Otonomos SAFTE Hub LLC and its related entities (“we” or “us” or “Otonomos”) recognize the importance of protecting the privacy and the rights of individuals in relation to their personal data. The use of the website requires your consent to transfer and process your information, as well as your consent to use cookies. Please read our Privacy Policy to understand how we collect, use, process, manage and disclose your personal information.

  • 1. Collection of your information
  • 1.1 We may collect the following types of personal data:
  • - name;
    - residential and mailing address;
  • - email address;
  • - personal identification number (e.g. identity card number or passport number);
  • - personal identification document (e.g. identity card or passport);
  • - telephone or mobile  number;
  • - nationality;
  • - age or birth date;
  • - place of birth;
  • - bank account details including statements;
  • -professional or job title or occupation; and
  • - type and source of income.

1.2 We collect personal data directly from you unless it is unreasonable or impracticable to do so. When collecting personal data, we may collect it by various means including:

- through your access and use of our website, including for the purposes of engaging in the Otonomos token sale;

    1. - when you complete an order on our website;
    2. - through emails, messaging applications or other file sharing means that we or you use to provide the personal data to us; or
    3. - through third parties or publicly available sources such as Google Analytics based outside the European Union; or
    4. - contact, transaction and financial data from providers of technical, storage, e-signing, payment or sales services.

1.3 If you do not provide us with the personal data described above, we may not be able to provide the requested services to you or your company, either to the same standard as if you had provided the personal data or at all.

2. Purpose of Collection, Use and Disclosure

2.1 We collect, use and disclose your personal data for the following purposes to:

- provide services to you or your company and send communications as requested or consented to by you or your company;

- provide you with access to certain areas of our website, including for the purposes of engaging in the Otonomos token sale;

    1. - answer enquiries and provide information or advice on our website;
    2. update our records and keep your contact details up to date;
    3. process and respond to any complaints or enquiries made by you; and
    4. comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or to co-operate with any governmental authority.

2.2 We will not be sharing, selling, renting or disclosing your personal data other than as described in this Privacy Policy.

3. Disclosure of Personal Data

3.1 We may disclose your personal data to:

    1. - our affiliates, contractors or third party services providers for the purposes set out in paragraph 2.1 and the purposes of: (a) operating our website or business; (b) fulfilling requests by you; (c) processing and verification to enable us comply with our internal policies; and (d) otherwise providing our services to you or your company;
      - law enforcement agencies or regulatory authorities where we are required to do so by law;
    2. relevant parties where it is necessary for legal proceedings; or
    3. - any other organizations for any authorized purpose with your express consent.

3.2 We may disclose your personal data to our affiliates, contractors or third party service providers overseas for some of the purposes listed above only when is necessarily required.

4.  Data Security

4.1 We take reasonable steps and follow industry standards in information security to ensure your personal data is protected from misuse or loss, and unauthorised access, modification or disclosure. Our information security systems apply to people, processes, and information technology systems on a risk management basis.

4.2 We perform periodical checks to ensure our handling of your personal information aligns with industry guidelines.

4.3 We store your personal data using a decentralised data encrypted storage technology. The use of this technology may result in your personal data being stored overseas. Where this happens, to ensure the security of your personal data, your transferred personal data will always be broken up into a number of small files (none of which will contain the entire personal data) with each file being encrypted and distributed across the decentralised network. The recipients of the encrypted files may not reside in countries that have data protection laws, however the technology is designed so that only you and we may access and use the personal data stored using it.

4.4 We monitor on an ongoing basis the level of protection offered by our technology providers. You may withdraw your consent to this overseas transfer of your personal data at any time by contacting us at our contact details below.

4.5 All email messages and instant messages sent to and from us may be monitored to ensure compliance with internal policies and to protect our business.

5. Cookies and Do not Track

5.1 Cookies are small text files that can be used by websites to make a user's experience more efficient. We use cookies to enhance your experience on our website and provide you the best possible experience. 

5.2 We use cookies to enable our systems to recognize your device. We may also use cookies for additional purposes, including:

  1. - conducting research and diagnostics; and
  2. - helping to prevent fraudulent activity and improve security.

5.3 Third parties may set up cookies when you are browsing on our website. These are third party providers approved by us such as analytics services, search engines, social media networks.

5.4 If you do not wish to receive any cookies you can adjust your browser settings so that your device does not accept them but bear in mind that by blocking all cookies this website may not won’t work properly. Alternatively, you may manage your cookies settings to allow necessary and non necessary cookies here. 

5.5  At this time we do not honor “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Cookies Notice. However, our website does not track any personal information unless you intentionally provide it to us.

5.5 We may change the provisions of this section at any time and will ensure to post the most up to date version on our website.

6. Communications

6.1 We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications are sent in various forms including mail, SMS, chat, telephone calls and email, in accordance with applicable laws. If you indicate a preference in regards to the method of communication, we will endeavor to use that method whenever practicable to do so.

6.2 You may at any time opt-out of receiving our newsletter or marketing communications by using the unsubscribe mechanism provided in our email communications. Alternatively, you may opt-out of receiving marketing communications from us by contacting us at the details below.

6.3 We may send you service related communications on rare occasions and when is necessary to do so.  These communications include updates to our terms and conditions of service or website maintenance notices. You do not have the option to unsubscribe from such notices which are not promotional in nature. 

7. Access, correction and data deletion

7.1 Certain jurisdictions may permit certain users of our website to withdraw its consent to this Privacy Policy. To make such a request, please send an email to the e-mail address at the bottom of this Privacy Policy. Please note that by withdrawing your consent to this Privacy Policy you will not be able to use the Website. We will process such requests in accordance with the applicable law.

7.2 You may contact us at the details below to request for access, correction or deletion of personal data that you have posted on our website or have provided to us. If you are entitled to access the personal data, we will try to provide you with suitable means of accessing it as soon as possible. 

7.3 You may request us to provide you the type of personal information we have shared with third parties by contacting us at the details below.

7.4 We may charge you a fee to cover our administrative and other costs in providing you any physical the personal data we hold and you require us to send you by mail.   

7.5 We do not charge for making any corrections or deletion of your personal data.

8. Notice to European Union Residents. 

8.1 Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR). We may process your Personal Information because: (a) we need to perform a contract with you; (b) you have given us permission to do so under the terms of this Privacy Policy; (c) the processing is in our legitimate interest and it is not overridden by your rights; (d) we may need to collect or process payment in connection with the Otonomos token sale; and (e) we need to comply with applicable laws.

8.2 Your Data Protection Rights under the General Data Protection Regulation (GDPR). We strive to comply with all applicable laws relating to our collection and processing of your Personal Information. In certain circumstances and as provided under applicable law, you have the following data protection rights: (a) the right to access, update or delete the information we have on you; (b) the right to rectify any information that is inaccurate or incomplete; (c) the right to object to any unlawful processing of your personal information; (d) the right to request the restriction of our processing of your personal information; (e) the right to know and receive a copy of the information we may have on you; and (f) the right to withdraw your consent at any time where we relied on your consent to process your personal information.(3) For any requests relating to your rights under the GDPR, please notify us at the email address at the bottom of this page. Furthermore, you have the right to complain to a Data Protection Authority about our collection and use of your personal information.

9. Contact

If you have any questions in relation to this Privacy Policy or your personal information, please contact us at [email protected].