Privacy Policy

Effective as of 17. September 2021.

Welcome to Blockademia's Privacy Policy!

Please note that this Privacy Policy applies to personal data that is collected and processed by Smart Contract Ltd., a company registered in Croatia, Zagreb, VAT number: HR26005457693 ( “Smart Contract“ , “we“ or “us“ ) who is responsible for ensuring that your Personal Data is processed in compliance with applicable regulations (the „Data Controller“).

Smart Contract, as a data controller, collects and processes personal data relating to interactions on the Website and Blockademia App (as defined in the Definitions section of the Terms of Use). This Privacy Policy describes how Smart Contract uses and protects any information that you give us.

This Policy applies to the data processing that takes place through or in connection with the following: (a) your use of the Website (as defined in Definition Section of our Terms of Use) (b) your use of the So]ware (as defined in Definition Section of our Terms of Use) (c) your use of the Blockademia app (as defined in Definition Section of our Terms of Use). We believe in full transparency, which is why we keep our Privacy Policy simple and easy to understand.

We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree with it. If you do not agree to this Privacy Policy, please do not access or otherwise use the Website and Blockademia app.

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Definitions section of the Terms of Use.

If you have any concern, question or if you would like to exercise any of your rights with respect to your Personal Data, you may contact our Data Protection Officer (“DPO”) at E- MAIL ADDRESS.

1. DEFINITIONS

2. DATA CONTROLLER

3. WHAT DATA DO WE COLLECT ABOUT YOU AND WHEN?

4. PERSONAL DATA WE PROCESS

5. WHAT WE DO NOT DO?

6. PERSONAL DATA SECURITY

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

8. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

9. HOW LONG DO WE KEEP YOUR DATA?

10. YOUR RIGHTS

11. CHANGES TO PRIVACY POLICY

12. COOKIE POLICY

 

1. DEFINITIONS

When we say “consent“ we mean your explicit consent on the processing of personal data. Persons who are 18 years of age or older depending on the applicable legislation in regard to the User may give free consent to the processing of their personal data.

When we say “cookies“ we mean small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookie Policy.

When we say “Data controller“ we mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

When we say “Data Processors“ or “processors“ we mean any natural or legal person who processes the data on behalf of the Data Controller. In addition, we may use the services of various service providers to process your data more effectively. In such cases, they are either our processors or sub-processors.

When we say “Data Subject“ , “you“ or “your“ we mean any natural person that shares personal data with us via Blockademia.

When we say “GDPR“ we mean the General Data Protection 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.

When we say “processing“ we mean any operation or set of operations which is performed on personal data or sets of personal data. This includes activities such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

When we say “personal data“ or “data“ we mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, either directly or indirectly. Therefore, data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data. For example, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, business e-mail addresses like This email address is being protected from spambots. You need JavaScript enabled to view it. . This Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).

2. DATA CONTROLLER

Smart Contract Ltd. is a company registered under the laws of Croatia, which, as a Data controller, determines the purposes and means of the processing of personal data. Controller is responsible for your personal data. The purpose of data processing is the reason why we process your personal data. The table in Section 4 of the Privacy Policy presents the purposes and legal basis for data processing. In such cases, Smart Contract is responsible for your personal data.

3. WHAT DATA DO WE COLLECT ABOUT YOU AND WHEN?

We may collect and receive information about you in various ways:

  • Information you provide through the use of the Blockademia Services, Blockademia Website and Blockademia app (for example, by creating the account on the Website).
  • Information you decide to provide through geing in touch with us via our Contact page.
  • Information we collect through the use of cookies in accordance with our Cookie Policy (for example, your time zone).

4. PERSONAL DATA WE PROCESS

5. WHAT WE DO NOT DO?

Smart Contract will never:

  • Sell any kind of personal information or data
  • Disclose this information to marketers or third parties not specified in Section 7
  • Process your data in any way other than stated in this Privacy Policy.

6. PERSONAL DATA SECURITY

Smart Contract takes the privacy and security of its members' personal information seriously. We maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.

Upon assessing whether a measure is adequate and which level of security is appropriate, we consider the nature of the personal data we are processing and the nature of the processing operations we perform, the risks to which you are exposed by our processing activities, the costs of the implementation of security measures and other relevant maoers in the particular circumstances.

Some of the measures we apply include access authorization control, information classification (and handling thereof), protection of integrity and confidentiality, data backup, firewalls, data encryption and other appropriate measures. We equip our staff with the appropriate knowledge and understanding of the importance and confidentiality of your personal data security.

We protect personal information you provide online in connection with registering yourself as a user of our Website or Blockademia app. Access to your own personal information is available through a password selected by you. This password is encrypted while transmioed from your browser to our servers and while stored on our systems. To protect the security of your personal information, never share your password to anyone. Please notify us immediately if you believe your password has been compromised.

