Privacy Policy and Cookies Policy

Insert Stonks

25 February 2022

We are collecting and processing your personal data.

Any type of personal data can be used to identify you. It is very important that you keep in mind that sharing your personal data is a responsible activity and increasingly requires you to take precautionary measures as to protect it. You have the right to remain in full control over your personal data. This means that you have the right to be made aware of risks, rules and safeguards in relation to the processing of your personal data. You have the right to ask questions about how and why your data is processed and, if you do not like the answer, you have the right to object to data processing and have your data erased.

As part of our commitment, in the next pages we will explain how we collect, use and protect your personal data, as well as why we are processing your personal data and what are your rights in relation to this processing.

Participation in the Initial Token Offering (ITO) is conditional on consent to the processing of personal data. The following information is necessary for the performance of the agreement between parties. Therefore, by consenting to your data being processed you agree to multiple and all purposes, hence if you do not agree with any of the purposes you should not participate in the ITO.

If you do not understand or have further questions regarding the purpose of data processing, before agreeing with it, please reach out to our person responsible for handling your personal data on info@insertstonks.io.

While complying with the Know Your Customer requirements, we will limit to the fullest possible extent interference into your right to privacy. We have in place appropriate technical and organisational measures to prevent unauthorised or unlawful access to the personal data you have provided to us. When assessing the appropriate level of security we took steps to ensure that only qualified and limited number of personnel can access your personal data. Moreover, records of your personal data are protected using state of the art encryption and processed only when necessary.

As complete data security cannot be guaranteed for communication via instant messaging (Telegram) and similar means of communication, we would recommend sending any particularly confidential information only by regular post or e-mail.

1. Insert Stonks and General Data Protection Regulation (GDPR)

Insert Stonks is a Data Controller within the meaning of Article 4 (7) of GDPR. If you are a resident of the European Union or other regions with laws governing data collection and use, then you agree to the transfer of your information to Saint Lucia.

2. You can contact person responsible for handling your personal data

You can send us your questions or request related to any aspect of your personal data via email info@insertstonks.io.1

3. Information you provided to us and how do we process your personal data

We are collecting and processing sensitive personal data about you.2 This personal data can be used to uniquely identify you. The processing of this data is necessary for the purposes of carrying out the professional obligations under the relevant regulations and, in particular, the Know-Your Customer and Anti-Money Laundering regulations. We may also use your de-identified and aggregated data for statistical purpose. You have the right to withdraw your consent at any time by writing an email to our responsible person. In case of overriding interests that require the processing to continue, we will nevertheless consider your request in good faith and respond to you. The following information is necessary for the performance of the agreement between parties and will be collected and processed by Insert Stonks or entities employed by Insert Stonks to perform these tasks on our behalf, subject to Insert Stonks supervision and obligations derived from this Privacy Policy:

a. Personal and Demographic data:

  • Name and Surname
  • Date of Birth
  • Gender
  • Occupation and professional affiliation
  • Origin of assets
  • Fiscal domicile
  • Addresses
  • Country of residence
  • Nationality and Citizenship
  • KYC documents (a copy of your national identity card or passport)
  • Financial information, including payment and transaction records and information relating to your assets
  • Details of our interactions with you and any records of our communication
  • Identifiers we assign to you (such as AMLA number)
  • When you access our Website, data transmitted by your browser will be automatically recorded by our server (such as log files and information collected by Google Analytics)

Important: In certain cases Insert Stonks will contact you with questions concerning further clarifications regarding your occupation, origin of assets or fiscal domicile. The question may take into consideration also your demographic data. Your answers can be used to prepare special clarifications or conclusions, which are not automated and drafted by taking into consideration macro-economic parameters.

b. Personal contact details:

  • Phone Number
  • Email Address (when you sign up with your email address to the newsletter or on the Website your email will be used for updates)

Important: Insert Stonks will use your personal data to draft a document called “Personal Profile” which will comprise your personal demographic data, personal economic and social data and personal contact details.

