal data have been unlawfully processed.
  4. The personal data must be erased for compliance with a legal obligation in the law to which we are subject.
  5. The personal data have been collected according to services and it is data of a child.
• according to restrictions of data processing, where one of the following applies:
  1. You contest the accuracy of data, for a period enabling us to verify the accuracy of the personal data.
  2. The processing of the data is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead.
  3. We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
  4. You object to the processing of data, pending the verification of whether our legitimate grounds for processing override yours.
• according to the right to data portability (in other words the right to receive the personal data, which you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance from us), where you gave us consent to your data processing or we have a contract that allows the data processing and the processing is carried out by automated means.

You also have the right to lodge a complaint on the way we process your data to the supervisory authority:

The Norwegian Data Protection Authority (Datatilsynet)

P.O. Box 8177 Dep., 0152 Oslo

[email protected]

+ 47 22 39 69 00

Sharing Information

We do not sell the personal information of our Customers, and we do not share your personal information with any other companies without your consent, for reasons other than delivering to you our services. We share your information with other companies that assist us in performing services for you, solely for this purpose, including consulting, and auditing. In such cases, we require full compliance with our Privacy Policy, so that your data are treated with the same standard of safety at all times. Those companies may be located outside your jurisdiction, but your data is protected by our contracts with them. Please note the government authorities of those jurisdictions may have access to your data. We may also release your personal information if we are required, to comply with the legal requirements, court orders, or to defend our or other’s legal rights or safety.

We may share, also without payment, anonymous, non-personally identifiable information with third parties for marketing or advertising purposes, but only if we receive your consent to do so. This means that your data may be automatically processed, including profiling. However, this does not cause you any legal effects or significantly influence Your situation.

Your personal information may also be shared and transferred due to company’s acquisition, merger, receivership proceeding, insolvency or bankruptcy proceedings and the like.

By registering as a SPENN Agent, you may be visible on the map built into the SPENN Agent Application, so that our Customers can see your location and contact you. This means some of your data (phone number and business name, current location) will be visible to SPENN Customers. Only in this way, the trustful network of SPENN Agents can be built. If you do not share your data, you will not be able to provide the Customers with SPENN financial and non-financial services.

Your name will also be visible to Customers, who types-in your phone number as a recipient of the transfer/request for transfer. This is to make sure that the Customers always send funds to the correct person, as our transactions are non-reversible.

Safety of Information

We implemented an internal data security policy together with our technical solutions and the professionalism of our staff to significantly mitigates the risk of loss or disclosure of, as well as unauthorised access to your data. The implemented safeguards are subject to legal requirements that we are bound by and that we strictly comply with.

The history of your transactions is secured by blockchain technology that provides an indelible and transparent record of transactions.

We store your data for as long as this is required by Anti-Money Laundering and Counter-terrorist Financing (AML) and Know Your Customer (KYC) laws and regulations, both characteristic for financial and tax services.

The following must be retained for all transactions for:

• Identification of Agents – full details of evidence of identity for a minimum of 10 years from the end of the relationship with the Customer.
• Transactions – full details of the transaction for a minimum of 10 years from the date the transaction was completed.

This may change, when the regulations according to the AML and KYC (both on the local and global scale) change.

Links to Other Websites

We may at our discretion include the links to third party websites that are not covered by this Privacy Policy. Please make sure to review their policies in this matter. Please be advised that those websites may place their cookies and collect data from you.

Phishing

We would like to draw your attention to the threat of phishing. This is an unlawful practise of creating “phishing” websites that imitate legitimate websites in order to steal sensitive personal or financial information. The link to such fake websites is usually a part of an email a person receives that also looks legitimate. Such fake websites can be infected with malware;

you can be asked to enter your personal details that can be a subject of identity theft. If you suspect that the email or any other communication You received may be of this nature that it only imitates Blockbonds/SPENN, please always contact our Customer Service.

Communication

We may provide you electronically with information about your transactions, our products, and agreements between us. You hereby agree to receive such communication electronically. We may also contact you via SMS or phone call on the telephone numbers you provided to us during registration, however not for the purpose of marketing unless we receive your prior written consent.

You can withdraw your consent to receive marketing communication by contacting us on the details below. If you opt-out from receiving the marketing communication, this will not affect communication relevant to your use of the Service.

Blockbonds AS,

Andoyfaret 33D,

4623 Kristiansand, Norway

E-mail: [email protected]

Will this be possible with the App. Agents contacting Agent

Yes

Is this part of the application form?

Nope it’s not