At Sapien, we value your privacy.
There are two distinct areas where Sapien collects your personal data. The first of which is during a direct investment in Sapien as a qualified investor, and/or the direct purchase of the Sapien utility token (“SPN”) from Sapien such as during the ICO and/or subsequent token offerings. These and similar actions require a KYC/AML screening on the part of Sapien and data collection related to KYC/AML is retained in a secure location with limited access in line with regulatory requirements.
The second area where Sapien collects your personal data is during interaction with the Site and/or Platform. The following sections outline your information collection, usage, control and disposal when you access and use Sapien’s Site, Platform, mobile apps, and other online products and services (collectively, the "Services") or when you otherwise interact with us.
How and Why Does Sapien Collect Your Data During Interaction with Sapien Services?
When you utilize Sapien Services or when you otherwise interact with Sapien, information that you directly provide to us is collected. This includes:
For What Other Purposes Does Sapien Use Your Data?
Sapien may collect and use Users personal information for the following purposes:
How Sapien Strives to Keep Your Information Secure
Sapien has instituted state-of-the-art best practices when it comes to storing and protecting your data. In compliance with GDPR, all encryption and decryption keys related to your data are maintained by Sapien and not outsourced to a third party. All appropriate security measures have been established to ensure that data collection, storage and processing practices are protected against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information, and/or any other data stored with our Services.
How Sapien Shares Data
Sapien does not sell, trade, or rent Users personal identification information to others. Sapien may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
However, when you use the Services, certain information may be shared with other Users and the public. For example:
Please note that, even when you delete your account, the posts, comments and messages you submit through the Services may still be viewable or available on our servers. For more information, see “How Can You Control Your Data” below.
We will not share, sell, or give away any of our Users’ personal information to third parties, unless one of the following circumstances applies:
Sapien’s Policy Regarding Data Sharing with Third Party Websites and Partners
Users may find advertising or other content on our Services that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Services. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Services, is subject to that website's own terms and policies.
We may partner with third-party advertisers, ad networks, and analytics providers to deliver advertising and content targeted to your interests and to better understand your use of the Services. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content such as unique identifiers, your IP address, or other information about your computer or device. For example:
For more information about how you may control the collection and/or use of information for advertising and analytics purposes, please see “How Can You Control Your Data.”
Children Under 18
Our Services are intended for general audiences and are not directed to children under 18. Therefore, individuals under the age of 18 may not create an account or otherwise access or use the Services. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we will take steps to delete that information.
How Can You Control Your Data?
As a Sapien user, you have choices about how to protect and limit the collection, use, and disclosure of information about you. This includes:
When Does Sapien Remove Your Data?
When you are no longer affliated with Sapien and/or any of our Services, we will ensure that your information is deleted from our systems to the extent possible, unless you direct otherwise.
Your posted electronic content may still be resident on a Blockchain; however, your personal association to the content can be removed as described in the “Electronic Content” section above.
For KYC/AML or any other governmental, regulatory and/or legal compliance obligation, the regulatory requirements pertaining to those obligations will be enforced by Sapien which may result in your data being retained by Sapien for a required timeframe.
International Data Transfers
If you wish to learn more about specific legal grounds we rely on to process your information for any particular purpose (including any legitimate interests we have to process this information), please contact us as provided under the Contact Us section. For example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.
In some regions, such as the EEA, you may have certain rights in relation to your personal information, including the right to access, correct, update, or request deletion of your personal information. Sapien takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You also can manage your profile and settings within our Platform. However, if you are not a user of our Services and you want to contact us directly about accessing, correcting, updating, or deleting your personal information, or altering your data or marketing preferences, you can do so at any time by contacting as provided in the “Contact Us” section. We will consider your request in accordance with applicable laws.
You can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us as provided in the “Contact Us” section. You also can deactivate your profile and obtain a copy of your information through your settings.
You can complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
If you wish to make a request based on the above, please inform us by contacting us as provided in the “Contact Us” section below. We may request evidence of your identity for verification purposes. We will respond to your request within the applicable statutory term.
Effective March 2, 2020