Privacy Notice for ICN User Interface

This privacy notice (“Privacy Notice”) explains the basis for our collection of personal data when you access and use the user interface (“ICN User Interface”) for connecting your wallets to the Impossible Cloud Network (“ICN”), and sets out how we use your personal data, the conditions under which we disclose it to others and the measures we take to keep it secure. In addition, we may inform you about the processing of your personal data separately, for example in consent forms, terms and conditions, additional privacy notices, forms, and other notices. We use the word “data” here interchangeably with “personal data”.

If you provide information to us about you or any person other than yourself, you must ensure that the data is accurate and that these other people understand how their data will be used, that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it. You are welcome to provide them with a copy of this Privacy Notice.

1. Controller

The responsible person for processing your data under this Privacy Notice (“Controller”) unless we tell you otherwise in an individual case is:

Impossible Cloud Network Foundation
Dammstrasse 16
Bergliweg 15
6300 Zug

You may contact us regarding data protection matters and to exercise your rights at legal@icn.global.

2. Data Collection and Purpose of Data Processing

We process the following data about you for the purposes outlined below:

1. ICN User Interface

When you access and use the ICN User Interface, we collect data that is necessary for the functionality and security of the ICN User Interface.

The data collected includes: IP address; information about the operating system of your end device; location data and geographical information; cookies; referrer URL; amount of data transferred; date, region, and time of the server request; name of your Internet provider; protocols; information regarding your consent to the GTC; your acknowledgement of this Privacy Notice; etc.

2. Wallets

To access the ICN, a wallet must be connected via the ICN User Interface. These wallets are provided by third-party providers, meaning we have no control over the wallets, the tokens held within them, or the associated private keys. When you use the functionalities of these wallets through the ICN User Interface, transactions and data are processed directly on-chain, as described in Section 7 of this Privacy Notice. This means that your transaction data and wallet addresses, are recorded on the public blockchain, and we do not have the ability to alter, intercept, or reverse these transactions. Furthermore, we cannot recover lost private keys or access funds stored in your wallet. 

3. Registration and KYC

Certain purchases on specific blockchains require completion of a registration process, including Know Your Customer (KYC) verification. After connecting your wallet, you will need to identify yourself by providing, among other information, a face scan, identification ducuments, and proof of address. The data collected during this process is used to provide our services and to ensure their functionality and security.

The data collected includes: surname; first name; address; phone number; email address; nationality; date of birth; gender; legally required information regarding anti-money laundering and terrorist financing; photographs of your face; identification documents; information regarding your agreement to the terms and conditions; acknowledgement of this data protection declaration and the AML and compliance guidelines; etc.

To comply with legal requirements and to prevent fraud, we collaborate with a third-party provider specializing in KYC checks. This provider acts on our behalf to verify your identity as part of the registration process. We are legally obligated to store the data collected in this context in accordance with applicable laws.

4. Contract and Services

We process your data for entering into a contract with you, perform and administer it and to provide our services to you.

The data collected includes: Information collected as part of the registration process; other information provided by you; information with regard to a possible conclusion of a contract and about the conclusion of the contract; information about the execution and administration of the contracts; etc. 

5. Innovation and Marketing

We process your data for marketing and business activities in relation to the ICN User Interface, in particular for the further development of the ICN User Interface, our servcies and any other platforms on which we operate. In addition, we and selected third parties may use your data to show you personalised content or advertising if and to the extent that you give us your consent, provided this is required by applicable law. You can object to such marketing activities or withdraw your consent at any time (see also Section 10 below).

All of the above data may be used for this purpose.

6. Communication

When you contact us by email, telephone, letter, or other means of communication, we collect the data exchanged between you and us for the purposes of communicating with you and providing our services related to the ICN User Interface to you, in particular to respond to your enquiries. By providing us with this data, you acknowledge that we use your data in accordance with this Privacy Notice.

The data collected includes: contact details; type, manner, place and time of communication; content of communication; etc.

7. Safety or Security Reasons

We process your data to protect our IT and other infrastructure. For example, we process data for monitoring, analysis and testing of our networks and IT infrastructures including access controls.

All of the above data may be used for this purpose.

8. Compliance with Law and Legal Procedures

We process your data to comply with legal requirements (e.g. to combat money laundering and terrorist financing (“Know Your Customer/KYC”), to fulfil tax obligations, etc.), and we might have to request further information from you to comply with such requirements or as otherwise required by law and legal authorities. Furthermore, we may process your data for the enforcement of legal claims and for the defence in legal disputes and official proceedings.

All of the above data may be used for this purpose.

9. Risk Management, Corporate Governance and Business Development

We process your data as part of our risk management and corporate government in order to protect us from criminal or abusive activity. Subject to the limitations of our legal structure, we might sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships as part of our business development. Such activities might result in the exchange and processing of data based on your consent, if necessary.

All of the above data may be used for this purpose.

10. Cookies

The ICN User Interface use cookies, and we may also allow certain third parties to do so. Cookies are text files that are stored on your device (computer, laptop, smartphone, etc.) and that are necessary for the use of the ICN User Interface as such or certain functions or that enable the analysis of the use of the ICN User Interface. 

