Privacy policy

This Gate11.io Privacy Policy (“Privacy Policy”) describes how the Company Processes Personal Data. Please read this Privacy Policy carefully before commencing the use of the Platform. If you have any questions relating to Processing of your Personal Data or pertaining to this Privacy Policy, please, contact us at info@gate11.io

Definitions

Other terms used in this Privacy Policy have the meaning described in GDPR.

What types of Personal Data we have and how do we get it?

When you visit the gate11.io, you may provide us with two types of information: personal data that you voluntarily disclose or that is collected on an individual basis; and information collected automatically when you use the gate11.io or our Services including, without limitation, information that we obtain from our partners (collectively, the “Information”). We will only collect and process Information for specified and lawful purposes and only to the extent it is appropriate and necessary for one or more of the purposes outlined in this Privacy Policy, namely for the purpose of providing Services and information about our Services to you and/or to comply with legal and regulatory requirements. You may be asked to provide personal data anytime you are in contact with us. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal data requested, but we may not be able to serve you as effectively or offer you all our Services if you choose not to share certain information with us.

Personal Data

Personal data is any information which is related to an identified or identifiable natural person. This Privacy Policy covers all personal data that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you. Personal data means any information that is unique to you, such as your:

• full legal name, date of birth, age, nationality, gender, signature, utility bills, phone number, email address and home address;

• passport or other photo identification such as a driver’s license or national identification card, other photographs like selfies;

• biometric data for verification and identification purposes;

• user ID, security questions, authentication data, transaction information, financial information, digital currency, or wallet addresses; and other personal data you may choose to provide us.

With your permission, we may also access profiles and other information from services (e.g. Facebook, Twitter, Linkedin, etc.). We may also collect and obtain information about you to comply with our legal obligations, such as anti-money laundering laws. We may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, channel partners, joint marketing partners, and social media platforms. For example, we obtain information about you from public databases and ID verification partners for purposes of verifying your identity when you sign up for our Services or use our Services. Our ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanction lists maintained by public authorities, and other relevant data. Pursuant to applicable data protection laws, our lawful basis for processing such data is compliance with our legal obligations. In some cases, we may process additional data about you to ensure our Services are not being used fraudulently or for other illicit activities. By using our Services or providing us with your personal data, you also expressly consent for us to collect, hold, use and disclose your personal data in accordance with this Privacy Policy and our User Agreement. In addition to providing the foregoing information, if you choose to correspond further with us through e-mail or through the “contact” section of the gate11.io or through events and public social networking platforms, we may retain, use, and disclose the content of your messages together with your user ID and e-mail address and our responses. You are required to advise us of any changes in your personal data that may impact the Services we are providing. From time to time, you may be asked to verify or update your personal data.

Information that is Collected Automatically

When you use the gate11.io or our Services, we automatically collect information from your devices. 

We collect the following information:

• Server Log Information: We collect server log information when you use the gate11.io, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the gate11.io site and the websites you visit just before and just after the Website.

• Device Information: We collect information about the computer or mobile device you use to access the gate11.io, including the hardware model, geo location/tracking details, browser fingerprint, operating system and version, the web browser and version you use, and other device identifiers.

• Telemetry Information. If you use any of our open-source software, we may collect bandwidth download and upload speeds, the amount of free and used storage space on your device and other statistics about your device.

• Usage Information. If you use the gate11.io, we will collect metadata about the files you upload for storage and information about the transactions you make on the gate11.io or with our Services, such as the name of recipients, your name, digital asset amounts, click-stream data, instances in which you have used your private key to authenticate communications and/or the timestamp of transactions.

• Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information when you interact with the gate11.io, including cookies, web beacons and other unique device identifiers. Cookies are small data files that are stored on your device when you visit a website, which enable us to collect information about your device, IP address, web browsers used to access the gate11.io, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.

Legal grounds and purposes of Processing Personal Data 

We only collect and process Personal Data about you where we have legal grounds. Legal grounds include consent (where you have given consent), contract (where processing is necessary for the performance of a contract signed with you), legal obligations applicable to us and our legitimate interests. We are also Processing the Personal Data in order to authorize, provide, control and administer access to the Platform and the services within the Platform; to manage our relationships with you (including in relation to token sale, if such occurs).

Compliance with Legal Obligations

The Company needs to comply with legal obligations. Therefore, we are required to Process Personal Data in accordance with applicable laws. Examples of purposes for such Processing are:

• to comply with rules and regulations relating to accounting, legal investigations, anti-money laundering, etc.;

• to fulfill the obligations of applicable litigation laws.

Legitimate Interests 

The Company Processes Personal Data for our legitimate interests. This Processing is necessary for the purposes of a legitimate interest pursued by the Company, which we have considered outweighing the Data Subject’s interest in protection of the Personal Data. Examples of purposes for such Processing are: 

• to create, develop, operate, deliver, and improve our Services, content, and marketing, to comply with our legal obligations, for anti-fraud purposes and for loss prevention.