Whenever we save your personal information, it’s stored on servers and in facilities that only selected Smart Contract personnel and our contractors have access to. We encrypt all data that you submit through the Website during transmission using Transport Layer Security (TLS) in order to prevent unauthorized parties from viewing such information. Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to Smart Contract. We never request that you submit sensitive or personal information over email, so please report any such requests to us by sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it..

Steps you can take to help us keep your information safe

There are many steps you can take to help us keep your information safe. First and foremost, choose complex, independent passwords for each website and service you maintain an account with. This helps keep any breach of any of your accounts isolated to one service. Also, don’t use anything related to your birthday, address, phone number, PIN number or any other easily guessable information in your password.

Smart Contract urges your caution when using public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, don’t use such computers to access your sensitive accounts, and if you must, ensure that you logout of your account entirely.

When either you or we update information in your account, such as the status of your account or ACI token (ACI) balance, we typically send you notice of these changes via email or text message. In recent years, individuals, businesses and even governments have seen a rise in “phishing” aoacks. Phishing occurs when someone aoempts to obtain your password or other sensitive information. Scammers o]en do this by impersonating a trusted user, or by offering a compelling reason to open a malicious email aoachment, click on a link or give over information. We never ask for your sensitive personal information, such as password, over email or other unsecure methods or through any site not under the revuto.com domain. Please notify us at This email address is being protected from spambots. You need JavaScript enabled to view it. if you ever receive suspicious correspondence from us.

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Smart Contract utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible.

We have strict due diligence procedures and measures in place and review, assess and background check all processors prior to forming a business relationship. We obtain company documents, certifications, references and ensure that the processor is adequate, appropriate and effective for the task we are employing them for.

We audit their processes and activities prior to contract and during the contract period to ensure compliance with the data protection regulations and review any codes of conduct that oblige them to confirm compliance.

This is the list of processors with whom we share your personal data:

We may also share your personal data with our outside accountants, legal counsels and auditors. Finally, personal information may be disclosed or transferred as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Blockademia.

8. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:

  • To the countries within the EEA;
  • To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
  • To the countries which do not belong to those specified under item 1. and 2, but only by applying the appropriate safeguard measure in accordance with the GDPR. We use servers located in the.

9. HOW LONG DO WE KEEP YOUR DATA?

The period for which we store your personal data depends on a particular purpose for the processing of personal data, as explained in detail in Section 4. We retain personal data for as long as we reasonably require it for legal or business purposes. In determining data retention periods, we take into consideration the applicable law (see Section 21 of the Terms of Use), contractual obligations, and the expectations and requirements of our Users. When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it.

However, as an exception to the retention periods in Section 4 the data may be processed to determine, pursue or defend claims and counterclaims.

10. YOUR RIGHTS

As a Data Subject in the EEA, whose personal information we hold, you have certain rights under the GDPR. This part of the Privacy Policy aims to give you a general understanding of these rights. In relation to each of the rights noted below, we provided a reference to the specific provision of the GDPR from which that right arises.

Right of Access (Article 15 GDPR)

You can send us a request for a copy of the personal data we hold about you.

We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data Subject and with prior verification as to the subject’s identity.

Information is provided to the Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.

Right to Correction of Your Personal Data (Article 16 GDPR)

If the personal data we have about you is incorrect, you have the right to request that we correct those data. Where notified of inaccurate data by the Data Subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.

Right to Be Forgoien or Right to Erasure (Article 17 GDPR)

You have the right to request from us that your personal data is deleted in certain circumstances including:

  • The personal data are no longer needed for the purpose for which they were collected;
  • You withdraw your consent (where the processing was based on consent);
  • You object to the processing and no overriding legitimate grounds are justifying us processing the personal data;
  • The personal data have been unlawfully processed; or
  • To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

  • To comply with a legal obligation; or
  • For the establishment, exercise or defense of legal claims.

Right to Restriction of Processing (Article 18 GDPR)

If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.

Right to Withdraw the Consent (Article 13(2)c) GDPR)

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

Right to Lodge a Complaint

If you have any concerns or requests in relation to your personal data, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. and we will respond as soon as possible but not later than within 30 days.

If you are unsatisfied with how we process your data, you may contact the competent supervisory authority.

In case you believe that we are processing your personal data in violation of the GDPR, you have the right to lodge a complaint with the supervisory authority located in the EEA where you reside or work or where the alleged infringement took place.

11. CHANGES TO PRIVACY POLICY

We reserve the right to change Privacy Policy from time to time at our sole discretion. If we make any changes, we will publish the new rules on this web page and, if we have your email, we will notify you directly.

Where you have previously consented to our Privacy Policy, your continued use of the Blockademia a]er we make changes is deemed to be acceptance of the updated rules.

12. COOKIE POLICY

This Cookie Policy describes the different types of cookies that may be applied by BLOCKADEMIA or by third-party organizations on this website or on our mobile application. The Cookie Policy is included in a separate document available on our website.

Contact

 
FOR POTENTIAL INVESTORS
 
 
MARKETING GENERAL INFORMATION
info@smartcontract.hr

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