Iris.ai BG has implemented numerous technical and organizational measures to ensure the most complete protection of the personal data processed for Project Aiur and assure that the processing of personal data will always be in line with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”/”GDPR”/”Regulation”) and the Bulgarian Personal Data Protection Act.
1. Personal data is any information relating to an identified or identifiable natural person;
2. Data subject is any identified or identifiable natural person;
3. Processing is any operation or set of operations which is performed on Personal data or on sets of Personal data;
4. Рseudonymisation means the processing of personal data in such a manner that the Personal data can no longer be attributed to a specific Data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal data are not attributed to an identified or identifiable natural person;
5. Controller is the legal person Iris.ai BG EOOD which alone determines the purposes and means of the processing of Personal data;
6. Processor is a natural or legal person, public authority, agency or other body which processes Personal data on behalf of a controller;
II. Identity and contact details of the Controller
Bulgarian limited liability company
15-17 Tintyava Street, Dianabad
represented by Georgi Dimitrov Dimitrov
Any Data subject may, at any time, contact any of us directly with all questions and suggestions concerning data protection.
III. Registration for Project Aiur
Project Aiur provides for 3 (three) categories of community members which will be introduced in terms of risks: anonymous, semi-verified and fully verified.
Anonymous community members will not provide any Personal data, except for wallet ID, and they will be able to do transactions at very limited amounts as of: up to 15 AIUR tokens a day, up to 60 AIUR tokens a week, and up to 120 AIUR tokens a month, as they cannot hold in their account more than 60 AIUR tokens at any point in time.
Semi-verified community members will need to provide their names, date of birth and nationality for a verification purposes and they will be able to do transactions at limited amounts as of: up to 70 AIUR tokens a day, 280 AIUR tokens a week and 560 AIUR tokens a month, as they cannot hold in their account more than 280 AIUR tokens at any point in time.
Fully-verified community members will need to provide names, date of birth, nationality, scanned ID and selfie for verification purposes, as they will also be checked against sanctions lists and they will be able to do transactions at unlimited amounts.
The verification of the Data subject, with the voluntary indication of Personal data, is intended on one hand, to enable the Controller to offer the Data subject contents or services, and on the other hand, to meet the Anti-Money Laundering (AML) requirements for prevention the use of the ICO projects and token sales for money laundering and terrorist financing. All such data is used for the purposes of verification only.
Although the Controller is not required to perform AML measures, it is possible that in the future AML obliged entities might be broadened to include companies performing ICO and token sale, thus the good practices require the verification of buyer’s identity and residency and we have decided to perform Know Your Client (“KYC”) procedures. Regarding this, we have decided to use an independent KYC Provider – SHUFTI PRO LIMITED, a company incorporated in England, United Kingdom, registration number 11039567, which will be involved in the process and will be handling with the KYC forms and the token buyer’s data, as well as provide the Controller with final conclusions on the processed and verified data.
The Controller has taken into account and applied all the organizational and technical measures, including pseudonymisation of Personal data, as described in Section X, that the Controller together with the KYC provider apply so that they ensure sufficient technical and organisational measures in such a manner that processing will meet the requirements of the Regulation and ensure the protection of the rights of the Data subject.
IV. Subscription for Aiur updates
Data subjects are given the opportunity to subscribe for updates for the Project Aiur via the Website’s subscription field. Data subjects may at any time revoke a given consent and for this purpose a corresponding link is found in each email sent for updates.
V. Legal basis for the processing
Article 6(1) lit. b GDPR serves as the legal basis for processing operations for which the processing of Personal data is necessary for the performance of a contract to which the Data subject is party, as is the case of the registration and verification of semi-verified and fully-verified community members with regard to the concluded by them contracts with us in order to provide them with the relevant services requested. The same applies to such processing operations which are necessary for carrying out pre-contractual measures.
VI. Possible consequences of failure to provide such data
The non-provision of the Personal data would have the consequence that the service requested by the Data subject could not be provided, i.e. the Data subject would not be able to get verified and purchase the relevant amount of AIUR tokens as described hereinabove in Section III.
VII. Period for which the personal data will be stored
Personal data is stored up until the termination of community member’s account. After that, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or there is no other legal ground on processing the data.
Except for SHUFTI PRO LIMITED, as stated above, we may disclose Personal data of the Data subjects to other processors, something we would need to do in order to provide the Data subjects with the relevant services requested. Such other processors, may be other KYC providers, Service providers, like Amazon (https://www.amazon.com), GitHub, Inc (https://github.com), and other. We shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the Regulation and ensure the protection of the rights of the Data subject.
IX. Rights of the Data subject
1. Right of confirmation
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor confirmation as to whether or not Personal data concerning him or her are being processed.
If a Data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the Controller/Processor.
2. Right of access
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor free information about his or her Personal data stored at any time and a copy of this information. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data subject, this information shall be provided in a commonly used electronic form. Furthermore, the European regulations grant the Data subject access to the following information:
– the purposes of the processing;
– the categories of personal data concerned;
– the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
– the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period;
– the existence of the right to request from the Controller/Processor rectification or erasure of Personal data, or restriction of processing of Personal data concerning the Data subject, or to object to such processing;
– the existence of the right to lodge a complaint with a supervisory authority;
– where the Personal data are not collected from the Data subject, any available information as to their source;
– the existence of automated decision-making, including profiling.
