Privacy Policy

Last Update: May 15, 2018

1. SCOPE

This Privacy Policy sets out the rules pursuant to which BLUE HORIZON (hereinafter referred to as “Blue Horizon”, “we” or “us”) collects, uses, stores and discloses Personal Data you provided us with through the use of our website tokensale.connecty.io (hereinafter the “Website”).

The data controller is Blue Horizon, a company incorporated under the laws of France, registered under number 838 973 568 and whose office is located at 36 Rue Waldeck Rousseau, 69006 Lyon, France.

Blue Horizon respects your concerns regarding the confidentiality and security of Personal Data provided by you and abides by the applicable laws and regulations.

This Privacy Policy is part of Blue Horizon ICO General Terms & Conditions.

2. DATA SUBJECT CONSENT

By using the Website or purchasing CTY Tokens, you have fully read, understood and accepted the terms of this Privacy Policy. If you do not agree with this Privacy Policy, you should withhold from using the Website and/or purchasing CTY Tokens.

We will only collect, use or disclose your Personal Data where it is necessary, fair and lawful to do so. In most cases, we will ask for your consent explicitly but, in some cases, we may infer consent from your actions and/or behaviour. As far as possible, we will only collect the minimum amount of Personal Data needed for the purposes covered by this Privacy Policy. We may ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy. You are not obliged to provide such consent but if you decide not to then we may not be able to respond to your queries or you will not be able to purchase CTY tokens. If you provide additional consent, the terms of that consent shall prevail in the event of any conflict with the terms of this Privacy Policy.

Please notice, however, that we may process your Personal Data without consent if we have a legitimate reason to do so, provided that such use will not have a prejudicial effect on your own rights and interests.

3. TYPES OF PERSONAL DATA COLLECTED

In this Privacy Policy, your "Personal Data" means any piece of information that could allow you to be identified directly or indirectly (by combining several pieces of information).

When you sign up to our pre-sale or sale mailing list and/or create an account to purchase CTY Tokens, we will collect and process the following Personal Data:

• Full name;
• Username;
• Address and country of residence;
• Nationality;
• Date of birth;
• Email address;
• Telephone number;
• Company’s name;
• Company’s address and country of incorporation;
• Credit card and bank information or any other information to make the payment of CTY Tokens effective;
• Details of any requests or transactions you make through the Website;
• Any other personal information you voluntary provide to us.

In certain cases, when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or “know-your-customer” (KYC) policies, We may require you to provide additional information, upon special request to you and specified in an email.

If you do not provide the Personal Data as specified hereinabove, you will not be able to purchase CTY Tokens.

When you visit the Website, we may also collect aggregate and anonymous data which is information that does not identify you specifically, including data collected automatically when you enter our Website (“Non-Personal Data”). This may include cookies, pixel tags, web beacons, browser analysis tools and web server logs. This also includes information from the devices you use to access the Website or mobile platform, your operating system type or mobile device model, browser type, domain and other system settings, as well as the language your system uses and the country and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Website. We may also collect information about a website you were visiting before you came to our Website and any website you visit after you leave our Website, if this information is supplied to us by your browser. We may also use software tools, such as Javascript, to measure and collect session information, including page response times, download errors and methods used to browse away from the page.

4. PURPOSE OF PROCESSING PERSONAL DATA

Your Personal Data will be used for the following purposes :

• For verification procedures pursuant to our legal obligations and/or internal policies;
• To manage our business needs during the different phases of Blue Horizon ICO such as Website administration, analytics, fraud prevention or to comply with the law;
• To communicate with you about the ICO, the Connecty Platform and its future services and other information we think will be of interest to you. You can opt-out of receiving our emails by following the unsubscribe instructions included in each such email or by contacting us at [email protected] ;
• To build, operate and improve the Website such as monitoring and analyzing trends, usage and activities in connection with the Website;
• To provide the services and respective customer support related to Blue Horizon ICO;
• To send you technical notices, updates, security alerts and administrative messages where necessary;
• To detect, investigate and prevent fraudulent transactions and other illegal activities;
• To protect the integrity and property of the Website.

5. LIMITED DISCLOSURE OF PERSONAL DATA

Except as provided herein, we will not display on the Website, or otherwise disclose your Personal Data to any third parties unless it is necessary to provide the services offered on the Website and for the ICO, when required by law, or if we have good faith belief that such action is reasonably necessary to:

• Comply with the law or any request from a governmental authority or a court order;
• Respond to claims that any submitted content violates the rights of third parties;
• Protect and defend our rights, property and interests;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

We will also disclose your Personal Data to the Website hosting services provider.

Blue Horizon will not provide your Personal Data to any other Website users or third parties other than those described here above, without your consent.

