Last Update: November 1, 2018

Privacy Statement

The tribeOS platform is a fully automated digital advertising marketplace (the “Platform”) created by tribeOS Ltd. (“tribeOS”, “we” or “us”), that is made available to you via the Bitcoin Cash Blockchain, and for which we provide investor access and further information on the tribeos.io website (the “Site”, collectively, with the Platform, the “Service”). At tribeOS, we are committed to protecting your privacy and safeguarding your Personal Information. The purpose of this Privacy Statement is to inform you about the types of Personal Information tribeOS collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws. [For example, we comply with the General Data Protection Regulation (“GDPR”) (EU) 2016/679.] [NTD: GDPR compliance to be discussed; standards are quite onerous.] Also, this Privacy Statement is designed to meet the standards prescribed by Canada’s Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) as well as applicable provincial privacy legislation and regulations, including, the Personal Information Protection Act (Alberta), the Personal Information Protection Act (British Columbia), and An Act respecting the protection of personal information in the private sector (Quebec).

From time to time, we may make changes to this Privacy Statement. Please revisit this page periodically to stay aware of any changes to this Privacy Statement. If we modify the Privacy Statement, we will make it available through the Site, and as such the Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

The following topics will be covered in this Privacy Statement:

1. To which companies does this Privacy Statement apply?
2. What is Personal Information?
3. How do we collect your Personal Information?
4. How do we use your Personal Information?
5. To whom do we provide your Personal Information?
6. When and how do we obtain your consent?
7. How long will we utilize, disclose or retain your Personal Information?
8. What are your rights regarding your Personal Information?
9. What safeguards have we implemented to protect your Personal Information?
10. How do you contact us regarding access to your Personal Information or our privacy practices?

1. To which companies does this Privacy Statement apply?

   This Privacy Statement applies to the collection, use and disclosure of Personal Information by tribeOS.

2. What is Personal Information?

   “Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, company, mailing address, e-mail address, billing address, passport and/or government issued identification, and credit card information.

3. How do we collect your Personal Information?

   We will always collect and /or process your Personal Information by fair and lawful means (for example, when you enter information on the Site, purchase tokens from us, contact us by telephone or by email or post on our social media accounts).
   
   We may collect and/or process Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law. The legal bases for our processing of Personal Information are primarily your prior consent or that the processing is necessary for providing the Service and that the processing is carried out in our legitimate interests, which are further explained in the “How do we use your Personal Information?” section. As such, if you choose to withhold any Personal Information requested by us, it may not be possible for us to make certain aspects of the Service available to you.
   
   We may collect standard internet log information about how and when you use our Site. This information may include but, not be limited to, your IP address and location data, weblogs, time, date, browser used, referring web addresses, other communication data, searches conducted, and/or pages visited. Our Site, like most other commercial websites, does this through the use of cookies. A cookie is a small data file stored by your computer to help optimize our Site for ease of use and to improve your experience. Our service provider(s) may also use cookies to collect standard information about your use of our Site, including your language preferences, your browser type and version, and similar information.
   
   For details of the cookies employed by us, please see our Cookie Policy included in this document below, which forms part of this Privacy Statement.

4. How do we use your Personal Information?

   We identify the purposes for which we use your Personal Information at the time we collect such information from you and (if applicable) obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):
   • to provide you with the Service and/or to process orders;
   • to properly identify you;
   • to undertake and comply with our Know-Your-Client obligations and policies;
   • to comply with our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada);
   • to determine, in our sole discretion, your eligibility for our tokens, products and services and the products and services of companies with whom we are affiliated;
   • to protect against fraud;
   • to develop and maintain strong business relationships with customers, partners and potential customers and partners;
   • to manage your use of our tokens;
   • to respond to questions, comments or concerns regarding tribeOS, the Service or our tokens;
   • to provide you with information about the development of our Platform, including, information regarding dividends, proxy votes and/or other relevant tribeOS information;
   • to use Google Analytics to better understand our web traffic and marketing effectiveness (whose privacy policy can be found at www.google.com/policies/privacy/partners/);
   • to allow for more meaningful and useful sales and marketing initiatives;
   • to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, feature, and functionality;
   • to collect opinions and comments in regard to tribeOS operations;
   • to recruit for positions at tribeOS and for other employment-related tasks;
   • to investigate legal claims;
   • such purposes for which tribeOS may obtain consent from time to time; and
   • such other uses as may be permitted or required by applicable law.

