International and EU GDPR

Blok Host LLC, a company registered in St. Vincent and the Grenadines (the “Company”), declares the following Privacy Policy, confirming that every defined word or term has the same meaning and purpose as stated in its relevant Website Terms and Conditions (“T&Cs”), in relation to:

I. any information the Company collects about the User when he/she uses any of the Company’s software services, and/or otherwise interacts with any Company product and/or member of the Company’s Team;
II. how the Company uses, shares, stores, and secures the information; and
III. how the User may access and control that information.

  1. User Information.
    1.1. The Company may collect any ''Personal Information'', which is any data, information, or combination of
    data and information that is provided by the User to the Company, or through the use of the Company software
    and that relates to an identifiable individual, including throughout any interactions with the Company's website.
    1.2. The Company collects the Personal Information when it is provided by the User or when the User interacts
    with the Company's software.
    1.3. The Company does not collect sensitive data or special category data about the User. This includes details
    about race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual
  2. Information Usage.
    2.1. The Company will only use any Personal Information that the applicable law allows to and in particular:
    2.1.1. to provide customer support and personalized features, and to protect the safety and security of
    the software;
    2.1.2. to satisfy a legitimate interest which is not overridden by the User’s fundamental rights or data
    protection interests, for example for research and development, and in order to protect the Company’s
    legal rights and interests;
    2.1.3. when the User consents to do so for a specific purpose;
    2.1.4. when the Company needs to comply with a legal or regulatory obligation.
    2.2. When the User has given consent to use any Personal Information for a specific purpose, he/she has the
    right to withdraw said consent at any time by contacting the Company, but this will not affect any use of the
    Personal Information that has already taken place.
    2.3. The Company does not share any Personal Information with any company outside its own group, if
    applicable, for marketing purposes, unless there is an express specific consent to do so.
    2.4. For users of the software who are located in the European Union, the legal bases for processing
    their information are published in the Legal Bases Table at the end of this Policy under Clause 9.
  3. Information Sharing.
    3.1. The Company may share Personal Information with third parties that help it operate, provide, support,
    improve, and market its software, products, and services, for example, third-party service providers who provide
    website and application development, data storage and backup, infrastructure, payment processing, customer
    support, business analytics, Anti-Money Laundering (''AML'') and Know Your Customer checks (''KYC'') and
    other relevant services.
    3.2. Third-party service providers have access to Personal Information only for the purpose of performing their
    services and in compliance with applicable laws and regulations. These third-party service providers are required
    to maintain confidentiality and security of all Personal Information that they process on the Company’s behalf
    and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and
    availability of any Personal Information.
    3.3. The Company takes reasonable steps to confirm that all third-party service providers process Personal
    Information in a manner that provides at least the same level of protection as is provided under this Privacy
    Policy. Where any third-party service provider is unable to satisfy these requirements, any reasonable steps to
    prevent or stop non-compliant processing will be taken.
    3.4. The Company may share Personal Information on an aggregated or de-identified basis with third parties for
    research and analysis, profiling, and similar purposes to help the improvement of products and services.
    3.5. If the Users use any third-party software in connection with our products or services, third-party software
    providers can gain access to the Personal Information. Policies and procedures of third-party software providers
    are not controlled by the Company, and this Privacy Policy shall not cover how any Personal Information is
    collected or used by third-party software providers. The User is encouraged to review the privacy policies of
    third-party software providers before using third-party software.
    3.6. The software may contain links to third-party websites over which the Company has no control. If the Users
    follow a link to any of these websites or submit information to them, any Personal Information will be governed
    by their policies. We encourage the User to review the privacy policies of third-party websites before submitting
    any information to them.
    3.7. The Company may share any Personal Information with government and law enforcement officials to
    comply with applicable laws or regulations.
  4. Information Storage
    4.1. All Personal Information provided by the User is stored on the Company’s servers or on a third-parties
    server to which only the Company has access to within the boundaries of relevant laws and regulations.
    4.2. The Company only retains Personal Information for so long as it is reasonably necessary to fulfill the
    purposes they were collected for, including for the purposes of satisfying any legal, accounting, or reporting
  5. International Transfer of Information
    5.1. The Company collects any Personal Information globally and transfers, processes, and stores any Personal
    Information outside the User’s country of residence where the Company’s or any third-party service providers
    operate for the purpose of providing the products and services.
    5.2. Some of the Countries in which the Company or third-party service providers are operating or are
    located may not have the privacy and data protection laws that are equivalent to those in the User’s
    country of residence. When Personal Information is shared with these companies or third-party service
    providers, use is made of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard
    the transfer of any Personal Information.
  6. User’s rights
    6.1. The User has the following right to:
    6.1.1. be informed of what the Company does with the relevant Personal Information;
    6.1.2. request a copy of relevant Personal Information the Company holds;
    6.1.3. require the Company to correct any inaccuracy or error in any Personal Information held;
    6.1.4. request erasure of any relevant Personal Information, except the one held for record-keeping
    purposes, to complete transactions, or to comply with legal obligations);
    6.1.5. object to or restrict the processing of any relevant Personal Information (including for marketing
    6.1.6. request to receive some of the relevant Personal Information in a structured, commonly used, and
    machine-readable format, and request that it is transferred to another party; and
    6.1.7. withdraw consent at any time where the Company is relying on consent to process the relevant
    Personal Information (although this will not affect the lawfulness of any processing carried out before
    such consent withdrawal).
    6.2. The software enable Users to update certain information about themselves.
    6.3. The User may opt-out of receiving marketing materials from the Company by expressly contacting it.
    However, the User will continue to receive notifications or information that are necessary for the use of the
    Company’s products or services.
    6.4. As a security measure, the Company may need specific information from the User to help confirm his/her
    identity when processing any privacy requests or when you exercise the rights stated in this Clause.
    6.5. Any request under paragraph 6.1 will normally be addressed free of charge. However, the Company may
    charge a reasonable administration fee if the request is clearly unfounded, repetitive, or excessive.
    6.6. The Company will respond to all legitimate requests approximately within one (1) month. Occasionally, it
    may take longer than one (1) month if the request is particularly complex or if the users have made a number of
  7. Policy Changes
    7.1. The Company reserves the right to amend this Privacy Policy from time to time by posting the updated
    Privacy Policy on the software or connected website or app store. By continuing to use the Company’s
    software after the changes come into effect, the User agrees to be bound by the revised policy.
  8. Children Privacy Policy
    8.1. The Company’s products and services are not directed or intended for individuals not major of age in their
    country of residence. The Company does not knowingly collect any personal information from individuals not
    major of age and if this will be detected, steps will be taken to delete such information.
  9. European Union Users - GDPR
    9.1. If the User is interacting with the Company’s software from the European Union (''EU''), that may differ
    from privacy laws under other jurisdictions. The User acknowledges that he may be transferring relevant
    Personal Information to the Company for storage and processing in other countries around the world for the
    purposes described under this Privacy Policy. The Company takes the utmost care in protecting any relevant
    Personal Information and has put in place adequate mechanisms to protect it when it is transferred
    9.2. The Legal Bases for collecting and using any relevant Personal Information if the User is a citizen or
    resident of the EU, will depend on the Personal Information concerned and the specific context in which it is
    Performance of a contract. The use of any relevant Personal Information may be necessary to perform
    the terms and conditions or other policies under which we operate our software.
    Consent. The User consent is needed if technical information such as cookie data and geolocation data
    is necessary, and any relevant Personal Information is used for marketing purposes. The User may
    withdraw his/her consent at any time by contacting the Company directly.
    Legitimate interests. The Company may use any Personal Information for its legitimate interests to
    improve its software, for security purposes, and fraud prevention, and to share information with any
    affiliates for internal administration. In such circumstances, the Company ensures that these interests are
    not overridden by the User’s data protection interests or fundamental rights and freedoms.
    9.3. Legal Bases Table

