Privacy Policy
This policy establishes the basis on which APIS VTN LTD., its headquarters in Ellen L. Skelton Building, Road Town, Tortola, British Virgin Islands (BVI) will treat any personal information that it may collect, process, and protect, provided through the website https://vottun.com (hereinafter the "Website") respecting at all times the principles of legality, loyalty, and transparency, as well as the rest of the obligations and guarantees established in the current regulations.
1. WHO WILL PROCESS YOUR PERSONAL DATA?
• Data controller: APIS VTN LTD.,(hereinafter APIS VTN)
• Registered address: Ellen L. Skelton Building, Road Town, Tortola, British Virgin Islands (BVI)
• E-mail: [email protected]
2. FOR WHAT PURPOSES ARE THE DATA PROCESSED AND ON WHAT BASIS OF LEGITIMACY DOES THE PROCESSING RELY?
Personal data collected by APIS VTN will be processed in accordance with the purposes and on the basis of legitimacy indicated below:
| PURPOSE | LEGITIMACY |
|---|---|
| Management of user account registration, necessary for the acquisition of APIS VTN services. | Contractual compliance 6.1 b) RGPD |
| Processing of images of attendees at conferences/events organized by APIS VTN for informative and informative purposes. | Consent 6.1 a) RGPD |
| Data processing of candidates who apply for a selection process through the form on the APIS VTN website. | Consent/Intent to conclude a contract 6.1 a) y 6.1b) RGPD |
| Respond to requests, doubts, proposals and complaints sent by users through the contact forms provided on the Website. | Consent 6.1 a) RGPD |
| Processing of data provided when registering for a conference or information session, or when downloading free guides, ebooks or similar products through our website for direct marketing purposes. | Consent 6.1 a) RGPD |
| Sending commercial communications, including by electronic means, in order to keep you informed about products and services. At any time and in each of the communications received, you may object in a clear, free and simple way to receiving them. | Consent 6.1 a) RGPD |
| To comply with the legally established obligations | Legal obligation 6.1 c) RGPD |
| Proceeding with the SVTN token presale, this includes collecting and processing information from the data subjects who decided to purchase | Legitimate interest consisting of promoting the sale of the SVTN token Art. 6(1)(f) of the GDPR |
With regard to data processing based on consent, the user may revoke his or her request at any time and free of charge, although this does not affect the lawfulness of any processing previously carried out.
To revoke your request, you may contact APIS VTN by e-mail at [email protected]
With regard to data processing based on legitimate interest, the users may object to the processing of their data for reasons relating to their particular situation. APIS VTN will cease to process the data, except for compelling legitimate reasons, or for the exercise or defense of possible claims.
To object to the processing where it is based on legitimate interest, you may contact APIS VTN by e-mail at [email protected]
3. WHAT DATA WILL BE PROCESSED?
The data to be processed by APIS VTN within the framework of the relationship with the data subject and depending on the purpose of the processing shall include, but not be limited to, the following categories:
- Private contact data and identification data (name and surname, address, email, landline or cell phone number, ID card or similar document, IP address).
- Data related to employment and organization, (company, department, position, responsibilities, functions).
- Data relating to professional and training circumstances (career, job data, period of employment, tasks, activities, studies, qualifications, evaluations).
- Financial data for billing management (bank account).
- Data relating to photographs and videos on personal image. When attending activities and events organized by APIS VTN, the person concerned may be photographed or videotaped. Such photographs and videos are used by APIS VTN to inform you of the events it organizes as well as to provide you with information or communications that may be of interest to attendees.
- Data related to entry onto the SVTN token presale whitelist, such as: name, last name, email address (required data). This may also include data such as the declared amount of funds in USD to be invested in the SVTN token presale, Twitter (X) account name, Telegram account name, and/or information on where the data subject heard about APIS VTN (optional data).
In addition, in order to analyze the performance of our services, data derived from the use and contracting of our products and services will be used.
4. OBLIGATION TO PROVIDE DATA
The forms provided on the Web Site will identify the information that must be filled in. If the user does not provide the information marked as mandatory, APIS VTN will not be able to process the request.