• to provide, maintain, deliver or improve the gate11.io or our Services;

• for quality control and staff training including improving our existing Services to ensure we can provide you with the best user experience and accurate information;

• to monitor and analyze trends, usage and activities in connection with the gate11.io, to determine the usefulness or popularity of certain content and to better understand the online activity of users of the gate11.io;

• to ensure our compliance with all relevant legal or regulatory requirements and to meet our regulatory and legal obligations;

• to assess risks including legal and financial risks;

• it is necessary for us to perform a task in the public interest;

• to enforce the terms and conditions of our User Agreement and other agreements we may have with you or third parties including, without limitation, if we believe your actions are inconsistent with our User Agreement, our other agreements or policies;

• it is necessary for, or to protect, our interests, rights, property and safety, or that of others;

• to ensure network and information security including processing your Information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations;

• in accordance with your consent including providing you with the information or products or services that you have requested;

• to monitor and manage the performance of our business operations, to analyze performance and generate internal reports;

• to invoice and process payments;

• to manage, maintain and develop our relationship with you and provide you with customer service including, without limitation, answering your inquiries or responding to a communication from you;

• for research and development purposes including developing new products or services;

• to send you technical notices, support or administrative notifications;

• to facilitate marketing and to communicate with you about news, products, services, events and other information we think will be of interest to you;

• in order to detect, investigate and prevent fraud or other illegal or unauthorized transactions or activities;

• to facilitate the effective management and administration of our business, including in relation to matters such as business planning, budgeting, and forecasting;

• to facilitate reorganization, an asset or business sale, corporate acquisitions, mergers, or other transactions;

• to link, connect or combine Information we collect from or about you with other Information;

  and

• to carry out any other purpose or reason for which the Information was collected, for which we have received your consent or for which we or our third parties have a legitimate interest.

For each of the purposes for which we process information, we rely on the following legal justifications:

• (a) Contractual Necessity – we rely on this justification where we process your personal data in order to discharge contractual obligations we owe you for purpose of service delivery.

• (b) Legitimate Business Interest – we rely on this justification where we need to process your personal data in order to meet our own requirement to operate, manage, and develop our business or to safeguard the legitimate interests pursued by us or by a third party (provided there is a balance between your interests and our interests). A legitimate interest is when we have a business or commercial reason to use your information.

• (c) Legal and Regulatory Requirement – we rely on this justification where we use your Information for the purpose of legal and regulatory compliance. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.

• (d) Legal Proceedings – we rely on this justification where it is necessary to handle your Information for the purpose of obtaining legal advice; in connection with any legal proceeding; or to exercise or defend legal rights in accordance with applicable data protection legislation.

• (e) Consent – we use your Information based on your consent.

Consent 

Some of the data may be Processed based on the Data Subject’s consent, e.g. when you subscribe to our newsletter. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time by contacting us at info@gate11.io

Whom do we disclose the Personal Data?

The Company may share some Personal Data with Recipients, such as competent authorities. The Company does not disclose more Personal Data than necessary for the purpose of disclosure. Recipients may Process the Personal Data acting as Data Processors and/or as Data Controllers. When a Recipient is Processing Personal Data on its own behalf as a Data Controller, the Recipient is responsible for providing information on such Processing of Personal Data to the Data Subject. The Company will never sell or rent your personal data. The Company will only share your Information if and to the extent appropriate or necessary to do so for one or more of the purposes outlined in this Privacy Policy or our User Agreement and will ensure that the sharing of such Information is kept to the minimum necessary. To the extent we share your Information will vary depending on your

circumstances and your relationship with us, but we may share your Information with one or more of the following categories of recipients:

• other members or associates of your organization;

• with our current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices internationally;

• with advisors, sub-contractors, consultants, agents, service providers or other third parties that we have partnered with or perform work for us and those who support our business operations;

• those who provide ancillary services which complement the Services we provide;

• to users of interactive areas of the gate11.io or our social media platforms like our online forums if you choose to share or display your personal data on them publicly, such as your username and any content you post;

• to third parties, advisors, agents and other service providers in connection with a reorganization, change of ownership, merger or transfer of all or part of our assets or business, or if we do a financing or are involved in an acquisition or any other situation where Information may be disclosed or transferred as one of our business assets;

• with government departments and agencies, law enforcement officials, regulators, courts, tribunals or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure or request, or when we believe in good faith that the disclosure of Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, to investigate violations of this Privacy Policy, our User Agreement or any other applicable policies or if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

  and

• with third parties where aggregate Information is disclosed which cannot be reasonably be used to identify you.

We use reasonable efforts to ensure that third parties we partner with are bound by the terms of this Privacy Policy or a similar policy. Your Information may be transferred to or accessed by the recipients described above from countries located anywhere in the world. Such countries may

have different and potentially less stringent standards relating to data protection than your country. In these cases, we will, whenever possible, take all appropriate steps that are within our control to ensure that adequate legal safeguards are in place for your personal data which are shared with such recipients. By using our Services, you consent to your Information being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country. In all such transfers, we may rely on standard contractual clauses and will protect and process your personal data as described in this Privacy Policy.

