Last Updated: September 15, 2021
- General Information
1.1 Privacy is of utmost importance at Graphene. We recognize the significance of protecting information which is stored or is intended to be stored on our computers and which relates to an individual. The data we protect (“Personal Data”) is any information relating to an identified or identifiable natural person, sometimes called a data subject. Protecting privacy and the confidentiality of Personal Data is a fundamental component of the way we do business.
- Collection of Personal Data
2.2 When you access and use the Platform or the Services, you do so anonymously without having to provide any Personal Data. Notwithstanding, Graphene may collect Personal Data when (i) you contact Graphene, or request that Graphene contacts you, for any reason, or (ii) you submit your Personal Data to Graphene for any reason.
2.4 Graphene may collect information relating to the general use of the Platform such as errors, log information concerning any errors encountered in the application and other related information relevant to Graphene’s provision of the Services, for the purpose of administration and error analysis to help Graphene improve its Services.
2.5 If you provide Graphene with any Personal Data relating to a third party, by providing such Personal Data to Graphene, you represent and warrant to Graphene that you have obtained the consent of such third party and are authorized by the third party for the relevant purposes.
2.6 You shall ensure that all Personal Data submitted to Graphene is accurate and complete. Please note that failure to do so may result in, amongst others, Graphene being unable to respond to your request.
2.7 You may withdraw your consent at any time after giving reasonable notice by submitting your request to [email protected]. Following the withdrawal of your consent, Graphene shall no longer collect, use or disclose your Personal Data unless consent is again obtained. The withdrawal of your consent may however result in certain consequences. In certain cases, Graphene may not be in the position to continue to provide its Services to you.
- Purposes for Collection, Use and Disclosure of Personal Data
Any collection, use and disclosure of your Personal Data by Graphene shall be for the purpose of providing customer or technical support to you only.
- Disclosure and Sharing of Your Personal Data
5.1 Graphene shall take reasonable steps to protect your Personal Data against unauthorized disclosure.
5.2 Graphene may disclose your Personal Data to third parties (e.g. affiliates, service provides or support agents) who are engaged to provide services to Graphene or who help Graphene in the course of its business operations. In the event Graphene so discloses Personal Data, such third parties will only have access to your Personal Data to the extent necessary to perform their functions and Graphene will conduct oversight over such service providers to ensure the secure management of Personal Data.
5.3 Graphene reserves the right to disclose your Personal Data in compliance with applicable laws and regulations.
5.4 Graphene does not sell your Personal Data to any third parties.
5.5 In the event that Graphene is in possession of any Personal Data, Graphene may transfer, store, process or deal with such Personal Data outside Gibraltar. In doing so, Graphene shall continue to comply with applicable data protection legislation.
5.6 Storage of Personal Data provided to Graphene is stored in accordance with applicable laws of the jurisdiction of the data subject at secure locations in the EU. Graphene has ensured that appropriate security standards are in place regarding the safeguarding, confidentiality and security of data. In regard to data subjects resident in the EU, Graphene, where required, registers with appropriate national data protection / information protection authorities. Graphene also ensures that data is held in a manner that meets the requirements of any national law of any member state of the European Union giving effect to the GDPR. The GDPR provides obligations on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
- Protecting Your Information
6.1 Graphene shall take reasonable steps to secure and protect your Personal Data (if any) in its possession or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, modification, disposal or similar risks to Personal Data.
6.2 Notwithstanding, Graphene cannot ensure the security of the information you transmit to Graphene via the Internet or the Platform, and shall not be liable for any Losses arising from any unauthorized collection, use or disclosure of Personal Data whatsoever.
- Access and Correction
You may request access or make correction to your Personal Data held with Graphene. Graphene reserves the right to charge a fee for processing your request for access, and such fee shall depend on the nature and complexity of your request.
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