Privacy Policy
This privacy policy was last modified on 12 September 2023.

SECTION 1 - Privacy Policy Overview
§1.1 BlockFarms LLC-FZ. (“BlockFarms”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information or, as otherwise termed, “personal data”.
§1.2 The purpose of this privacy policy (the “Policy”) is to provide you with information about our privacy practices generally and what information we may collect, use and share about you when you visit our website block-farms.io (the “Website”), and/or when you use our Chainlink Oracle(s), and/or our various Validator(s) services.
§1.3 This Policy informs you about: (i) how we will handle and look after your personal data, (ii) our obligations in regard to processing your personal data responsibly and securely, (iii) your data protection rights as a data subject, and (iv) how the law protects you. This Policy should be read in conjunction with our ‘Terms of Service’ (which may be found here).
§1.4 For purposes of clarity, this Policy does not apply to any other service/s which we may offer, whether or not accessed through our website, unless otherwise specified.

SECTION 2 – Who We Are And How To Contact Us
§2.1 BlockFarms is the controller and responsible for determining what personal information we collect and how it is used or shared.
§2.2 We are registered in the United Arab Emirates (U.A.E.) with company license number 2305899 and have our registered office at Business Center 1, The Meydan Hotel, Floor M, And Al Sheba, Dubai, United Arab Emirates.
§2.3 block-farms.io is a Website operated by us, BlockFarms LLC-FZ. The Website is not intended for minors and the Services are not offered to minors. As such, we do not knowingly collect personal data relating to minors.
§2.4 If you have any questions about our Privacy Policy or privacy practices, please contact us by email at contact@block-farms.io.

SECTION 3 – About our Privacy Policy
§3.1 The privacy of your Personal Information is important to us. We respect your rights to privacy and rights under the Privacy Act and are committed to complying with the requirements of Privacy Laws in the collection and handling of your Personal Information.
§3.2 This policy explains how we collect, retain, process, share, transfer and handle your Personal Information and describes the kinds of Personal Information we collect, use, disclose and our purposes for doing so.
§3.3 We use some defined terms in this policy. You can find the meaning of each defined term at the end of this policy.
§3.4 Personal Information is information which may be used to reasonably identify you. For example, your name, address, date of birth, gender, email address, telephone number is generally considered to be Personal Information. Personal Information may also include information we collect about your individual preferences. We do not collect sensitive information from you, however, sensitive information you provide can become available on public blockchains through metadata matching if you use our service.
§3.5 This policy applies to your Personal Information when you use our Website, and interact generally with us but does not apply to Third Party Sites. We are not responsible for the privacy policies or content of Third Party Sites, nor do we accept responsibility for information released on to, or made available by public blockchains.
§3.6 For the avoidance of doubt, unless stated otherwise, this policy will govern our collection of your Personal Information irrespective of the forum.
§3.7 This policy may be updated from time to time and the most up to date version will be published on our Website. We encourage you to check our Website periodically to ensure that you are aware of our current policy.
§3.8 Your continued usage of our Website and/or services will be taken to indicate your acceptance of the terms of this privacy policy insofar as it relates to our Website.
§3.9 We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

SECTION 4 – Why we collect Personal Information
§4.1 When you visit our Website, we collect Personal Information so that we can provide you with products and services and improve and customize your experience with us. We only collect Personal Information if it is reasonably necessary for us to carry out our functions and activities.
§4.2 The purposes for which we collect and hold your Personal Information include:
(a) to deliver our products and services to you;
(b) to improve our products and services to you;
(c) to manage our relationship with you, evaluate our business performance and build our customer database;
(d) to respond to your requests and seek your feedback;
(e) to provide and improve technical support and customer service;
(f) to conduct research, compare information for accuracy and verification purposes, compile or analyze statistics relevant to the operations of our business;
(g) to facilitate our internal business operations, including fulfilment of any legal and regulatory requirements and monitoring, analyzing and improving the performance and functionality of our Website and investigating breaches of or enforcement of any legal terms applicable to our Website;
(h) to protect our property, the Website or our legal rights including to create backups of our business records;
(i) to manage risk and protect our Website from fraud by verifying your identity and helping to detect and prevent fraudulent use of our Website;
(j) for the direct marketing and promotional purposes as set out below; and
(k) to manage our business, including analyzing data collected from our Website concerning visits and activities of users on our Website including the Analytics Services. This analysis helps us run our Website more efficiently and improve and personalize your experience online.

