Privacy Policy

We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data. This Privacy Policy aims to give you information about how we collect and process your personal
data when you visit our websites (including subdomains of our websites) and applications through which we make our products/services available, including, for example our Filedgr NFT viewer
application via Xumm and Filedgr API (together, the “Platform”). This Privacy Policy would apply regardless of where you visit our Platform from and would apply to any data that you may provide through our Platform, when you purchase our products/services, or when you otherwise interact with
us.
Our Platform is not intended for children, and we do not knowingly collect data relating to children. Please read this Privacy Policy carefully and ensure that you understand it. By using our Platform or products/services, you agree to be bound by this Privacy Policy and consent to the collection, use, processing, and disclosure of your personal data as described in this Privacy Policy. It is important you read this Privacy Policy together with any other Privacy Policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and
privacy policies and is not intended to override them. References to “you” or “your” are to you as an individual using our Platform or otherwise contacting us (whether on behalf of yourself, or another individual or organisation).

1. INFORMATION ABOUT US

  1. Our Platform is owned and operated by Filedgr, a Luxembourg private limited
    liability company (société à responsabilité limitée) having its registered office at 40,
    rue Glesener, L-1630 Luxembourg and registered with the Luxembourg Register of
    Commerce and Companies under number B274.857 (“Filedgr”, “we”, “us”, or
    “our”). We are the controller and are responsible for our Platform. 
  2. We are responsible for your personal data, except where we process your personal
    data because you use our products/services as a result of your relationship with a
    partner who we work with or supply our products/services to.
  3. Where we process your personal data because you use our products/services as a
    result of your relationship with a client who we supply our products/services to, we
    are not the data controller as we would be processing personal data on behalf of our
    client as a data processor.
  4. Where we are processing your personal data on behalf of our client, the privacy
    policy that you should be referring to would be our client’s privacy policy. Our client’s
    privacy policy should inform you as to how your personal data will be processed.
  5. We are bound by applicable data protection laws in respect of the handling and
    collection of your personal data. We are a data controller within the meaning of the
    Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
    2016 on the protection of natural persons with regard to the processing of personal
    data and on the free movement of such data, and repealing Directive 95/46/EC
    (General Data Protection Regulation).

2. OUR CONTACT DETAILS

If you have any questions about this Privacy Policy, including any requests to exercise your
legal rights, please contact us using the details below: 


Email address: privacy@filedgr.com

3. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

  1. Personal data or personal information means any information about you that enables you to be identified personally.
  2. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers that can be linked with such information in order to identify you. It does not include data where the identity has been removed (anonymous data).
  3. Depending on the use you make of our Platform, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
    • a. Identity Data includes your name, username or similar identifier, marital status, job title, date of birth and gender
    • b. Contact Data includes residential address, business addresses, billing address, delivery address, email address and telephone numbers.
    • c. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Platform, and other technology on the devices you use to access our Platform.
    • d. Profile Data includes data about your interests, preferences, feedback, and survey responses.
    • e. Usage Data includes information about how you use our Platform or products/services.
    • f. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  4. We do not ask you for any Special Category Data about yourself. Special Category Data includes information about your race or ethnicity, health, hobbies, religious or political beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. We also do not ask you for any information about criminal convictions and offences.
  5. We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law and will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature of our Platform or aggregate statistics about the behaviour of visitors and users of Filedgr API. However, if we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

4. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with
you, or pursuant to a product/service that we have been asked to supply to you, and you fail to
provide that data when requested, we may not be able to perform the applicable contract or
deliver the applicable product/service. In this case, we may have to cancel any arrangement
you have with us, but we will notify you if this is the case.

5. HOW WE COLLECT YOUR PERSONAL DATA

  1. We use different methods to collect data from and about you, including through:
    • a. Direct interactions. You may give us your personal data by entering information on our Platform e.g., when registering for Filedgr API, filling in forms or questionnaires, subscribing to our service or publications, by corresponding with us by phone or email, or by otherwise directly interacting with us.
    • b. Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy (https://filedgr.com/privacy/cookies) for further details.
    • c. Third parties or publicly available sources. We may receive personal data about you from various third parties (such as the partners we work with from time to time in relation to the running and operating of our Platform) and public sources, including analytics providers, search information providers, publicly available social media accounts, technical and payment services, data brokers or aggregators.
  2. We offer our Filedgr NFT viewer application via the Xaman Wallet, which is owned and operated by The Integrators B.V. (trading as XRPL Labs). As part of offering our services through the Filedgr NFT viewer application, we may receive personal data about you from XRPL Labs. You should therefore refer to the privacy policy of XRPL Labs for more information on how your personal data may be processed by XRPL Labs.