5. To whom do we provide your Personal Information?

   We identify to whom, and for what Purposes, we disclose your Personal Information, at the time we collect such information from you and (if applicable) obtain your consent to such disclosure.
   
   We may disclose your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as service providers that provide telephone support, data storage or processing, or hosting. When we disclose your Personal Information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Statement are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organisational measures.
   
   Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Service, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your Personal Information will at all times continue to be governed by this Privacy Statement. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Information Officer (see question 10 below).
   
   In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of tribeOS, in whole or in part, your Personal Information may be transferred as part of the transaction.
   
   We may finally make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding your interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

6. When and how do we obtain your consent?

   We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any Purpose. You provide your consent by executing this User agreement.

7. How long will we utilize, disclose or retain your Personal Information?

   We may keep a record of your Personal Information, correspondence or comments, in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the Purposes for which that Personal Information was collected and as permitted or required by law. If you would like further information regarding the periods for which your Personal Information will be kept, contact our Privacy Information Officer (see question 10 below).

8. What are your rights regarding your Personal Information?

   On written request and subject to proof of identity, you may access the Personal Information that we hold, process, used or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change in your Personal Information by mail or e-mail.
   
   If you are a resident of the European Union (“EU/EEA”), under certain circumstances and in accordance with the GDPR or other applicable EU/EAA data protection laws, you may have the following rights:
   • Access: In addition to the rights of access and correction set out above you may request a copy of the Personal Information we hold and certain other information about it;
   • Erasure: entitled to ask us to delete or remove Personal Information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Information is required for compliance with law or in connection with claims;
   • Restriction: entitled to ask us to suspend the processing of certain of Personal Information, for example to establish its accuracy or the reason for processing it;
   • Transfer: request the transfer certain of Personal Information to another party;
   • Objection: one may challenge when we are processing Personal Information based on a legitimate interests (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information;
   • Automated decisions: contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered; and
   • Consent: where we are processing Personal Information with consent, withdrawal of consent.
   You may also have a right to lodge a complaint with a data protection supervisory authority, in particular in the country/province/state where you are habitually resident where we are based or where an alleged infringement of data protection law has taken place.
   
   To exercise any of these rights, please contact us as set forth in the Section 10.
   
   If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at: http://ec.europa.eu/justice/data-protection/index_en.htm. Please note that the term Personal Information used in this Privacy Statement is equivalent to the term “personal data” under the GDPR and other applicable European data protection laws.
   
   The Service is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided Personal Information, then you may alert us as set forth in question 10 and request that we delete that child’s Personal Information from our systems.

9. What safeguards have we implemented to protect your Personal Information?

   We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk as there are inherent and unknown risks associated with accessing public blockchains such as the Bitcoin Cash Blockchain, accepting tokens, owning tokens and using tokens for the provision or receipt of services, We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards. If you believe your Personal Information has been compromised, please contact us as set forth in question 10. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

10. How do you contact us regarding access to your Personal Information or our privacy practices?

    If you have any questions or comments about this Privacy Statement or your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Information Officer can be reached by mail or email using the following contact information:
    
    

    In writing:	Attn: Privacy Information Officer
    Address:	tribeOS Ltd, Clarendon House, 2 Church Street, Hamilton, HM 11, Bermuda
    By e-mail:	[email protected]

Last Update: November 1, 2018