You can configure your browser in such a way that no cookies are stored on your computer or a message always appears before a cookie is installed. Please note that deactivation of cookies may result in the ICN User Interface not functioning or not functioning completely.

11. Third-Party Offerings

The ICN User Interface may contain third-party offerings. Please note that when you use such link, your data such as IP address, etc. are transmitted to these third parties. We have no control over, do not review and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these third-party websites or their content, or to any collection of your data after you click on links to such third-party websites. We encourage you to read the privacy notices of every website you visit. Any links to third-party apps and websites are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

12. Plug-Ins

We do not use plug-ins on the ICN User Interface. If the ICN User Interface contains icons from other third-party providers (e.g. Telegram, Discord, Twitter/X), we only use theses for passive linking to the pages of the respective providers.

13. Third-Party Platforms

We operate accounts on third-party platforms (e.g. Telegram, Discord, Twitter/X). If you communicate with us via our accounts or otherwise interact with our accounts on these third-party platforms, your data will also be processed according to the privacy notices of the respective platform. Please find further information on the purpose and scope of data collection and processing by the third-party providers in their respective privacy policies.

3. Legal Basis for Data Processing

Where we asked for your consent, we process your data based on such consent. Where we did not ask for your consent and where required under applicable law, we process your data on other legal grounds, such as:

• a contractual obligation;
• a legal obligation;
• a vital interest of the data subject or of another natural person;
• to perform a public task;
• our legitimate interest.

4. Transfer of Data to Third Parties

As part of our data processing, we may share your data with third parties, in particular to the following categories of recipients:

• Service Providers

We may share your information with service providers and business partners around the world with whom we collaborate to fulfil the above purposes (e.g. IT provider, KYC provider, advertising service provider, security companies, telecommunication companies, lawyers) or who we engage to process data for any of the purposes listed above on our behalf and in accordance with our instructions only.

• Contractual Partners

If required by the respective contract, we will pass on your data to other contractual partners, dealers, subcontractors, etc. 

• Legal Authorities

We may pass on data to offices, courts, and other authorities if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities are responsible for processing data about you that they receive from us.

5. Disclosure of Data Abroad

The data that we collect from you may be transferred to, processed, and stored in, a country outside the European Economic Area (EEA) or Switzerland. In view of the EEA or Switzerland the law in some of those countries may not offer an adequate level of data protection. We only transfer data to these countries when it is necessary for the performance of a contract or for the exercise or defence of legal claims, or if such transfer is based on your explicit consent or subject to safeguards that assure the protection of your data, such as the US-EU Data Privacy Framework, the US-CH Data Privacy Framework and/or the Standard Contractual Clauses approved by the European Commission (SCCs), adjusted according to Swiss law, all of the aforementioned if applicable and required.

6. Profiling and Automated Decision Taking

We might analyse aspects of your individual’s personality, behaviour, interest and habits make predictions or decisions about them for the purposes laid out in Section 2, e.g. to perform statistical analysis or to prevent misuse and security risks. This analysis identifies correlations between different behaviours and characteristics to create profiles for individuals. For example, we may use profiling to determine in which products or services you might be interested. We may also use profiling to assess your creditworthiness. We do not use profiling that can produce legal effects concerning you or similarly significantly affect you without human review.

In certain circumstances, automated decision taking might be necessary for reasons of efficiency and consistency. In such cases, we will inform you accordingly and take the measures required by applicable law.

7. On-Chain Data 

When you use blockchains, you acknowledge that your wallet address and other data/information provided by your transactions, which are considered personal data if relating to an identified or identifiable natural person, are permanently and publicly stored on-chain, which means such data is publicly available to anyone. Neither we, nor any third party, has any power to delete such data published by its users to the blockchain. If you want to ensure that your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be available or exercisable by you or us due to the technological infrastructure of the blockchain.

You hereby release and indemnify us of any liability associated with data that you transferred to the blockchain.

8. Retention and Storage of Data

We only process your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of complying with legal retention requirements and where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. Upon expiry of the applicable retention period, we will securely destroy your data in accordance with applicable laws and regulations.

9. Data Security

We take appropriate organizational and technical security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. However, we and your data can still become victims of cyber-attacks, cybercrime, brute force, hacker attacks and further fraudulent and malicious activity including but not limited to viruses, forgeries, malfunctions, and interruptions which is out of our control and responsibility. We have also put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Your Rights

To the extent provided for by applicable law, you may request information free of charge about the data processed relating to you, its origin and recipients and the purpose of the data processing. You may also have the right to correction, deletion, restriction, or objection to processing, as well as to the transfer of the data to another controller. Furthermore, you can revoke your consent at any time with effect for the future. All you need to do is send us an informal email to the above address. 

Please note that the foregoing rights are subject to legal restrictions and may interfere with or make impossible the provision of our services.

11. Amendment of this Privacy Notice

Due to continuous development of the ICN User Interface and the contents thereof, changes in law or regulatory requirements, we might need to change this Privacy Notice from time to time. Our current Privacy Notice can be found in the ICN User Interface.

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November 29, 2024

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