Privacy Statement

PRIVACY NOTICE LAST UPDATED ON SEPTEMBER 7, 2018 1. Introduction Oneiro N.A. Inc. (“Oneiro”, “we” or “us”) has created this Privacy Notice to demonstrate our firm commitment to secure and trustworthy internet commerce and the individual’s right to privacy. This Privacy Notice defines Oneiro’s privacy policies and practices in relation to information that is collected by us through Oneiro’s ndau website (the “Website”) and its mobile application (the “Application”, and together with the Website: the “Platform”). WE STRONGLY URGE YOU TO READ THIS PRIVACY NOTICE AND MAKE SURE THAT YOU FULLY UNDERSTAND AND AGREE TO IT. IF YOU DO NOT AGREE TO THIS NOTICE, PLEASE DISCONTINUE AND AVOID BROWSING AND/OR MAKING ANY OTHER USE OF THE WEBSITE OR, IF YOU ARE USING THE APPLICATION, KINDLY CEASE ANY FURTHER USE AND UNINSTALL IT FROM YOUR DEVICE. PLEASE REVIEW SECTION ‎4 BELOW TO UNDERSTAND WHAT KIND OF PERSONAL DATA WE COLLECT. 2. Your Consent We will collect and process your Personal Data as described in this Privacy Notice. Where applicable, we will obtain your consent for such collection and/or use. However, with respect to Personal Data which is required for us to comply with applicable law, protect us, our affiliates and/or our users, your browsing of the Website, or your use of the Application (as applicable), will be deemed as your consent. 3. For What Purposes Do We Use Your Information? In general, we collect and use your Personal Data in order to comply with applicable law (where applicable), and in order to maintain and improve the operation of the Platform. This may include our need to understand how our Platform is used, to improve our customer service and support operations, and protect our users. These purposes reflect our legitimate interests. Accordingly, we use Personal Data for the following purposes: ” To verify your identity, and examine your eligibility to subscribe for our ndau tokens; ” To provide our users with customer care, assistance and technical support; ” To further develop, customize and improve the Platform and your user experience, based on personal or general experiences and difficulties; ” To contact our users (via e-mail, or any other available channels) with general or personalized service-related messages (such as tokens purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as updates, new features and services, newsletters, etc.); ” To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity; ” To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our third-party vendors may use to provide and improve our respective services; and, ” To comply with any applicable laws and regulations. Promotional Communications. We may also contact you via the email address you provide, in order to notify you about new services, events, and special opportunities or any other information we think you may find valuable. If you do not wish to receive such promotional communications, you may notify us at any time by contacting us or by following any “unsubscribe”, “stop”, or “change email preferences” instructions in the communications you receive. 4. How Do We Collect Your Information? We collect two main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data”): (a) Data Automatically Collected or Generated. When you visit, interact with, or use our Platform, we may collect or generate technical data about you. We collect or generate such data either independently or with the help of third-party services, including the use of “cookies” (as further detailed in our “cookies policy” [add link]). We may also utilize other tracking technologies which are specific to the Application. Such data consists of connectivity, technical, or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of users of our Platform. We do not use such data to learn a user’s true identity or contact details, but mostly to have a better understanding of how our users typically use the Platform. The use of such technical and device data also helps us to optimize our ad management and our users’ viewing experience, and to improve the overall user experience and functionality of our Website and the Platform. (b) Data Received from You. You may voluntarily provide us with Personal Data, such as your name, email address, phone number, location, financial information, and location when you contact us, including other information we require in order to verify your eligibility to use our services via the Platform. If you choose to give us your email address, we will communicate with you via email. We do not share your email address with others outside Oneiro. Depending on how your email application is set up, information about your actions or use of the email sent by us may be transmitted automatically when you receive, open, and/or click on that email. In any event, you may opt out from receipt of any additional emails from us at any time. 5. How Do We Retain and Store Your Information? Oneiro NA Inc., is a US corporation; however, it has taken upon itself to adopt all requisite security measures regarding the storage of your Personal Data, and to only use it in accordance with this Privacy Notice. While privacy laws may vary between jurisdictions, Oneiro has taken reasonable steps to ensure that your Personal Data is treated in a secure and lawful manner and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in other applicable jurisdictions. In general, we retain your Personal Data we collect from your browsing sessions for a period of 18-24 months from date of the last browsing session. We retain your Personal Data pertaining to your email address until you determine to unsubscribe from receiving emails from us. However, we may retain any portion of your Personal Data for a longer period for legal and accounting purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise). Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period and are free to securely delete it for any reason and at any time, with or without notice to you. 6. With Whom Do We Share Information? We may share your data (including Personal Data) with certain third parties, including law enforcement agencies and our affiliates (including Third Party Affiliates) – but only in accordance with this Privacy Notice: (a) Compliance with Laws, Legal Orders, and Authorities. We may disclose or allow government and law enforcement officials to access certain Personal Data in response to a subpoena, search warrant, or court order (or similar requirement), or in compliance with applicable laws and regulations, including national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing. (b) Service Providers and Business Partners. We may engage selected third-party companies and individuals to perform services complementary to our own, including but not limited to hosting services, data analytics services, e-commerce, user engagement services, email distribution and monitoring services, and our business, legal, and financial and compliance advisors (collectively, “Third-Party Affiliates”). These Third-Party Affiliates may have access to your Personal Data depending on each of their specific roles and purposes in facilitating the purposes of our Services and may only use it for such purposes. Currently, we engage the following Third-Party Affiliates: (A) Legal advisors (B) Financial consultants (C) Oneiro General Counsel (D) Third-party web developers and Platform storage service providers (c) Protecting Rights and Safety. We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property, or personal safety of Oneiro, any of our users, or any members of the general public. For the removal of doubt, Oneiro may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval. 7. Security Measures Oneiro maintains physical, electronic, and procedural safeguards to help guard your Personal Data. We restrict access to personally identifiable information to those persons who need to know that information to provide products or services to you and any persons you have authorized to have access to such information. While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us. 8. Transfer of Data Between the Oneiro Group Entities Currently, Oneiro does not have any group entities with which it shares your Personal Data. 9. Your Rights Regarding Your Personal Information We care about your privacy rights. Please note that you may have certain rights regarding the manner of collection, processing, and usage of your personal information pursuant to applicable privacy laws (such as the EU GDPR). Under the GDPR (to the extent it applies to you) you may be eligible for the following rights: o The right to have your Personal Data deleted. However, please note that we may limit this right in the event we are required to retain such Personal Data in order for us to comply with any legal obligation, or in the event that we believe that we require, or may require in the future, to use such Personal Date is required, for the purpose of exercising of a legal defense; o The right to access the Personal Data that we collect and process; o The right to rectify untrue or incorrect Personal Data; o The right to object to us processing your Personal Data. However, in cases you object to our processing of any Personal Data which we require to reasonably provide you with any services and/or otherwise make the Platform available to you, you will not be able to use such services, and your use of the Platform might be limited (in whole or in part); o The right to have your Personal Data exported at your request, which we will make efforts to comply with within a reasonable time and provide you with such compiled data through an electronic medium of our choice. o In the event that Oneiro will limit your use of the Platform on the basis of automatic decision making (including processing) regarding your Personal Data, or otherwise make such analysis available to any other person or entity, you will have the right to object to such profiling; and, o The right to lodge a formal complaint with the EU supervisory authority, if you believe that any of your rights under the GDPR were breached. Please note that the above list contains a summary of the main rights you may have under the GDPR. Under no circumstances shall the above be deemed as an exhaustive list. You are advised that as part of our protection measures, we may require certain identification before facilitating such rights in your favor. 10. Children The Platform is directed towards and designed for use by persons aged 16 and older. We do not solicit or knowingly collect Personal Data from children under the age of 16. If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 16, we will delete such information from our systems. 11. Links to Third Party Websites The Platform may contain links to other websites. While we try to link only to websites that share our respect for privacy, please be aware that Oneiro is not responsible for the privacy practices or the content of other websites. Websites that are accessible by hyperlinks from the Platform may use “cookies.” We encourage you to read the privacy statements provided by other websites before you provide personally identifiable information to them. 12. Changes to this Privacy Notice This Privacy Notice may change over time as we modify or expand our service. If we decide to change our Privacy Notice, we will prominently post those changes on this page. Other than where your opt-in consent is required under applicable law, your continued use of the Platform after we post such notice constitutes your agreement to any such changes. 13. Contacting Us If you have any questions about this Privacy Notice, or in the event that you wish to exercise certain rights for which you are eligible with respect to your Personal Data, please contact us using the information below. We welcome your questions and suggestions about our Privacy Notice. Contact Information: Mailing address: Oneiro N.A. Inc., 545 Boylston Street, Boston, MA 02116. Email: