Last Update: 03.11.2021

Privacy and Cookies Policy

We are committed to protecting the privacy and security of your personal information.

This policy (hereinafter “Policy”) explains how PDL Development OÜ processes (i.e collects, uses, stores, shares) and protects any Personal Data we collect from you, or that you provide to us when using our webpage https://padlocktoken.io/ (hereinafter Website) and/or purchasing PadLock token or by any other means of communication if such option has been made available.

DEFINITIONS

The following definitions (if capitalized) have been given the following meaning:

“Data Subject” means natural person whose Personal Data is being collected, held or processed.

“GDPR” means 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.

“Personal Data” means any information relating to an identified or identifiable natural person User.

“Personal Data Processing” means any operation or set of operations which is performed on the Personal Data of a Data Subject.

“Principles” means principles relating to processing of Personal Data as set out in GDPR and applied to all Personal Data Processing made by us.

“Website” means website https://padlocktoken.io/, operated by PDL Development OÜ for the purposes of providing information on its services and communication with the Users.

“Third Party” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Website.

“User” means any legal or natural person who visits and uses the Website and its functions.

“Contact Form” means the contact form provided on the Website allowing Us to connect to the Users to give information regarding our services.

ABOUT US

This policy applies to current and former users of our Website. This notice does not form part of any contract nor does it constitute or imply any offer of purchase or any kind to you. We may make changes to this policy at any time, which will be posted on this page. Changes to the terms of this policy will take effect from the time they are disclosed on this page. Please check back frequently to see any changes to this policy.

While using our Website or communicating with us via our Website or any other means, if such possibilities are available, the controller of your Personal Data is.

PDL Developments OÜ
Register code: 16356325
Legal address: Pärnu mnt 22, 10141, Tallinn
e-mail: info@padlocktoken.com

PRINCIPLES

We will always take into account the interests, rights and freedoms of Data Subjects.

All the processes, guidelines, operations and activities that are related to Personal Data Processing are based on the following principles:

  • Lawfulness. There is always a legal basis for the Personal Data Processing;
  • Fairness. Personal Data Processing will be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed;
  • Transparency. Personal Data Processing will be transparent for the Data Subject;
  • Purposefulness. Personal Data will be collected for legitimate purposes that have been established precisely and clearly and will not later be processed in any manner which is in conflict with these purposes. A Data Subject will always be able to examine the established purpose of Processing for a specific purpose;
  • Minimisation. Personal Data will be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. We will be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected, the personal Data will be deleted or archived.
  • AccuracyPersonal Data will be correct and will be updated as necessary, and all reasonable measures will be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing will be deleted or corrected without delay.
  • Limit of storage. Personal Data will be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. If we wish to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data it shall anonymise the data in such a manner that the Data Subject will not be identifiable. We will store the Data received in accordance with the law. The data processed under the basis of consent will generally be retained until the consent is withdrawn.
  • Reliability and confidentiality. Personal Data Processing will be carried out in a manner which ensures adequate security of Personal data.
PERSONAL DATA PROCESSING

We process Personal Data of our Users in order to enable them to contact us and provide our Users with information regarding our services they will find necessary.

We collect your Personal Data mainly in the following ways:

  • Personal Data you provide in the Contact Form available on the Website;
  • Information we receive from third parties (i.e Google Analytics)
  • Automatically collected data (cookies, browser data etc.)

We assume that the Users will submit true information which is related to their own natural person or the person they are representing.

Google Analytics is a web analytics tool that helps you analyse your website traffic.

LEGAL BASES FOR THE USE OF PERSONAL DATA

We use the collected information to engage the Users and to provide information about the goods and services of PDL Development OÜ and marketing materials related to them.

We may use this information in the following ways under the applicable legal basis:

  • Performance of a contract or taking pre-contractual steps at the request of a Data Subject (GDPR art 6 (1)(b)). We process Users’ Personal Data on the assumption that the User is interested in entering into contractual relationship for the purposes of getting access to the goods and services of PDL Development OÜ. We also process Users’ Personal Data to communicate with Users regarding any contractual agreements the parties have entered into.
  • Legitimate Interest (GDPR art 6 (1)(f)). We may process Users’ Personal Data where it is in our legitimate interests to do so as an organisation and without prejudicing Users’ interests or fundamental rights or freedoms. We may process Users’ Personal Data in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. We may also process data on legal persons in order to forward them marketing materials regarding the goods and services of PDL Development OÜ.
  • User’s consent (GDPR art 6(1)(a)). We will require the User’s consent allowing us to communicate to the User about the goods and services of PDL Development OÜ. We may request you to provide us with your consent also to perform other processes of Personal Data Processing which have not been mentioned before. The User has always the right to refuse this content. The Users does not have to give us any personal information in order to browse our website.
TRANSFER OF PERSONAL DATA TO THIRD PARTIES

Users’ Personal Data is only accessible to authorized persons who are obliged not to disclose your Personal Data to anyone.

