Privacy Statement

Introduction

1. PROOFI application (hereafter: “PROOFI”) is owned by LTO Network B.V., a private limited liability company organized and existing under the laws of the Netherlands, having its corporate seat at Amsterdam, the Netherlands, with address Herengracht 504, 1017CB, Amsterdam, registered at the trade register of the Chamber of Commerce under number 73662968 (hereafter “LTO Network”). LTO Network attaches great importance to the responsible handling of personal data of users of PROOFI (hereafter "Users").

2. LTO Network processes personal data of Users carefully and with due observance of the provisions of the EU General Data Protection Regulation (GDPR).

3. In this Privacy Statement, LTO Network informs Users about the way LTO Network processes their personal data and how they can control this process.

Article 1: Explanation of personal data and goal for the processing thereof

Personal data

1. LTO Network collects email addresses and names of Users that choose to use the PROOFI app. LTO Network also collects and saves emails sent by users that use the PROOFI app (hereafter all collectively called “Personal Data”). These are data that can be linked to the identity of an individual person and may contain private information pertaining to the User. LTO Network shares Personal Data with third party Onfido.

2. LTO Network is at all times responsible for the management of the Personal Data and will make every effort to protect the Personal Data. In the event of a data breach, LTO Network will immediately inform the User of that event via the email address known to it and make every effort to prevent further distribution of these Personal Data.

3. The User has the right at all times to receive the Personal Data provided by him / her to LTO Network in an orderly manner from LTO Network ("right of access"). On the first request of a User, LTO Network will forward his / her Personal Data to a third party to be designated by that User ("right to data portability") or remove it entirely from its system ("right to be forgotten").

4. Any questions that a User may have regarding his Personal Data can be asked via support@ltonetwork.com. These questions will be answered within 2 working days at the latest.

Goal

5. LTO Network requires Personal Data from a User and shares these data with third party Onfido in order for the User to use the PROOFI app for the purpose for which it was intended: verification and identification. Without this collecting and processing of Personal Data, the PROOFI app cannot function.

Permission

6. To receive, process and use Personal Data of a User, LTO Network requires the User's permission. This permission is granted by a User by stating to have read and to have accepted this Privacy Policy during registration before use of the PROOFI app.

Article 2: Transfer to third parties

1. LTO Network shares Personal Data of Users with one third party : Onfido, a company incorporated in London, United Kingdom.

Article 3: Data security

1. LTO Network makes use of appropriate technical and organizational security procedures, among other things to ensure that unauthorized persons do not gain access to Personal Data and to prevent the loss, unlawful use or modification of Personal Data.

Article 4: Availability and modification of your data

1. Users can request access to their Personal Data at any time. Users may also request that their Personal Data be changed or deleted by sending an e-mail to support@ltonetwork.com.

Article 5: Cookies

1. LTO Network uses cookies on its website as mentioned in its Cookie Statement.

Article 6: Change Privacy Statement

1. LTO Network reserves the right to amend this Privacy Statement. Every modification will be announced via ltonetwork.com. By making use of ltonetwork.com after making changes you agree to a modified Privacy Statement. Keep an eye on this page for all changes.

This Privacy Statement has been updated on 06-12-2019