In the course of exercise of our rights, we will run your personal data against publicly accessible databases that will disclose to us whether you are a Politically Exposed Person (PEP) or if there are any criminal charges brought against you.3

If we have been informed by you that you are interested in our business solutions, or when we reasonably assume so, we will add your limited Personal and Demographic data as well as personal contact details to the list of professional contacts that is stored in Pipedrive.

Online service Description
Pipedrive

We manually input the following data into Pipedrive: name, surname, contact details (email address), professional affiliation, country of residence.

The information is stored on Pipedrive servers in the EU and USA.

For details please see here.

c. Audio and visual identification

Insert Stonks will ask you to schedule a video call in which you will be asked whether you consent with the video and audio identification being recorded. We will ask you to state information listed above under the “Information you provide us”. We will ask you to display your identity to the camera.

4. Cookies

Insert Stonks uses cookies to keep our sites reliable, secure and personalised. When you continue to use our sites you accept cookies, this helps us to make the sites (insertstonks.io) better by remembering your preferences, customising content or ads.

Most cookies collect general information, such as how visitors arrive at and use our sites, the device they are using, their internet protocol address (IP address), what pages they are viewing and their approximate location (for example, we would be able to recognise that you are visiting our sites from a particular city). We also use cookies to help us understand our audience and to analyse how and which of our sites are used (Google Analytics and Yandex Analytics).

Online service Description
Google Analytics

Google collects information concerning: number of users and sessions, session duration, operating systems, device models, geography, first launches, country (based on IP), language, carrier.

The information is stored on Google servers in USA and EU.

For details please see here.

We use cookies to serve you with advertisements that we believe are relevant to you and your interests.

Nevertheless, cookies can be blocked, deactivated or deleted through a variety of different tools that are available (including browser controls and settings). You can find information hereto in the settings of the web browser you use. If all cookies used by us are deactivated, your experience of the sites may change or be limited.

5. Legal basis for processing

We may disclose your information only if legally obliged to do so, when meeting our on-going regulatory and compliance obligations (e.g. anti-money-laundering and tax laws), including in relation to recording and monitoring communications, disclosures to tax authorities, financial service regulators and other regulatory and governmental bodies, and investigating or preventing crime.

Depending on the purpose of the processing activity, the processing of your personal data will be one of the following:

  • Necessary for fulfilling our contractual obligations towards you, without unduly affecting your interests or fundamental rights and freedoms.
  • Required to meet our legal or regulatory responsibilities, including when we conduct the KYC checks.
  • In limited circumstances, processed with your consent which we obtain from you from time to time (for instance where required by laws other than the EU GDPR or when exercising our rights under Articles 16 and 17 of the Charter of Fundamental Rights), or processed with your explicit consent in the case of special categories of personal data such as your financial information.

6. Purpose of processing

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for the following purposes:

  • Client on-boarding processes, including to verify your identity and assess your application and to conduct legal and other regulatory compliance checks to comply with anti-money laundering regulations, and prevent fraud.
  • Ensuring proper execution by ensuring that we can identify you and make payments or transfers to your accounts;
  • Managing our relationship with you, which includes communicating with you in relation to the products and services you obtain from us and from our business partners, handling customer service-related queries and complaints, verifying your identity.
  • We will notify to you any other purpose from time to time.

To the extent we obtained your consent to process your personal data in the past, we will no longer rely on such consent, but instead will rely on lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this Privacy Policy), and our ability to rely on that consent is hereby waived or extinguished. For the avoidance of doubt, any consent given for the purpose of our compliance with the regulatory obligations remains unaffected by this paragraph.