    Processing purpose

    Type of data processed

    Legal bases

    To enable the User to access products and services

    Account Data, Transaction Data, Support Data, Technical Data [and User Content]

    Contract performance

    To administer and maintain he safety and security of the software

    Technical Data

    Contract performance

    Technical Data To study the usage of products or services

    Transaction Data, Support Data, Technical Data, Usage Data

    Legitimate interest to improve the software

    To gather feedback on products, services, or features

    Account Data

    Legitimate interest to improve the software

    9.4. Rights under EU law:
    If the User’s relevant Personal Information is subject to the protections offered by EU law, he/she may:
    ● Access, correct, update or request deletion of any relevant Personal Information, at any time by
    contacting the Company using the contact details provided on the software or website (in accordance with
    applicable data protection laws) or writing to the support group therein indicated, provided that the
    Company may charge a reasonable fee for any manifestly unfounded, excessive or repetitive requests;
    ● Object to the processing of any relevant Personal Information, ask the Company to restrict processing of
    any relevant Personal Information or request portability of any relevant Personal Information for the
    legitimate interests set out above. In certain circumstances, the Company may not be able to stop using
    the Personal Information, with motivated cause.
    ● Withdraw consent at any time if the Company collected and processed any relevant Personal Information
    with consent;
    ● Opt-out of any marketing communications that the Company (or any third party to whom the Company
    disclosed the Personal Information with consent) may send;
    ● Complain to a data protection authority about the Company’s collection and use of any relevant Personal
    These rights apply only to Users who are subject to EU law.
    9.5. The Company is the Data Controller in relation to its Website and is responsible for any relevant Personal
    Information, save for what pertains to other third-party service providers connected. The User may contact
    the Company through its software, website or by writing on the support groups therein provided if he/she
    has any concerns about this Policy and any relevant Personal Information.