Privacy Policy

Last updated 15 March 2024

Welcome to the privacy policy of CoinRock Ventures/Zuramedia Ltd. Protecting your privacy is paramount to us, and we are dedicated to safeguarding your personal information. This privacy policy is designed to inform you about how we manage your personal data when you browse our website (no matter where you access it from) and when you utilize our products and services. It will also provide information on your rights and how to reach out to us if you have any questions or concerns.

Purpose of this privacy policy

This privacy policy is intended to inform you about the ways CoinRock Ventures/Zuramedia collects and processes your personal information when you interact with this website. This includes any data you might submit when signing up for our newsletter or applying for one of our accelerator programs.

CoinRock Ventures/Zuramedia refers to Zuramedia Ltd, which is registered in the UK. As data controllers, we are responsible for managing the personal information we gather. We may share this information with our subsidiaries and related entities as outlined in this policy (collectively referred to as “Zuramedia”, “CoinRock Ventures”, “we”, “us”, or “our” within this document).

Our website is not designed for children, and we do not intentionally collect information about children. Occasionally, we may provide you with additional details on privacy when you access certain products or services. It’s vital that you carefully read this privacy policy along with any supplementary information we offer, to fully understand our data use practices.

Should you have any queries regarding this privacy policy or our approach to privacy, please reach out to us at info@coinrock.io.

You also have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO), the authority for data protection issues in the UK (www.ico.org.uk). Nonetheless, we encourage you to contact us first with any concerns, as we would value the opportunity to address them directly.

Modifications to the Privacy Policy and Your Obligation to Notify Us of Changes

Our privacy policy is subject to ongoing evaluation and review. The most recent update was made on January 27, 2023. Ensuring the accuracy and up-to-dateness of your personal data in our records is crucial. Should there be any changes to your personal information during your association with us, we kindly ask that you update us accordingly.

Third-party links

This site may feature links to external websites, plugins, and applications from third parties. Interacting with these links or enabling these connections could permit third parties to gather or disseminate information about you. We do not have authority over these third-party sites and cannot be held accountable for their privacy policies. We advise you to review the privacy policies of any website you navigate to after leaving ours.

The data we collect about you

Personal data excludes any information from which identity has been removed, resulting in anonymous data. We may collect, utilize, store, and transfer various types of personal data about you, which are categorized as follows:

Identity Data includes full name, username or similar identifier.
Contact Data includes residential address and email address.
KYC Data includes personal data obtained from:
- Identity verification (ID document information and proof of address);
- Verification of ultimate beneficial ownership of corporate and other legal entities;
- Anti-money laundering, proceeds of crime and terrorist finance checks (AML/CFT checks); and
- Sanctions lists checks.
Financial Data includes bank account details and other financial information, including but not limited to, source of funds and source of wealth information.
Transaction data includes details about payments to or from you, including digital access wallet information.
Technical Data includes IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Communications Data includes your preferences in receiving marketing from us.

During our Due Diligence process, we may opt to engage a third-party KYC provider to gather and verify KYC data. This verification process will include AML/CFT checks and ongoing surveillance. Your information will be collected based on the service provider’s privacy policy and with your explicit consent.

Additionally, we might collect and process Special Categories of Personal Data about you. This encompasses information regarding your health, racial or ethnic origin, political stances, religious or philosophical beliefs, trade union membership, genetic or biometric data, as well as data on criminal convictions and offenses, as part of our KYC/AML screening during client onboarding.

We also compile and utilize Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data, which may be derived from your personal data, is not considered personal data by law since it does not directly or indirectly disclose your identity. For instance, we may use your Usage Data to determine the percentage of users engaging with a specific feature of our website. Nonetheless, if Aggregated Data is combined with your personal data in a way that could directly or indirectly identify you, we will treat the combined data as personal data and handle it in line with this privacy policy.

If you fail to provide personal data

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 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.

How is your personal data collected?

We employ various techniques to gather information from you and about you, such as:

Direct Interactions: You might provide us with your details by filling out forms, subscribing to our services or newsletters, entering into agreements with us, communicating through email or social media, directly engaging with our team members either in person or electronically, or by offering services to us.
Automated Methods or Interactions: When you navigate our website, we automatically gather Technical Data regarding your devices, as well as your browsing behaviors and patterns. This collection of personal information is conducted through the use of cookies and technologies similar to cookies.