If and when we disclose your Personal Data to trusted third parties, we will use our best efforts to ensure that they keep your Personal Data secured, take all reasonable steps to protect it from misuse and only use it in a manner consistent with our instructions, this Privacy Policy and applicable data protection laws and regulations.

The Website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies. Blue Horizon does not bear any responsibility for these policies or for any Personal Data that may be collected through these websites or services. Please check carefully these policies before submitting any Personal Data to these websites or use these services.

6. PERSONAL DATA SECURITY

All Personal Data we collect is stored in the data centres located in the European Union. Only our authorised employees and those of our service providers have access to the Personal Data whereas they may access the data only for the purposes stipulated in the Privacy Policy.

We take all reasonable precautions to keep your Personal Data secure, accurate, complete, up-to-date and require any third parties that handle or process your Personal Data for us to do the same. Access to your Personal Data is restricted to prevent unauthorised access, modification, interference, loss or misuse and is only permitted among our employees and services providers on a need-to-know basis and/or pursuant to confidentiality obligations.

Your Personal Data will be saved on European servers that comply with the ISO/IEC 27001 standard.

However, despite our efforts to protect your Personal Data, no data transmission over Wi-Fi or the Internet or any processing of data via connected digital means can be 100% secure. Thus, we cannot guarantee the security of any information you disclose or transmit to us online.

In the event of a violation of your Personal Data that may create a high risk for your rights and freedoms, we undertake to inform you in writing as soon as possible. We will also describe the possible consequences of this violation as well as the measures that have been or will be taken to address it.

7. PERSONAL DATA RETENTION

Your Personal Data is retained for a period appropriate to the purposes for which it was collected and in any case, pursuant to the applicable laws and regulations in force in France.

8. TRANSFER OUTSIDE EUROPEAN UNION

We do not store your Personal Data on servers located outside European Union. However, you are informed and you agree that we may transfer your Personal Data to other trusted third parties located outside European Union, including countries who are not offering an efficient level of protection according to the European Commission (including but not limited to service providers and suppliers).

9. COOKIES

We use cookies to enhance your experience on the Website and to improve the provision of the services. Cookies are small text files that are placed on your computer, mobile or other device by websites that you visit.

• List of cookies used on our Website

When you visit our Website, we may, subject to your choice, install various cookies on your device.

Name of the cookie	Use
connecty_app	Main connecty logged session
connecty_remember	Long time session
connecty_http	Maintain session
connecty_httptoken	Security token for http connection
connecty_httsptoken	Security token for https connection
connecty_csrf	Security token for interactions

Cookies allow us:

• To adapt the layout of our Website (language, resolution, operating system used, etc.) to display preferences of your device when you visit our Website;
• To determine the date of your last visit to the Website, the pages you visit, the files you download (if applicable) and the type of browser, the number of people who visit the Website and the frequency of these visits, to personalise content;
• To store information that you filled on the Website (registration or access to your account);
• To enable you to access to restricted areas on our Website, such as your account with identifiers;

Third parties cookies may be placed on your browser via the Website for analytical and advertising purposes, but we do not have any control over how the information is collected and used by these third parties.

By using the Website, you are agreeing that we may use cookies for the purposes set in this Privacy Policy.

How to accept or reject cookies

You can choose at any time to express and edit your wishes regarding cookies, by following the instructions described below.

By changing your browser settings

You can configure your browser so that cookies are stored on your device or on the contrary, they are rejected, either systematically or by the issuer. You can also configure your browser so that the acceptance or rejection of cookies will be proposed from time to time, before a cookie is likely to be stored in your device. The "help" function on the toolbar on most web browsers will instruct you on how to prevent the browser from accepting new cookies, how to have the browser notify you when you receive new cookies and how to disable cookies altogether.

By deactivating the cookies according to the third parties procedure

However, please be aware that doing so may impair our Website and its functionality or may even render some or all of it unusable.

10. DATA SUBJECT RIGHTS

If you have any questions, comments or concerns about how we handle your Personal Data, you may contact us by email to [email protected].

You have the right, at any time, and free of charge, to tell us if you:

• don't want to be contacted in the future by us;
• would like us to correct, update, or delete your Personal Data in our records;
• wish to report any misuse of your Personal Data;
• want to access to information held about you or make use of your Personal Data portability right.

To assist us in dealing with your request, please provide your full name, details with a copy of your ID card/passport.

11. MODIFICATIONS TO PRIVACY POLICY

We may modify this Privacy Policy from time to time. All changes will be effective upon posting the updated version of the Privacy Policy on the Website. We will inform you about the changes as appropriate. We encourage you to read our Privacy Policy frequently to stay informed about how we use your Personal Data. You agree to be bound by any such changes if you continue to use the Website after such changes have been posted.