We share your Personal Data only in accordance with the Principles and under the legal bases we have been outlined in this Policy.

We do not share your Personal Data with third parties unless it is necessary to provide services to you, you have consented to it or is required by law.

We may share and disclose your Personal Data in limited circumstances such as:

  • To an accountant or auditor, if such service is outsourced;
  • To other service providers, whose services are necessary for our everyday operations (i.e IT services);
  • If the sharing of Personal Data is required to fulfill obligations deriving from applicable law;
  • If you have consented to share and disclose your Personal Data with other third parties;
RETENTION OF DATA

The information we have stored for the purpose of fulfilling our contractual obligations or obligations arising from the pre-contractual negotiations will be stored for 3 years, or in case there is a risk of any potential claims towards us, for as long as all opportunities to submit such claims have been exhausted and all claims have been expired. This is necessary for us to be able to protect ourselves.

RIGHTS OF THE DATA SUBJECT

The Data Subject has a right to request access to own data. The User has the right to request from us to transmit the Personal Data collected about the User.

The Data Subject has a right to request correction of data if the data at our disposal is incorrect.

The Data Subject has a right to request deletion of data stored by us. First, where the data is processed based on a legitimate interest or User’s consent. The deletion of Personal Data is not possible, where data processing or storage is necessary to perform an obligation arising from law, the data is necessary for the performance of the objective for which it has been collected. If we are unable to delete the data, we will explain this to the User.

The Data Subject has a right to submit an objection to an action of Personal Data Processing, where the processing of Personal Data is performed on the basis of legitimate interest.

The Data Subject has a right to restrict the processing of Personal Data if:

  • The User has challenged the correctness of the Personal Data, until we have controlled the correctness of it;
  • The processing of Personal Data is illegal, but the User does not want the Personal Data to be deleted;
  • The User requires the Personal Data to compose a legal claim, to present or to defend such claim;
  • He User has objected to the data processing until we control whether our legitimate justifications outweigh the User’s reasons.

To exercise these rights, please contact us by e-mail at info@padlocktoken.com. If you are concerned about a potential breach of the General Data Protection Regulation or other legislation on personal data in connection with the use of the Website, please also contact us by e-mail at info@padlocktoken.com. If you are not happy with the way your complaint has been resolved, you can file a complaint with the Estonian Data Protection Inspectorate (phone: +372 5620 2341; e-mail: info@aki.ee; postal address: Tatari 39, Tallinn, Estonia).

COOKIES

Our Website uses cookies to distinguish you from other users of our Website. This helps us improve your experience when you browse our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Cookies allow the Website to recognize the visitor’s device. Different cookies may have many different functionalities, but the most common ones are usually used for enabling different functionalities on the website (strictly necessary cookies). For more information, see www.aboutcookies.com.

Cookies can be either first-party cookies or cookies which are set by our Website. Third-party cookies are set by someone other than the owner of the Website you’re visiting. Third-party cookies on the Website are presented by companies with whom we work with.

Our Website may use the following cookies:

  1. Strictly necessary cookies. These are cookies that are required for the operation of our Website.
  2. Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, i.e. remember your preferences (for example, your choice of language or region).
  4. Targeting cookies.These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
COOKIES USED BY PDL DEVELOPMENT OÜ

Third party cookies:

Google Analytics: gtag.js and analytics.js (Universal Analytics) - cookie usage

The analytics.js JavaScript library or the gtag.js JavaScript library can be used for Universal Analytics. In both cases, the libraries use first-party cookies to:

  • Distinguish unique users
  • Throttle the request rate

When using the recommended JavaScript snippet cookies are set at the highest possible domain level. For example, if your website address is blog.example.co.uk, analytics.js and gtag.js will set the cookie domain to .example.co.uk. Setting cookies on the highest level domain possible allows measurement to occur across subdomains without any extra configuration.

Note: gtag.js and analytics.js do not require setting cookies to transmit data to Google Analytics.

gtag.js and analytics.js set the following cookies:

Cookie Name Default expiration time Description
_ga 2 years Used to distinguish users.
_gid 24 hours Used to distinguish users.
_gat 1 minute Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_ <'property- id>.
AMP_TOKEN 30 seconds to 1 year Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<'property-id> 90 days Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.

We ask for your consent before we load any third-party cookies or cookies that are not strictly necessary into your browser or device. Strictly necessary cookies are essential to enable you to use the full functionalities of our Website and therefore we are not required to collect your consent before using them.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

DATA PROTECTION CONTACT

If you have any questions or comments about this policy our how we process your personal data, please contact PDL DEVELOPMENT OÜ by email at info@padlocktoken.com