We may also obtain personal data about you from third parties and publicly accessible sources. This includes receiving information from analytics providers like those offering Technical Data, as well as from KYC (Know Your Customer) and other service providers, along with public records.

How we use your personal data

We will only utilize your personal data in situations where:

we need to perform the contract we are about to enter into or have entered into with you.
we have your permission to do so.
it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
we need to comply with a legal obligation.Where we process Special Category Data, we only do so with your explicit consent.

Purposes for which we will use your personal data

Below, we’ve organized in a table format all the methods by which we intend to use your personal data, alongside the legal bases we depend on to do so. Where applicable, we’ve also noted our legitimate interests.

Be aware that we might process your personal data based on multiple legal grounds, depending on the particular reason for which we are using your data. If you require more information about the specific legal basis we’re relying on to process your personal data, please feel free to reach out to us.

Promotional Non-Fungible-Tokens (NFTs)

From time to time, we might issue NFTs (Non-Fungible Tokens) as part of promotional activities with the aim of enhancing the Coinrock Ventures/Zuramedia brand visibility and rewarding individuals who engage in our events. By participating, you commit to supplying truthful information for receiving these NFTs. We are not liable for any losses that may occur due to security breaches, errors, or technical malfunctions. Additionally, it’s important to note that no promises, warranties, or assurances are made regarding the NFTs’ value.

Given the emerging nature of NFTs, you acknowledge and agree that they are subject to a range of risks, including but not limited to, legal and regulatory challenges. We cannot be held accountable for any damages or losses connected with the NFTs and do not ensure that the NFTs will remain usable, functional, or hold any value.

By engaging with us, you confirm that you have read, understood, and agree to these terms.

Our use of ‘cookies’

You have the option to adjust your browser settings to either reject all or some browser cookies, or to alert you when websites place or access cookies. Should you choose to disable or refuse cookies, be aware that certain sections of this website may not be accessible or function correctly.

Cookies Explained:

Cookies are small text files sent to your web browser by a website you visit. These files are stored in your browser and enable the website or a third-party to recognize you, simplifying your future visits and making the service more beneficial to you.

Our Use of Cookies:

When you interact with our services, we might use various cookies in your web browser for specific purposes: to activate certain features of the service, gather analytics, remember your preferences, and support the delivery of advertisements, including behaviorally targeted ads.

Types of Cookies We Use:

We employ both session and persistent cookies on our site, which include essential and third-party cookies. Essential cookies are crucial for authenticating users and preventing fraudulent use of user accounts.

Third-party Cookies:

Beyond our own, we may also use third-party cookies to compile service usage statistics, deliver advertisements on our service, and so on. You can find more information about cookies at third-party sites such as AllAboutCookies (http://www.allaboutcookies.org/) and the Network Advertising Initiative (http://www.networkadvertising.org/).

Social Media Cookies:

Sharing our content on social media, like liking our page on Facebook, following us on Twitter, or giving a ‘+1’ on Google Plus, will result in those social networks recording your activity and potentially setting cookies for this purpose. Also, if our website features content from social networks (like a Twitter feed or Facebook comments box), these services may set a cookie even if you don’t interact directly with that functionality. We cannot access cookies set by social networks, nor can these networks access the cookies we set.

Google Analytics:

Our website utilizes Google Analytics, a service from Google, Inc., to collect information on website usage. The data generated by the cookie about your use of the site (including your IP address) is sent to Google and stored on servers in the United States. Google uses this information to evaluate your website use, compile reports for website operators, and offer other services related to website and internet usage. Google may also share this information with third parties where legally required, or where such third parties process the information on Google’s behalf. Google will not link your IP address with any other data held by Google. You can learn more about Google’s privacy policy at http://www.google.com/privacy.html.

Change of purpose

We commit to using your personal data solely for the purposes for which it was originally collected, unless we determine that it’s necessary to use it for another, compatible purpose. Should you want to understand how processing for a new purpose aligns with the original reason for collection, feel free to reach out to us.

Be aware that there may be instances where we’re allowed to process your personal data without your awareness or consent, in line with the aforementioned guidelines, especially when it’s mandated or allowed under law.

Disclosures of your personal data

We may disclose your personal data to the entities listed below, in accordance with the purposes outlined in the previously mentioned table.

Internally within the Outlier Group;
External Third Parties as set out in the Glossary below; and
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 policy.

We mandate that all third-party entities uphold the confidentiality and security of your personal data and handle it in a manner that complies with legal standards. We prohibit these third-party service providers from using your personal data for their own interests, allowing them to process your information solely for designated purposes and in strict adherence to our directives.

In instances where we transfer your personal data outside of the UK, we take measures to ensure it receives a comparable level of protection. This involves engaging only with certain service providers or utilizing specific contracts approved for use in the UK, which extend the same level of data protection as within the UK.

Data security

We’ve implemented suitable security protocols to safeguard your personal data against accidental loss, unauthorized use, access, alteration, or disclosure. Furthermore, access to your personal data is restricted solely to those employees, agents, contractors, and other third parties who need the information for business purposes. They are instructed to process your personal data strictly according to our directives and are bound by confidentiality obligations.

To address potential personal data breaches, we have established procedures for managing such incidents. Should a breach occur, we will inform you and any relevant regulatory body as mandated by law.

Data retention

We commit to holding your personal data only as long as necessary to accomplish the purposes for which it was collected, including meeting any legal, regulatory, tax, accounting, or reporting obligations. Should there be a complaint, or if we reasonably foresee potential litigation related to our interactions, we might retain your data for a longer duration.

The decision on how long to keep personal data involves evaluating the data’s quantity, nature, and sensitivity, the risk of harm from unauthorized access or disclosure, the reasons for processing your data and if those objectives can be achieved by other means, along with relevant legal or regulatory obligations.

Under certain conditions, you have the right to request the deletion of your data; for more details, refer to the “Request erasure” section below.

Legally, we are required to maintain basic information about our customers (including Contact, KYC, and Transaction Data) for six years after they no longer use our services.

Your legal rights

Under data protection laws, you possess several rights in relation to your personal data. Below is an overview of these rights:

Request Access: You have the right to request a copy of the personal data we hold about you, to ensure we are processing it lawfully.

Request to be Informed: You can ask for information about how we collect and use your personal data.

Request Correction: If the personal data we hold about you is incomplete or inaccurate, you have the right to have it corrected. We may need to verify the accuracy of the new data you provide.

Request Erasure: You have the right to ask us to delete or remove your personal data in certain circumstances, such as if there’s no valid reason for us to continue processing it, or if you’ve exercised your right to object to processing.

Object to Processing: If we are processing your data based on legitimate interests or direct marketing, you can object to this processing if you believe it impacts your fundamental rights and freedoms.

Request Data Transfer: You have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format. This applies to automated information you initially consented to us using or that we used to perform a contract with you.

Withdraw Consent: If we are processing your data based on your consent, you can withdraw this consent at any time. This won’t affect the lawfulness of processing before your withdrawal, but it may mean we can’t provide certain services to you thereafter.

Automated Decision-Making and Profiling Requests: [We do not use your personal data for automated decision-making or profiling.]

It’s important to note that these rights may be limited under certain conditions as prescribed by law and we may not always be able to fulfill your request due to these legal constraints.

No fee usually required

You are entitled to access your personal data and exercise your other rights without incurring a fee. Nonetheless, should your request be clearly baseless, repetitive, or excessive, we reserve the right to charge a reasonable fee for the administrative costs associated with your request. In certain situations, we might even choose not to fulfill your request under these conditions.

Zuramedia Ltd (“Zuramedia”) is registered in England and Wales, company registration number 09866544.

Glossary

External third parties with whom your personal data might be shared include:

Service Providers: Entities acting as processors located within the UK or internationally, offering various services to us.

KYC and Compliance Service Providers: UK-based service providers acting as processors, offering Know Your Customer (KYC), regulatory, compliance, and client onboarding services.

Parties Involved in Our Services: This includes counterparties and their legal representatives, accountants, surveyors, family offices, other intermediaries, as well as courts, tribunals, public registrars, and stock exchanges that are involved in the services we offer to our clients.

Professional Advisers: Lawyers, bankers, auditors, and insurers operating either as processors or joint controllers in the UK, providing consultancy, banking, legal, insurance, and accounting services.

Regulatory Authorities: HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers in the UK, who may require reporting of processing activities under certain circumstances.