5. HOW LONG WILL WE KEEP THE DATA?
APIS VTN conservará los datos personales de los usuarios únicamente durante el tiempo necesario para la realización de las finalidades para las que fueron recogidos, mientras no revoque los consentimientos otorgados. Posteriormente, en caso de ser necesario, mantendrá la información bloqueada los plazos legalmente establecidos.
En el caso de los datos que nos facilite en relación con el envío de las candidaturas, serán conservados durante un año, desde la fecha de la última actualización. Transcurrido dicho período, sin que hayan sido actualizados, los datos serán suprimidos, salvo que nos indique lo contrario.
Puede obtener más información en [email protected].
6. TO WHOM WILL YOUR DATA BE COMMUNICATED?
The personal data processed will not be communicated to third party companies, except with the prior information and express consent of the interested party.
In addition, we inform you that certain data, within the framework of the regulations in force or of the contractual relationship you maintain with APIS VTN, may be communicated to:
- Public administrations with competence in APIS VTN's sectors of activity, when so established by current regulations.
- The State Security Forces and Corps by virtue of the provisions of the Law.
- Banks and financial institutions for the collection of the services offered.
- Other professionals in the legal field, when such communication is required by law, or for the execution of the contracted services.
7. INTERNATIONAL DATA TRANSFERS
In the event that we transfer personal data or exchange personal data with third parties outside the European Economic Area, we will ensure that we and the persons or companies to whom we transfer personal data take appropriate protection measures in accordance with existing data protection legislation, in particular by using the safeguards of Chapter V of the GDPR, such as standard contractual clauses or such other mechanisms as may be appropriate from time to time.
8. RIGHTS OF THE INTERESTED PARTY
- Access: allows the data subject to obtain information on whether or not APIS VTN is processing personal data concerning him/her and, if so, the right to obtain a copy of the personal data being processed.
- Rectification: allows you to correct errors and modify data that are inaccurate or incomplete.
- Deletion: allows data to be deleted and no longer processed by APIS VTN, unless there is a legal obligation to keep it and/or there are no other legitimate reasons for APIS VTN to process it. For example, when personal data is no longer necessary for the purposes for which it was collected, the customer may request that we delete such data without undue delay.
- Limitation: under the legally established conditions, allows the processing of data to be stopped, so that APIS VTN avoids processing in the future, and will only keep the data for the exercise or defense of claims.
- Opposition: in certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. APIS VTN will cease to process the data, except for compelling legitimate reasons, or for the exercise or defense of possible claims. Likewise, the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on him/her or significantly affects him/her in a similar way.
- Portability: allows the data subject to receive his or her personal data and to be able to transmit it directly to another controller in a structured, commonly used and machine-readable format.
APIS VTN guarantees the adoption of the necessary measures to ensure the exercise of these rights free of charge, being necessary for such exercise that you identify yourself properly and communicate with us through the following channels:
- By writing an email through the following address, providing the same information set out in the previous section to: [email protected]
- By sending a letter by post, indicating in the request which right is being exercised, to the address Ellen L. Skelton Building, Road Town, Tortola, British Virgin Islands (BVI), to the attention of APIS VTN customer management.
Likewise, and especially when the interested party considers that he/she has not obtained full satisfaction in the exercise of his/her rights, he/she may file a complaint before the Spanish Data Protection Agency located at Calle de Jorge Juan, 6, 28001, Madrid or through www.aepd.es.
9. SECURITY MEASURES
APIS VTN is committed to keeping your Personal Data secure, taking all reasonable precautions to do so. To this end, we implement all necessary technical and organizational measures in accordance with this Policy and applicable laws and regulations to protect your Personal Data against any unauthorized access, modification or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.
We also contractually require our service providers and partners to apply an adequate level of security for the proper protection of personal data.
10. CHANGES TO THIS PRIVACY POLICY
This Policy may change over time due to possible changes in the criteria followed by the supervisory authority responsible for data protection at any given time. APIS VTN therefore reserves the right to modify this policy in order to adapt it to these criteria, as well as to new health, jurisprudential or legislative developments.
Last Update: 18/02/2025