7. With whom do we share your personal data?

Category of personal data Legal basis and purpose of processing Entity that we share your personal data with
  • Name and Surname
  • Date of Birth
  • Gender
  • Country of residence
  • Nationality and Citizenship
  • Address
  • Phone number
  • Name and Surname
  • E-mail address
  • Approximate location and business based on your IP
  • Cookies
  • Country of residence
  • Professional affiliation

This processing is necessary to verify the personal data contained in your identity documents to ensure compliance with applicable laws in Switzerland (Anti-Money-Laundering Act and Ordinance) and for the performance of our mutual contractual obligations (Terms and Conditions governing the Initial Token Offering) We use this information to provide you with meaningful advertising marketing materials – such as news about ITO and our products and information necessary to facilitate the service (your subscription to the Newsletter) or meaningful advertisement that is sometimes sent directly to your email.

Qualified employees of Insert Stonks and our business partners

Tax authorities

Financial service regulators

Other regulatory or governmental bodies

Employees of Insert Stonks and our business partners

Tax authorities

Financial service regulators

Other regulatory or governmental bodies

  • KYC documents
  • Fiscal Domicile
  • Financial information, including payment and transaction records and information relating to your assets
  • Details of our interactions with you and any records of our communication

This processing is necessary to verify the personal data contained in your identity documents to ensure compliance with applicable laws in Switzerland (Anti-Money-Laundering Act and Ordinance) and for the performance of our mutual contractual obligations (Terms and Conditions governing the Initial Token Offering)

Qualified Employees of Insert Stonks and our business partners

Tax authorities

Financial service regulators

Other regulatory or governmental bodies

  • Name and Surname
  • E-mail address
  • Country of residence
  • Professional affiliation
  • (other information that are required in order to verify your application and for the conclusion of an employment contract and which we are obliged by law to collect)

If you apply for a professional position at Insert Stonks, this processing is necessary to take your candidature into consideration in order for us to fulfil contractual, statutory and supervisory obligations, and in order to safeguard legitimate interests.

Qualified Employees of Insert Stonks and our business partners

Tax authorities

Other regulatory or governmental bodies

8. Your rights

You have a right to ask us to amend or rectify inaccurate personal data we collect and process and the right to request restriction of your personal data pending such a request being considered.

Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Please also note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You have a right to ask us to stop processing your personal data, or to request deletion of your personal data (the so-called right to be forgotten). However, these rights are not absolute and in case of overriding interests that require the processing to continue, we will consider your request and respond to you with the outcome.

When personal data are processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing by clicking the "unsubscribe" link in any of our emails to you, or by emailing us (here).

Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you have the right to request your personal data be transferred to you or to another controller (the so-called data portability). You also have the right to ask Insert Stonks for a copy of some or all of the personal data we collect and process about you.

In certain circumstances, Insert Stonks may process your personal data through automated decision-making, including profiling, in particular during the KYC process. Where this takes place, you will be informed of such automated decision-making that uses your personal data, be given information on the logic involved, and be informed of the possible consequences of such processing. In certain circumstances, you can request not to be subject to automated decision-making, including profiling.

9. Who can access your personal data?

Your personal data will be shared with employees and agents of Insert Stonks.

If required, we disclose personal data to public authorities, regulators or governmental bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so.

If you are not satisfied with Insert Stonks’ response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen.

10. Assignment of rights

In case of reorganisation, in particular when the respective Foundation is registered and some rights and obligations transferred, or sell of business, personal data will be shared so that you can continue to receive products and services. Insert Stonks will take steps to ensure such potential purchasers keep the data secure.

11. How long do we store your personal data?

Insert Stonks will retain personal data for the period of your relationship or contract with Insert Stonks. An ongoing or anticipated legal or regulatory proceeding may lead to retention beyond this period.

1The person responsible for handling your personal data is not a Data Protection Officer within the meaning of Art. 37 GDPR even if his tasks coincide with those listed in Art. 38 and 39 GDPR.

2Not within the meaning of Art. 9 of the General Data Protection Regulation 2016/679 (EU GDPR).

3Pursuant to Art. 10 of the GDPR on processing of personal data relating to criminal convictions and offences, Insert Stonks is required to collect and analyse this data by the Anti-Money-Laundering Act as amended and in force.