Social sharing Features

The gate11.io may offer social sharing features, links to social media and other integrated tools. Your use of such features enables the sharing of information with your contacts or the public, depending on the settings you use with the entity that provides the social sharing feature or social media. Please visit the privacy policies of the entities that provide these features to obtain more information about the purpose and scope of data collection and the processing of such data by such entities.

Hyperlinks and Third-party Sites

The gate11.io may contain links to other third-party websites that may collect personal data about you, including through cookies or other technologies. If you link to another website, you will leave the gate11.io and this Privacy Policy will not apply to your use of and activity on those other websites. You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.

Privacy when using Digital Assets and Blockchains

Your transactions involving bitcoin, ether and other digital currency or virtual assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data from such networks.

Online Communication

We require your consent to send you marketing communications (for example: email marketing,

exclusive offers, etc). If you are a new customer, we will contact you by electronic means (email or SMS) for marketing purposes only if you have consented to such communication. If you are a current customer, we will only contact you by electronic means with information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal data for direct marketing purposes or to pass your personal data on to third parties for marketing purposes, you can withdraw your consent by logging into your account at gate11.io or by contacting us at info@gate11.io. Direct marketing includes any communications to you that are only based on advertising or promoting products and services. As mentioned above, you can opt out of our marketing communications anytime. However, certain electronic communications between us and you are necessary for usage of our Services including login notifications, withdrawal confirmations, deposit notifications and 2-Factor Authentication (this can be replaced with Google Authenticator, Authy, or Trezor). We highly recommend that you do not turn off 2-Factor Authentication as this provides the maximum amount of security for your account.

If you chose not to consent to the terms of this Privacy Policy or opt out of receiving notifications from us that makes it difficult or impractical for us to provide Services to you, we will grant you a period of up to 10 business days from the moment you do not consent or opt out to move your assets to an external digital wallet of your choosing and close your account.

Personal Data Protection

We take reasonable administrative, physical and electronic measures designed to safeguard and protect your personal data from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the personal data you input, and storing your personal data in encrypted form behind a firewall designed to block access from outside our network. However, no security or encryption method can be guaranteed to protect information from hackers or human error, no computer security system is entirely fool-proof, and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the data you submit to or receive from us through the Internet or for any unauthorized access or use of that information and we cannot and do not guarantee that personal data communicated by you to us or sent to you by us will be received or that it will not be altered before or after its transmission to us. We cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your Information will not occur. Please recognize that you play a vital role in protecting your own Information. When providing information on the gate11.io or accessing or using our Services, you should choose a password of sufficient length and complexity, not reveal this password to third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account. Furthermore, we cannot ensure or warrant the security or confidentiality of Information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that Information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at info@gate11.io.

How and how long do we store the Personal Data?

As a general rule Data Subject’s Personal Data are Processed within the EU/EEA. The transfer and Processing of Personal Data outside of the EU/EEA could only take place if there is a legal basis and appropriate safeguards are taken. We keep Personal Data for a limited time period and in any event no longer than 10 years for the purposes for which the Personal Data were collected. After the retention period comes to an end the Company will then delete the Personal Data. Information we collect may be stored or processed on computers located in any country where we or our partners provide Services or carry on business. We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain information for accounting and security purposes even after our business relationship with you has ceased.

Use of Cookies

We use cookies as described in the table below.

You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies you may be unable to access certain areas or features of our website. For information on how to adjust or change your browser settings, visit www.aboutcookies.org or www.allaboutcookies.org.

For the information on, policy and control options for the third-party cookies, please read cookie policies of such third parties.

Use of Google Analytics

Google Analytics is integrated on our website gate11.io. 

Google Analytics is a website analysis service. Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. You can find more information about Google Analytics’ use of Personal Data here: https://policies.google.com/privacy?hl=en 

Data Subject’s rights and how to complain?

Under GDPR, you have the following rights:

Your right of access – you have the right to ask us for copies of your personal information. 

Your right to rectification – you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of Processing – you have the right to ask us to restrict the Processing of your information in certain circumstances. 

Your right to object to Processing – you have the right to object to the Processing of your information in certain circumstances.

Your right to data portability – you have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you.

Please contact us at info@gate11.io if you wish to make a request.

You can also complain to the Lithuanian State Data Protection Inspectorate (website address: www.vdai.lrv.lt) if you are unhappy with how we have used your Personal Data.

The Privacy Policy can be amended from time to time due to legislative changes, changes in the Platform, activities of the Company and other factors. We will inform you about the amendments by publishing the amended text of the Privacy Policy on the website gate11.io. We advise you to regularly review the relevant and applicable Privacy Policy.

Last updated: October 2024