This Privacy Policy governs the processing of your personal data by NGRAVE (hereinafter: “NGRAVE”, “we”, “us”, “our”) whenever you use our website www.ngrave.io (hereinafter: “Website”); and/or communicate with us via e-mail, telephone, and social media (hereinafter: “Social Media Channels”; e.g. Facebook, LinkedIn and Twitter).

NOTE: If you want information on how we process personal data via cookies and social plug-ins on our Website, you are kindly referred to our Cookie Policy.

1. In General

1.1. Your personal data are processed by NGRAVE, a company registered as Ngrave.IO NV under Belgian company number 0700.252.896, having its registered office at Kloosterstraat 94, 2000 Antwerpen. NGRAVE can be contacted via e-mail at privacy@ngrave.io

Explanation: This is the entity responsible for the processing of your personal data as covered in this Privacy Policy.

1.2. Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.

Explanation: To make sure we have the same understanding of what is written here, it is important that certain notions are interpreted in the same way by you and by us.

1.3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.

Explanation: Laws tend to change from time to time, and we want to make sure that this Privacy Policy remains in line with any such changes.

1.4. NGRAVE reserves the right to modify, change or amend this Privacy Policy at its own discretion and from time to time. Such modification, change, or amendment shall be communicated via the Website. If you do not accept the modifications, changes, or amendments, you are to inform us by sending an e-mail to privacy@ngrave.io. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Policy have been announced in a visible manner on our Website, you will be deemed to have unambiguously accepted all such changes.

Explanation: As any company, changes in laws, market circumstances, interests etc. may require us to change our Privacy Policy from time to time to ensure that it remains accurate. If this happens, you are kindly asked to take note of the changes and to agree with them if you find them acceptable.

1.5. NGRAVE collects, stores and processes data as part of its services to the User, including personal data from you and about you from various sources to provide our services and to manage our Website. “You” may be a visitor to our Website, or a user of our services (“User”).

Explanation: This Privacy Policy explains how we collect personal data from you.

2. Types of personal data we process

2.1. Whenever you visit our Website and Social Media Channels, we may collect:

• technical information associated with the browser and device you use, such as your IP address, device type, operating system and Internet browser type;

• geographic data, based on your IP address;

• usage data, such as time spent on the Website, pages visited, links clicked, and the pages that led or referred you to our Website;

• information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services, for which we use Google Analytics or similar tools.

Explanation: Here we explain which types of personal data we collect in any case whenever you visit our Website and Social Media Channels.

2.2. When you respond to NGRAVE’s emails or surveys, subscribe to our newsletter, fill out our online form to contact our sales team, give us your business card or contact details at conferences or other events, or contact us via e-mail, telephone, or Social Media Channels, we may collect:

• the basic identity information you provide us with, such as your full name, e-mail, phone number, country, and anything else you tell us about you, your needs and timeline;

• the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.), including anything else you tell us about you, your needs and timeline;

• your preferences regarding receiving our e-mail communications, such as newsletters, promotions, advertisements, etc.

• publicly available information of your profile on Social Media Channels;

• any other personal data you choose to provide to us.

Explanation: Here we explain which types of personal data we collect when you actively seek to contact us or want us to contact you.

2.3. When you apply for a job via e-mail, we collect and process the following categories of personal data:

• personal identification data (e.g. name, e-mail address);

• the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);

• any attachments you send us, such as your CV.

Explanation: Here we explain which types of personal data we collect when you apply for a job with us.

2.4. When you place an order on our Website, our payment partners may collect:

• personal identification data, such as name, e-mail address, and shipping information;

• payment information, such as credit card number, name on the card, expiry date and security code, or Coinbase account information and cryptocurrency address, depending on the payment method used.

Explanation: Here we explain which types of personal data we collect when you place an order on our Website.

3. Purposes for which NGRAVE uses your personal data

3.1. NGRAVE processes your personal data to provide you its services in a personalized and efficient way with the Website, e-mail, telephone, and Social Media Channels, and for overall customer management.

Explanation: We first and foremost collect and process your personal data to provide you with the things you request by surfing to our Website, log in once registered, or when you interact with us.

3.2. NGRAVE will enter into a contract with you to provide its services. This contract requires us to process certain personal data.

Explanation: We have to process certain personal data to provide you with our services.

3.3. NGRAVE processes your personal data mentioned in clause 2.3 above specifically to allow you to apply for a job with us.

Explanation: This provision is self-explanatory.

3.4. We will also process your personal data when you apply with us for evidence purposes, so that we may defend ourselves in possible ensuing legal or other proceedings.

Explanation: This provision is self-explanatory.

3.4. We will also process your personal data when you apply with us for evidence purposes, so that we may defend ourselves in possible ensuing legal or other proceedings.

Explanation: This provision is self-explanatory.

3.5. NGRAVE processes your personal data to perform statistical analyses so that we may improve our Website, our services or develop new services.

Explanation: This provision is self-explanatory.

3.6. NGRAVE processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

Your personal data may be transferred upon NGRAVE’s own initiative to the police, financial intelligence units, or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.

Explanation: From time to time we may be legally required to transfer your personal data to governmental authorities.

3.7. NGRAVE may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.

Explanation: This provision is self-explanatory.

3.8. NGRAVE may process your personal data for the preservation of the legitimate interests of NGRAVE, its partners or a third party if and when your registration with, or use of, the services, Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website and/or services, (c) a danger to the Website and/or services or any of NGRAVE’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

Explanation: Here we reserve the right to process your personal data if you use our Website in any way that may harm NGRAVE or someone else or is illegal.