SECTION 5 – What Personal Information do we collect?
§5.1 The kinds of Personal Information we collect will depend on the type of interaction you have with us. Generally, the kinds of Personal Information we collect may include:
(a) your name, address (postal and residential), email address, telephone number(s), date of birth and gender when you register with us;
(b) information from third party sources such as data providers and credit organisations, where permitted by law, including public blockchain data such as your nominated public key for a digital asset wallet (including any wallet address);
(c) details of the device you have used to access any part of our Website, including carrier/operating system, connection type, IP address, browser type and referring URLs and other information may be collected and used by us automatically if you use our Website, through the browser on your device or otherwise;
(d) demographic information;
(e) location data;
(f) your connections with others whose personal information we may collect or hold; and
(g) transaction details relating to your use of our products, services or rewards including data regarding your feature usage patterns, interactions on our website and interactions with us.

SECTION 6 – With whom do we share Personal Information?
§6.1 We may disclose Personal Information collected from you:
(a) to our related entities, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other third parties to satisfy the purposes for which the information was collected (as outlined in clause §4.2 of this policy) or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;
(b) to third parties who help us to verify the identity of our clients and customers, and other software service providers who assist us to provide the services we provide to you;
(c) to third parties who help us analyze the information we collect so that we can administer, support, improve or develop our business and the services we provide to you including cloud hosting services, off-site backups and customer support;
(d) to third parties, including those in the blockchain and fintech industry, marketing and advertising sectors, to use your information in order to let you know about goods and services;
(e) if the disclosure is requested by law enforcement or government agency, or is required by a law, or legal process, such as a subpoena, court or other legal process with which we are required to comply, including in relation to our obligations under the Anti-Money Laundering and Counter Terrorism Financing Acts;
(f) if disclosure is required to enforce the terms of this policy or to enforce any of our terms and conditions with you;
(g) to our professional advisers such as consultants and auditors so that we can meet our regulatory obligations, and administer, support, improve or develop our business;
(h) to any other person, with your consent (express or implied);
(i) to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers;
(j) to protect the interests of our users, clients, customers and third parties from cyber security risks or incidents and other risks or incidents; and
(k) to maintain the integrity of our Website and protect our rights, interests and property and those of third parties.
§6.2 In addition to the above recipients, we will disclose your Personal Information if we are required to do so under law or if the disclosure is made in connection with either the normal operation of our business in a way that you might reasonably expect, for example, if such disclosure is incidental to IT services being provided to our business or for the resolution of any dispute that arises between you and us. This disclosure may involve your Personal Information being transmitted Overseas.
§6.3 In the event of a proposed restructure or sale of our business (or part of our business) or where a company proposes to acquire or merge with us, we may disclose Personal Information to the buyer and their advisers without your consent subject to compliance with Privacy Laws. If we sell the business and the sale is structured as a share sale, you acknowledge that this transaction will not constitute the ‘transfer’ of Personal Information.
§6.4 We may disclose de-identified, aggregated data with third parties for marketing, advertising, and analytics purposes. We do not sell or trade your personal information to third parties.