Furthermore, the Data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the Data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a Data subject wishes to avail himself of this right of access, he or she may, at any time, contact the Controller/Processor.
3. Right to rectification
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor without undue delay the rectification of inaccurate Personal data concerning him or her. Taking into account the purposes of the processing, the Data subject shall have the right to have incomplete Personal data completed, including by means of providing a supplementary statement.
If a Data subject wishes to exercise this right to rectification, he or she may, at any time, contact the Controller/Processor or directly make the necessary changes from the functionalities of the account.
4. Right to erasure (Right to be forgotten)
Each Data subject shall have the right granted by the European legislator to terminate his or her account and obtain from the Controller/Processor the erasure of Personal data concerning him or her without undue delay and, and the Controller/Processor shall have the obligation to terminate the account and erase the Personal data without undue delay, as long as the there is no other legal ground for the processing.
If a Data subject wishes to terminate his or her account and erase his or her Personal data stored by us, he or she may, at any time, contact the Controller/Processor or directly erase his/her account.
5. Right of restriction of processing
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor restriction of processing where one of the following applies:
– accuracy of the Personal data is contested by the Data subject, for a period enabling the Controller/Processor to verify the accuracy of the Personal data;
– processing is unlawful and the Data subject opposes the erasure of the Personal data and requests instead the restriction of their use instead;
– Controller/Processor no longer needs the Personal data for the purposes of the processing, but they are required by the Data subject for the establishment, exercise or defence of legal claims;
– Data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller/Processor override those of the Data subject.
If one of the aforementioned conditions is met, and a Data subject wishes to request the restriction of the processing of Personal data, he or she may at any time contact the Controller/Processor.
The Controller/Processor, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the Personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller/Processor shall inform the Data subject about those recipients if the Data subject requests it. We will arrange all the necessary measures in any individual cases.
6. Right to data portability
Each Data subject shall have the right granted by the European legislator, to receive the Personal data concerning him or her, which was provided to a Controller/Processor, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the Controller/Processor to which the Personal data have been provided, as long as the processing is based on consent, or on a contract, and the processing is carried out by automated means.
Furthermore, in exercising his or her right to data portability, the Data subject shall have the right to have Personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the Data subject may at any time contact the Controller/Processor.
7. Right to object
Each Data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of Personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Controller/Processor shall no longer process the Personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data subject, or for the establishment, exercise or defence of legal claims.
If the Controller/Processor processes personal data for direct marketing purposes, the Data subject shall have the right to object at any time to processing of Personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the Data subject objects to the processing for direct marketing purposes, we will no longer process the Personal data for these purposes.
In addition, the Data subject has the right, on grounds relating to his or her particular situation, to object to processing of Personal data concerning him or her by the Controller/Processor for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the Data subject may contact the Controller/Processor. In addition, the Data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
8. Automated individual decision-making, including profiling
We do not perform automated decision-making and profiling.
9. Right to withdraw data protection consent
Each Data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her Personal data at any time.
If the Data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the Controller/Processor.
10. Right to a complaint
Each Data subject shall have the right granted by the European legislator to lodge a complaint with the competent supervisory authority and before the competent courts of the Member States of his or her habitual residence, place of work or place of the alleged infringement if the Data subject considers that the processing of personal data relating to him or her is in breach of the provisions of the GDPR.
The competent supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection with address: Sofia 1592, 2 Prof. Tzvetan Lazarov Str., Phone: 02 / 91-53-518, e-mail: email@example.com, website: www.cpdp.bg.
11. Right to information on action taken
Each Data subject shall have the right granted by the European legislator to be provided by the Controller/Processor with information on action taken on a request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller/Processor shall inform the Data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the Data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data subject.
12. Right to information in case of data breach
Each Data subject shall have the right granted by the European legislator to be informed without undue delay by the Controller/Processor about a personal data breach which is likely to result in a high risk to the rights and freedoms of natural persons.
X. Security of the Personal data
We have implemented all kinds of technical and organisational measures to ensure that processing is carried out in accordance with the GDPR, including:
1. pseudonymisation of Personal data;
2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
3. the ability to restore the availability and access to Personal data in a timely manner in the event of a physical or technical incident;
4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
The Controller, together with the KYC provider SHUFTI PRO LIMITED, have implemented appropriate technical and organisational measures, such as pseudonymisation on the Personal data provided by the Data subjects for verification purposes. Those measures include minimization on the Personal data transmitted to the Controller by the KYC provider SHUFTI PRO LIMITED, such as wallet ID and KYC provider ID only, excluding any other Personal data concerning the Data subject. KYC provider SHUFTI PRO LIMITED processes all the necessary data for verification purposes of the community members and does not transmit those data to the Controller, except for, as stated above, wallet ID and KYC provider ID.
These measures are designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.
If you believe that any information about you is false or inaccurate, please inform us as soon as possible writing to: firstname.lastname@example.org.
Last updated: June 21st 2018