Website privacy notice.
Acorn Collective Limited (the “Company”, "we", "us" or "our") respect your right to privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Definitions section to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you make a contribution for an OAK token (the “Token”).
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This version was last updated on 21 May 2018.
We are the data controller and responsible for your personal data.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Our full details are:
You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (the “GRA”), the supervisory authority for data protection issues in Gibraltar. We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact us in the first instance.
The data protection legislation in Gibraltar has been the Data Protection Act 2004 (the “DPA”) and implements Directive 95/46/EC.
On 25th May 2018 Regulation 2016/678 of the European Union on the protection of personal data (“GDPR”) comes into force and will, to the extent that there are GDPR and the DPA (and/ or the DPA has not been amended) replace the DPA.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data as part of our KYC (“know your customer”) requirements by providing such information and completing the forms for our whitelist process.
This includes personal data you provide when you:
We may receive personal data about you from various third as set out below:
We will ensure that the personal information we hold about you is:
We will only use your personal data in accordance with Data Protection Legislation and the Data Protection Principals. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
|Purpose / Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To register you on the whitelist||Identity, Contact||Performance of a contract with you, compliance with a legal obligation.|
|To process your contribution||Identity, Contact, Financial, Transaction||Performance of a contract with you|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise), necessary to comply with a legal obligation|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will only use your personal data for the purposes for which we collected.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
We may have to share your personal data with the parties set out below for the purposes set out in the table:
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do ordinarily not transfer your personal data outside the European Economic Area (the “EEA”).
In circumstances where we do need to transfer any data outside of the EEA we will strive to ensure that the individual or entity receiving the personal data provides an adequate level of protection for that personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In most cases we will aim to keep records of personal data for a minimum of 5 years after the expiry of our contract. However, there may be instances where we are required to keep records for a longer period of time in order to comply with other legal obligations.
You have certain rights in relation to your personal data as summarised here:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may refuse to comply with your request in circumstances where your request is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests as soon as reasonably practicable and, in any event, within 30 days of receipt of the request.
Information which is stored electronically, on a computer, or in certain paper-based filing systems.
For the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
Data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
The people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed.
Those of our employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.
Include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.
Any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.