Last Updated on: 31st May 2018
Local Token S.L. (“Local Token Exchange”) understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits localtokenexchange.com and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of localtokenexchange.com;
means a small text file placed on your computer or device by localtokenexchange.com when you visit certain parts of localtokenexchange.com and/or when you use certain features of localtokenexchange.com. Details of the Cookies used by localtokenexchange.com are set out in section 12, below;
means this website, localtokenexchange.com;
“EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015
means Local Token S.L., a company registered in Spain under company registration number B-93548030, whose registered address is Avda. Ricardo Soriano 1 – 2a, 29601 Marbella, Malaga, Spain and whose main trading address is Avda. Ricardo Soriano 1 – 2a, 29601 Marbella, Malaga, Spain.
2. Information About Us
▪ Our Site, localtokenexchange.com, is owned and operated by Local Token S.L., a company registered in Spain under company registration number B-93548030, whose registered address is Avda. Ricardo Soriano 1 – 2a, 29601 Marbella, Malaga, Spain and whose main trading address is Avda. Ricardo Soriano 1 – 2a, 29601 Marbella, Malaga, Spain. Our TAX ID number is B-93548030.
▪ Our data protection officer is Luis Perez who can be contacted at [email protected]
▪ We are not currently regulated by the any official regulating bodies
▪ We are not currently members of any associations.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
Depending upon your use of localtokenexchange.com, We may collect some or all of the following data:
Date of Birth
Contact Information such as email addresses and telephone numbers
Demographic Information such as post code, preferences and interests
Financial Information such as credit / debit card numbers
IP address (automatically collected)
Web browser type and version (automatically collected)
Operating system (automatically collected)
A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
◦ All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
◦ We use your data to provide the best possible products and services to you. This includes:
▪ Providing and managing your Account;
▪ Providing and managing your access to localtokenexchange.com;
▪ Personalising and tailoring your experience on localtokenexchange.com;
▪ Supplying Our products and services to you;
▪ Personalising and tailoring Our products and services for you;
▪ Responding to communications from you;
▪ Supplying you with email updates e.g. newsletters, alerts etc. that you may have subscribed to (you may unsubscribe or opt-out at any time by contacting us;
▪ Market research;
▪ Analysing your use of localtokenexchange.com and gathering feedback to enable Us to continually improve localtokenexchange.com and your user experience;
◦ In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
◦ With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
◦ Advertisers whose content appears on localtokenexchange.com may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on localtokenexchange.com.
◦ Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
◦ We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data.
◦ Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.
◦ We use the following methods to store your data:
▪ Cloud-based digital storage
◦ Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our site. Steps We take to secure and protect your data include:
▪ Staff awareness training on the importance of personal data
▪ Data is only accessed by authorised personnel
▪ All staff have signed confidentially agreements
◦ Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
▪ We may share your data with other companies in Our group. This includes Our subsidiaries AND/OR Our holding company and its subsidiaries.
▪ We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
This is a list of third parties that we contract with and with whom some or all of your data might be shared with
◦ We may compile statistics about the use of localtokenexchange.com including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
◦ In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
◦ In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
◦ When you submit information via localtokenexchange.com, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account).
◦ You may also wish to sign up to one or more of the preference services operating in your country: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
◦ You may access certain areas of localtokenexchange.com without providing any data at all. However, to use all features and functions available on localtokenexchange.com you may be required to submit or allow for the collection of certain data.
◦ You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected], or using the contact details below in section 15.
• Google Analytics
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
1. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
2. The decision is authorised by law; or
3. You have given you explicit consent.
• Where We use your personal data for profiling purposes, the following shall apply:
1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
2. Appropriate mathematical or statistical procedures will be used;
3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
15. Contacting Us