REMME Privacy Notice

Last Updated: 08.06.2018

About

Remme Capital LTD – the Remme Company (“REMME”, “We”, “Us”) is committed to safeguarding your privacy and protecting your Personal Information. This is very much in line with the main idea underpinning the creation of REMME – protection of sensitive data by implementing decentralized public key infrastructure based on blockchain technology. 


We define "Personal Information" as any information which, directly or indirectly, identifies you personally, e.g. your name, address, e-mail address, location data etc.


REMME Privacy Notice explains how we collect, use and share your Personal Information in the course of our business activities as well as the legal basis underpinning the collection of your Personal Information. We only collect the personal data that is reasonably necessary for us to efficiently conduct our business activities. 


This Privacy Notice describes the Personal Information we collected during the REMME Tokens Pre-Order Campaign as well as the Personal Information we collect now, after the General Data Protection Regulation (“GDPR”) came into force. 


This Privacy Notice covers the Remme Capital LTD, https://remme.io website (“Website”) and REMME software (“Product”), including all its services and functions (collectively referred to as “Services”).

Personal Information We Collected during the REMME Tokens Pre-Order Campaign

During the REMME Tokens Pre-Order Campaign, we used and collected the following Personal Information from you:
- first name;
- last name;
- e-mail;
- country of residence;
- telegram username;
address of your Ethereum wallet. 

We collected and used the above-listed Personal Information in furtherance of the following aims: 
- to establish and verify your identity;
- to conduct our internal KYC check to ensure that you were not coming from the list of blacklisted countries;
- to comply with the Anti-Money Laundering Rules;
- to place your Pre-Order with Us;
- if you contacted us, to reply to your queries;
- to deliver REMME Tokens to you. 

PLEASE NOTE: The Personal Information we collected during the REMME Tokens Pre-Order Campaign, was done on a one-off occasion. After the REMME Tokens Pre-Order Campaign was finished, we have not collected any additional Personal Information from the customers and currently have no intention of doing so. If this change, we will make the amendments in the Privacy Notice accordingly.

Personal Information We Collect and Use from the Technical Community

We collect and use the following Personal Information from the technical community: 
- first name;
- last name;
- gender;
- age;
- current location - country and city;
- country and city where you are based (this information is necessary for us to establish if you can join local events);
- e-mail;
- discord username (this is a crucial tool to have for REMME tech community, which is why we require REMME tech community members to register with discord if they do not currently have an account there);
- your area of expertise (developer/ cybersecurity professional/researcher/blockchain expert); 
- topics you are most interested in (REMChain (REMME custom blockchain and its components)/ integration process/ building your own apps on top of REMME PKI (d) protocol/ everything about masternodes/other – here we ask you to specify the topic);
- reason why you want to join REMME tech community; 
- your comment, which is optional.

We collect and user the above-listed information in furtherance of the following aims:
- to analyze the members of the REMME technical community;
- to work with the REMME technical community (to contact you if reasonably required and if you contact us, to reply to your queries);
- to further define the beta testing process for the Product;
- to develop and improve the Product.

Legal Grounds for Processing

Our processing of your Personal Information is based on the following legal grounds:
- consent –   where you have consented to our use of your Personal Information;
- legal obligation – where we need to use your Personal Information to comply with our legal obligations (identification and verification of your identity to manage the risk of our client base and to ensure you fall within our acceptable risk profile); 
- contract performance – where we need to collect and use your Personal Information to perform the services to you (delivering REMME tokens for those who placed the pre-order);
- legitimate interest it is our legitimate interest to promote our business, develop our communication with the customer, build our technical community in order to further develop, test and improve our product. The latter involves analyzing the information we receive from the technical community.  If you are a data subject protected by the GDPR you may have rights to restrict or object to this processing, however, please note that this may adversely affect the product we offer as well as our ability to effectively communicate with our customers.

Transmission, Storage and Security of Your Personal Information

No data transmission over the Internet or website can be guaranteed to be secure from intrusion, and is subject to possible loss, interception, or alteration while in transit. Accordingly, REMME does not assume any liability for possible loss, interception or alteration of your information while in transit. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with data protection legislative requirements.

Your Personal Information is being stored as a database of customers on the Google Drive Personal Account (https://www.google.com/drive/) – cloud storage service. The only person who has an access to the Google Drive Personal Account is the CEO of the Company.

We provide all organizational and technical measures for the data protection, which are required under the GDPR, including encryption and pseudonymization of your Personal Information. 

We take necessary and sufficient organizational and technical measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
Immediate access to the Personal Information is allowed only to our authorized employees involved in providing the Services. Such employees keep strict confidentiality and prevent unauthorized third-party access to Personal Information.

Sharing Your Personal Information with Third-Parties

We have no Third-Parties with whom we share your Personal Information. Should this change, we will notify you accordingly.

Retaining Your Personal Information

We will store your Personal Information till it is necessary to carry out our obligations regarding the Services we provide to you. This period lasts from12 to 36 months and can be extended in specific cases. Once your Personal Information is not used anymore for the purposes listed in this Privacy Notice and if we are no longer legally obliged to hold your Personal Information for regulatory or legal purpose, we will anonymize or dispose of your Personal Information in line with acceptable industry and security standards so that this information cannot be subsequently retrieved and associated with you.

Copies of evidence obtained in relation to AML checks: in relation to your Personal Information obtained in relation to KYC checks during the REMME Tokens Pre-Order Campaign, we have retained that Personal Information whilst our Tokens Pre-Order Campaign was running and will retain for a further 5 years to deal with any queries or claims that may arise thereafter.

Other Disclosures

In addition to the disclosures for the purposes identified elsewhere in this Privacy Notice, we may disclose information about you:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings;
- to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
- to the purchaser or seller (or prospective purchaser or seller) of any business or asset which we are (or are contemplating) selling or purchasing. 

Except as provided in this Privacy Notice, we will not sell, share or rent your information to third parties.

Your Rights & Contacting Us

If you are a citizen of the EEA member state, regarding your Personal Information, you have the right to request us:
- an access to the information that was collected;
- to withdraw your consent (if applicable);
- to rectify/erase your Personal Information;
- to update and keep information accurate;
- to delete any undesirable collected information;
- to restrict the processing of the information;
- to stop the processing of the information in case that the information is used for direct marketing purposes; and
- to send your Personal Information to any third party in structured and machine-readable format.

You can complete requests by contacting us at team@remme.io. If you believe that our use of your Personal Information violates your rights, you can lodge a complaint with your national data protection authority.

Changes to the Privacy Notice

We may update this Privacy Notice from time-to-time by posting a new version in our website. We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavor to provide you with the announcement about any significant changes.

Contacting Us

Should you have any questions about this privacy notice, please contact us.
You may email us at team@remme.io.
Our registered office is at: QUIJANO & ASSOCIATES (BVI) LIMITED, Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands.

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