Welcome to the Shares Crypto Ambassador Privacy Notice (‘Notice’). This Notice explains how Shares collects, uses and transfers the personal data of Ambassadors and provides clarity on how it does so lawfully. If there are any material updates made to this Notice we will contact you and let you know. If any of your information changes, please let us know.
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Crypto Ambassador Privacy Notice
Who does this Notice apply to?
Firstly, we’ll formally introduce ourselves. We’re Shares Digital Assets (referred to as ‘Shares’, ‘we’, ‘us’, ‘ours’ throughout this Notice). We control the personal data of Shares Crypto Ambassadors (referred to as ‘Ambassador’, ‘you’, ‘yours’ throughout this Notice). Our address is ul. Mogilska 43, 31-545 Kraków. We’ll control your personal data.
Ambassadors are those who perform Services in accordance with the Crypto Ambassador Agreement (‘the Contract’). As the performance of such activities requires Ambassadors to have a Shares account on the App, this Notice provides you with information specific to the data processing we perform in relation to your personal data as a Ambassador and should be read in conjunction with our User Privacy Policy (available here: https://shares.io/pl/privacy-policy-eu/), which also applies to you and provides information relating to our processing of users’ personal data.
What personal data do we process about you?
In addition to the personal data outlined in our User Privacy Policy, we collect your:
- Personal and contact details,
- Social media details,
- Contract and associated legal documentation,
- Background information, including qualifications / experience,
- Proof of identification(s),
- Correspondence,
- Shares account details,
- Shares account activity,
- Publicly available information.
Where do we collect your personal data?
From public sources. We may collect your personal data from publicly available sources, such as Google and LinkedIn.
From You. We may collect your personal data from you. You provide us with this data when corresponding, contracting and engaging with Shares.
From content you generate. We may collect your personal data from engagements you have on the platform or from content you generate there.
Why and how do we process your personal data?
We process your personal data for the purposes laid out in our Contract, which have been summarised as follows:
- To ensure that you are a suitable Ambassador;
- To enable you to provide the Services;
- To remunerate you appropriately;
- To oversee your activity on the App;
- To monitor and assess your performance as an Ambassador;
- To determine the appetite for and the success of the Inner CIrcle or any variation or evolution thereto;
- To improve and enhance engagement on the platform;
- Additional purposes may also be applicable but not expressly stated here.
You are obligated to provide personal data for the purposes of the Contract. Failing to do so may result in the breach and / or termination of the Contract.
We process this data as it is necessary for the fulfillment of our Contract, for our legitimate interests (to monitor and grow the platform, investigate relevant matters and defend ourselves against any legal claims) and to comply with our legal obligations as a company that provides regulated services.
Do we transfer your personal data outside of the UK & EEA?
We may transfer your data outside the UK or the European Economic Area (EEA).
Whenever we transfer your personal data out of the UK or the EEA, we make sure it’s given a similar degree of protection by guaranteeing at least one of the following safeguards is implemented:
- We’ll only transfer your personal data to countries that provide an adequate level of protection for personal data by the European Commission;
- We’ll make sure that appropriate contractual protections are in place with third parties that we share personal data with outside of the EEA & UK (as approved by the European Commission or the Polish Chairman of the Data Protection Office where relevant).
How long do we retain your personal data?
We will retain your personal data for no longer than is absolutely necessary to fulfill our legitimate interests, contract and / or legal obligations, where appropriate.
As previously mentioned, the Shares User Privacy Policy also governs our use and retention of your personal data however there may be times where this data is required to be retained for longer, given the special nature of your role on the platform as a Ambassador.
What rights do data subjects have over their personal data?
In certain circumstances, you have the right under data protection law to:
- Request access to your personal data. This is the right to access and receive a copy of your personal data and other supplementary information. This right is not absolute and may be subject to certain limitations and exemptions.
- Request correction of your personal data. This is where we’ll rectify inaccurate or incorrect data we process about you.
- Request erasure of your personal data. This is the right to request the erasure of your personal data. This right is not absolute and may be subject to certain limitations, depending on our lawful basis for processing your personal data.
- Object to our processing of your personal data. This is only an absolute right when related to direct marketing. For all other data processing, you can object. We‘ll then review and process your request subject to relevant limitations, such as the lawful basis for processing your personal data in the first instance.
- Request restriction of processing your personal data. This is not an absolute right. Where you have a particular reason for requesting that we restrict our processing of your data, you can request to do so. This may limit the way we use your personal data.
- Request transfer of your personal data. This is the right to data portability; it allows individuals to obtain and reuse their personal data for their own purposes across different services.
- Right to withdraw consent. Where you have provided your consent for us to process your personal data, you have the right to withdraw such consent.
- Right to object to solely automated decision-making and profiling that produces legal or similar effects. This right is not relevant to Shares’ users as we do not presently participate in data processing that is solely automated and makes decisions which have a legal (or similar) effect.
Should you wish to make such a request, you can do so by messaging us in the ‘Support’ section of the Shares app or emailing us at privacyrequests@shares.io. You can also opt out of direct marketing by clicking unsubscribe at the bottom of any marketing email.
Generally, you don’t have to pay a fee to exercise any of these rights, and we'll confirm completion of your request within one calendar month.
However, we may charge a reasonable fee or extend our timeline for responding in cases where a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We’ll always notify you in the event this occurs.
You have the right to make a complaint at any time to the relevant data protection authority:
- in Poland: Personal Data Protection Office (UODO), https://uodo.gov.pl/en
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or UODO so please contact us or our DPO in the first instance.
How can you contact our DPO?
In accordance with data protection legislation, Shares has appointed a Data Protection Officer (DPO). You can contact our DPO in a number of ways:
- In writing. FAO: The DPO, Shares Digital Assets Spółka Z Ograniczoną Odpowiedzialnością, Mogilska 43 Cowork ul. Mogilska 43 31-545 Kraków Polska.
- By email.eu-dpo@shares.io
The DPO is there to assist data subjects generally. However, the most efficient way to exercise your rights under data protection legislation is by emailing: privacyrequests@shares.io
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