SECTION 7 – How we collect and store data and transmit Personal Information
§7.1 We usually collect and store information including in paper, physical and electronic form provided by you when you communicate with us by telephone, email, web-based form, letter, facsimile or other means, including when:
(a) we provide you with our services via email or our Website;
(b) we provide you with assistance or support for our products or services;
(c) you participate in our functions, events or activities or on our social media pages;
(d) you request that we provide you with information concerning our products or services;
(e) you upload or submit information to us or our Website; or
(f) you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products or services.
§7.2 Where practicable we will only collect information from you personally. However, we will also collect your Personal Information through our partners and third parties who supply services to us.
§7.3 Please note that we use our own and third party computer servers including our Website hosts, data backups, which may be located Overseas and your Personal Information may be stored and transmitted Overseas as part of the normal operation of our business.
§7.4 We do not accept responsibility for Personal Information being released to public blockchains through the use of our Website, whether it be through public smart contracts or metadata matching.
§7.5 We also collect information from your computer or mobile device automatically when you browse our Website. This information may include:
(a) the date and time of your visit;
(b) your domain;
(c) locality;
(d) operating system;
(e) the server your computer or mobile is using to access our Website;
(f) your browser and version number;
(g) search terms you have entered to find our Website or access our Website;
(h) pages and links you have accessed both on our Website and on other websites;
(i) the last website you visited;
(j) the pages of our Website that you access;
(k) the device you use to access our Website; and (l) your IP Address.
§7.6 While we do not use some of this information to identify you personally, we may record certain information about your use of our Website such as which pages you visit and the time and date of your visit and that information could potentially be used to identify you.
§7.7 It may be possible for us to identify you from information collected automatically from your visit(s) to our Website. If you have registered an account with us, we will be able to identify you through your user name and password when you log into our Website. Further, if you access our Website via links in an email we have sent you, we will be able to identify you.
§7.8 The device you use to access our Website may collect information about you including your location using longitude and latitude coordinates obtained through GPS, Wi-Fi or cell site triangulation. For information about your ability to restrict the collection and use of such information, please use the settings available on your device.
§7.9 We may use statistical analytics software tools and software known as cookies which transmit data to third party servers located Overseas. To our knowledge, our analytic providers do not identify individual users or associate your IP Address with any other data held by them.
§7.10 We will retain your Personal Information for any time period we consider necessary to provide our products and services to you and to comply with our legal obligations. The period may vary depending on the type of Personal Information we hold. If we no longer need your personal information for these purposes, we will take steps to destroy the information or ensure it is de-identified.

SECTION 8 – How we protect your Personal Information
§8.1 We will endeavor to take all reasonable steps to keep secure and protect any Personal Information which we hold about you, including:
(a) securing our physical premises and digital storage media;
(b) using computer safeguards such as Secure Socket Layer (SSL) technology to ensure that your information is encrypted and sent across the Internet securely;
(c) placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorized interference, access, modification and disclosure; and
(d) taking regular back-ups of our electronic systems.
§8.2 Notwithstanding that we will take all reasonable steps to keep your Personal Information secure, data transmission over the internet is never guaranteed to be completely secure. We do not and cannot warrant the security of any information you transmit to us or from any online services.

SECTION 9 – Use of Cookies
§9.1 When you visit our Website or the website of any of our partners, we and our partners may use cookies and other tracking technology (Cookies) to recognize you and customize your online experience. Cookies are small files that store information on your computer, mobile phone or other device. They enable us to recognize you across different websites, services, devices and/or browsing sessions. Cookies also assist us to customize online content and advertising, save your preferences for future visits to the Website, measure the effectiveness of our promotions, prevent potential fraud and analyze your and other users’ interactions with the Website.
§9.2 If you do not wish to grant us the right to use cookies to gather information about you while you are using our Website, then you may set your browser settings to delete, disable or block certain Cookies. The following browsers have publicly available information about how to adjust cookie preferences: Microsoft Edge, Mozilla Firefox, Google Chrome and Apple Safari.
§9.3 You may be requested to consent to use of Cookies when you access certain parts of our Website, for example, when you are asked if you want the Website to “remember” certain things about you.
§9.4 Certain aspects and features of the Website are only available through use of Cookies. If you disable Cookies, your use of the Website may be limited or not possible or parts of our Website may not function properly when you use them.
§9.5 Upon your first visit to our Website (or the first visit after you delete your Cookies), you may be prompted by a banner to accept our use of Cookies and other tracking technology (Cookies policy). Unless you have adjusted your browser setting so that it will refuse cookies and or declined to accept our Cookies policy, our system will issue Cookies when you access our Website.
§9.6 Our Website may contain web beacons (also called single-pixel gifs) or similar technologies (Web Beacons) which are electronic images that we use:
(a) to help deliver Cookies;
(b) to count users who have visited our Website; and
(c) in our promotional materials, to determine whether and when you open and act on them.
§9.7 We may also work with third-parties:
(a) to place Web Beacons on their websites or in their promotional materials as part of our business development and data analysis; and
(b) to allow Web Beacons to be placed on our Website from Analytics Services to help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations.
§9.8 The Web Beacons of Analytics Services may enable such providers to place Cookies or other identifiers on your device, through which they may collect information about your online activities across applications, websites or other products.