3.9. NGRAVE may also process your personal data mentioned under clauses 2.1 and 2.2 above for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of NGRAVE and selected partners, or to invite you to participate in our events or surveys. Using Google Analytics and other marketing and analytics tools, we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”).

Unless you are an existing customer who has already used our services and who we wish to target with our own marketing material, NGRAVE will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements. You may at any time opt out from receiving future marketing or other communications.

Explanation: We want to use your personal data for marketing purposes. This means that we collect information regarding your preferences and interests and use this information to make our marketing material more relevant to you.

When we want to send you marketing material via e-mail, Social Media Channels or other person-to-person electronic communications channels and unless you are a pre-existing customer, we will first seek your prior approval with receiving our marketing via such channels.

4. Legal basis for processing your personal data

4.1. The processing of your personal data for the purpose described in clause 3.3 is necessary for the steps to be taken prior to entering into a contract with you.

Explanation: The law requires us to state precisely which legal basis we use to process your personal data, considering the purposes we have listed in the previous article.

When you send us CV and other data to apply for a job, we need to process your personal data in order to give full effect your application.

4.2. The processing of your personal data for the purposes outlined in clause 3.2 is necessary to allow NGRAVE to carry out its obligations under the contract with you.

Explanation: To use our services, you enter into a contract with us. The provision of these services requires us to process certain personal data.

4.3. The processing of your personal data for the purposes outlined in clause 3.6 is necessary to allow NGRAVE to comply with its legal obligations.

Explanation: Sometimes the law obliges us to process your personal data.

4.4. The processing of your personal data for the purposes outlined in clauses 3.1, 3.4, 3.5, 3.7 and 3.8, is necessary for the purpose of the legitimate interests of NGRAVE, which are:

• being able to appropriately respond to your requests for information and other requests;

• allowing us to defend ourselves in legal proceedings;

• continuous improvements to NGRAVE’s services, Website, Social Media Channels, products and services to ensure that you have the best experience possible;

• keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;

• safeguarding our commercial and business interests and needs in light of changing market conditions;

• marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.

Explanation: We may also process your personal data for our own legitimate interests, which are mainly concerned with successfully conducting our business as any other company would do.

4.5. For processing your personal data for the purposes outlined in in clause 3.9, NGRAVE as the responsible party asks for your consent.

By consenting to our processing of your personal data for sending you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels, you agree that we are allowed to process your personal data for this purpose in the manner and under the conditions outlined in this Privacy Policy.

Explanation: This provision is self-explanatory.

5. Recipients and transfers

5.1. We share personal data with third party business partners when this is necessary to provide our services to our Users. Examples of third parties to whom we may disclose personal data for this purpose are payment services providers when you place an order on our Website.

Explanation: To perform our services, some information needs to be transferred to other parties.

5.2. Other than the case provided for in 5.1, NGRAVE does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. We may share personal data with other NGRAVE entities in order to provide our services and for internal administration purposes.

You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers. You can find more information on how these social media providers process your personal data in their respective privacy policies.

Explanation: We do not share your personal data with third parties unless you consent to it or unless we have anonymized your personal data.

You understand however that when you use, for instance, Facebook to communicate, Facebook also processes your personal data.

5.3. NGRAVE relies on the services of third-party processors, for instance, for website hosting, analytics, etc. These third-party processors are only allowed to process your personal data on behalf of NGRAVE upon explicit written instruction of NGRAVE. NGRAVE warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

Your use of our Website implies that your personal data may be transferred outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:

• The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or

• A contractual arrangement between NGRAVE and that entity.

Explanation: Our Website and services may be developed, maintained or hosted by third parties. Similarly, we rely on the services of third parties to process your personal data internally.

6. Quality assurance

6.1. NGRAVE does its utmost to process only those personal data which are necessary to achieve the purposes listed under the purpose for processing.

Explanation: We will not process more personal data about you than we really need for the purposes we have communicated to you.

6.2. Your personal data are only processed for as long as needed to achieve the purposes which are described above or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website and/or services. NGRAVE will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, unless there is:

• an overriding interest of NGRAVE or any other third party in keeping your personal data identifiable; or

• a legal or regulatory obligation or a judicial or administrative order that prevents NGRAVE from de-identifying them.

Explanation: Here we explain how long we will keep your personal data in a way that allows us to identify you.

6.3. NGRAVE will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of NGRAVE or its third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.

Explanation: We are committed to keeping your personal data safe.

7. Your rights

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.1. You have the right to request access to all personal data processed by NGRAVE pertaining to you. NGRAVE reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to NGRAVE.

7.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.

7.3. You have the right to withdraw your earlier given consent under clause 4.5 for processing your personal data.

7.4. You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by NGRAVE against:

• overriding interests of NGRAVE or any other third party;

• legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that NGRAVE limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.

7.5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

7.6. You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.

7.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@ngrave.io for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card proving your identity. NGRAVE will promptly inform you of having received this request. If the request proves valid, NGRAVE shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request. If you have any complaint regarding the processing of your personal data by NGRAVE, you may always contact NGRAVE via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with NGRAVE’s response, you are free to file a complaint with the competent data protection authority. For a list of national data protection authorities, visit https://edpb.europa.eu/about-edpb/board/members_en.