6. PURPOSES FOR PROCESSING PERSONAL DATA

  1. We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    • a. Where we need to provide products/services or information to you or to perform the contract we are about to enter or have entered with you.
    • b. Where we have a legal or regulatory obligation we must comply with.
    • c. Where it is necessary for our legitimate interests (or those of a third party and your interests and fundamental rights do not override those interests. Generally, we do not rely on consent as a legal basis for processing your personal data.
  2. We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
Types of personal data What we use your personal
data for		 Our reasons (legal bases)
Identity Data 
Contact Data
Profile Data 
Marketing and
Communications Data		 Providing and managing your
access to our Platform,
including managing our
relationship with you (such as
notifying you about changes
to our terms or privacy policy,
or asking you to leave a
review or take a survey)		 Performance of a contract
with you
Necessary for our legitimate
interests (for example, to
keep our records updated and
to study how our Platform is
used)
Necessary to comply with a
legal or regulatory obligation
Identity Data 
Contact Data 
Profile Data
Marketing and
Communications Data 
Technical Data 
Usage Data		 Personalising and tailoring
your experience on our
Platform and measuring or
understanding the
effectiveness of any
advertising we serve to you		 Necessary for our legitimate
interests (for example, to
provide users with a good
experience and to inform our
marketing strategy)
Identity Data 
Contact Data
Technical Data		 Administering and protecting
our Platform and business
(including troubleshooting,
data analysis, testing, system
maintenance etc.)		 Necessary for our legitimate
interests (for example, for
running of our business,
provision of administration
and IT services and network
security) 
Necessary to comply with a
legal or regulatory obligation
Identity Data 
Contact Data 
Profile Data 
Usage Data		 Being as responsive as
possible to you, for example,
when answering your queries		 Necessary for our legitimate
interests (for example, to
provide you with a good
service) and for your
legitimate interests (for
example, to receive
assistance promptly)
Identity Data 
Contact Data 
Marketing and
Communications Data		 Supplying you with
information by email, post, or
other means that you have
opted-in-to (for example,when you have subscribed to
receive such information)		 Necessary for our legitimate
interests (for example, to
provide a good service, grow
our business, and develop our products/services, and
for your legitimate interests
(for example, to obtain
information you have asked
for)
Identity Data 
Contact Data		 Providing services to you
which you have requested for
via the Platform (such as
where you have contacted us
to make a listing request)		 Necessary for our legitimate
interests (for example, to
improve our Platform) and
for your legitimate interests
(for example, to have your
collection listed on our
Platform)
Technical Data
Usage Data		 Using data analytics to
improve our Platform,
marketing, products/services,
and user relationships and
experiences		 Necessary for our legitimate
interests (for example, to
keep our Platform relevant,
to develop our business and
to inform our marketing
strategy)
Your consent
Identity Data
Contact Data		 Registering you as a new user
on our Platform		 Performance of a contract
with you 
Necessary for our (and your)
legitimate interests (for
example, to provide a
product/service to you)
  1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
  2. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. MARKETING

  1. We may send you marketing communications by email, text message, telephone, or email. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
  2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our business offerings may be relevant to you.
  3. We will get in your express opt-in consent before we share personal data with any third party for marketing purposes.
  4. Opting out of marketing:
    • a. You can ask us or third parties to stop sending you marketing messages at any time.
    • b. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
    • c. If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.

8. AUTOMATED DECISION MAKING

  1. Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.
  2. We do not make any automated decisions.

9. HOW WE MAY SHARE YOUR PERSONAL DATA

  1. We may share your personal data with certain parties as set out below: 
    • a. External third parties such as: 
    • b. Third parties to whom we may choose to sell, transfer, or merge parts of our
      business or our assets. Alternatively, we may seek to acquire other businesses
      or merge with them. If a change happens to our business, then the new
      owners may use your personal data in the same way as set out in this Privacy
      Policy.
  2. We require all third parties to respect the security of your personal data and to treat it
    in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  3. International transfers. We may need to share your personal data outside Luxembourg and/or EEA, for example, where our third parties are based in other countries. Whenever we transfer your personal data out of Luxembourg and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
    • a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
    • b. If we transfer your personal data to any other country which is not subject to an adequacy decision of Luxembourg or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in Luxembourg or the EEA (as applicable).
    • c. Where we use certain service providers outside of Luxembourg and/or the EEA (as applicable), we may use specific contracts approved for use in Luxembourg and/or the EEA (as applicable) which give personal data the same protection it has in Luxembourg and/or the EEA (as applicable).

10. DATA SECURITY

  1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
  2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
  3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. HOW WE RETAIN YOUR PERSONAL DATA

  1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing our services to you and satisfying any legal, regulatory, tax, accounting or reporting requirements.
  2. We may retain your personal data for a longer period in the event of a complaint if we reasonably believe there is prospect of litigation in respect of our relationship with you.
  3. 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 unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  4. In some circumstances you can ask us to delete your data (see your legal rights below).
  5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  6. Otherwise, we securely erase or anonymise your personal data where we no longer require your information for the purposes collected.