SECTION 10 – Not identifying yourself
§10.1 It may be impracticable to deal with you on an anonymous basis or using a pseudonym.
§10.2 We may be able to provide you with limited information in the absence of your identifying yourself but generally we will be unable to provide you with any information, goods and/or services unless you have identified yourself.

SECTION 11 – Queries and Complaints
§11.1 We have appointed a data protection contact point (“DPCP”) who is responsible for overseeing questions in relation to this Notice and our processing activities in general. If you have any questions or requests, including any requests to exercise your legal rights as a data subject, please contact the DPCP using the details set out below:
Full name of legal entity: BlockFarms LLC-FZ.
Name of DPCP: Matthew Gladson
Email address: contact@block-farms.io
Postal address: Office 104/105 Level 1, Emaar Square, Building 4 Sheikh Mohammed Bin Rashid Boulevard Downtown Dubai, United Arab Emirates.
§11.2 In order to disclose information to you in response to a request for access we may require you to provide us with certain information to verify your identity. There are exceptions under Privacy Laws which may affect your right to access your Personal Information – these exceptions include where (amongst other things):
(a) access would pose a serious threat to the life, health or safety of any individual;
(b) access would have an unreasonable impact on the privacy of others;
(c) the request for access is frivolous or vexatious;
(d) the information relates to existing or anticipated legal proceedings between you and us and the information would not otherwise be accessible by the process of discovery;
(e) giving access would reveal our intentions in relation to negotiations with you;
(f) giving access would be unlawful;
(g) denying access is required or authorized by or under an United Arab Emirates law or a court/tribunal;
(h) the information relates to commercial sensitive decision making process; or
(i) giving access would prejudice enforcement related action.
§11.3 If you wish to have your Personal Information deleted, please contact us using the details above and we will take reasonable steps to delete the information (unless we are obliged to keep it for legal or auditing purposes). To the extent that any Personal Information is stored on a blockchain it may be impracticable, unfeasible or impossible to delete.

SECTION 12 – Changes to this Privacy Policy
§12.1 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
§12.2 We will only retain your personal data for as long as necessary in order to fulfil the purposes for which we collected it, i.e. the performance of our customer relationship with you (whilst ongoing), and thereafter: for the purpose of satisfying any legal, accounting, tax or reporting obligations to which we may be subject; and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or involving you.
§12.3 We will maintain and retain your personal data throughout the period of your customer relationship with us and for a further period of five (5) years from the date of its termination. This retention period enables us to make use of your personal data in order to satisfy any applicable reporting obligations to public authorities and/or for the assertion, filing or defense of possible legal claims by or against you (taking into account applicable prescriptive periods). In certain cases, we may need to retain personal data for a period of up to eleven (11) years to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data and records).
§12.4 There may also be other instances where the need to retain certain items of personal data about you for longer periods, as dictated by the nature of the relationship and/or services provided.

SECTION 13 – Changes to this Privacy Policy
§13.1 We may amend this privacy policy from time to time at our sole discretion, particularly where we need to take into account and cater for any:
(a) business developments; or
(b) legal or regulatory developments.
§13.2 If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, may provide you with additional notice (such as adding a statement to the Website homepage or sending you a notification). We recommend you review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help us to protect your privacy.

SECTION 14 – Definitions used in this policy
(a) Analytics Services means any third party website analytics provider and includes third party website analytics companies such as Google Analytics.
(b) IP Address means a number automatically assigned to your computer which is required when you are using the internet, and which may be able to be used to identify you.
(c) Overseas means any place or country other than the United Arab Emirates and includes the following countries: United States of America.
(d) Personal Information has the meaning set out in the Privacy Act.
(e) Privacy Laws means such laws as may place requirements on the handling of Personal Information under the Privacy Act.
(f) Third Party Sites means online websites or services that we do not own or control, including websites of our partners.
(g) Website means https://block-farms.io and/or any other website as we may operate from time to time.
(h) you, your and similar terms means, as the context requires (1) you, when you use our Website; and/or (2) you, during your dealings with us as a customer; and/or (3) any agent providing your Personal information to us; and/or (4) any agent dealing with us on your behalf.