PRIVACY POLICY FOR CHAINAR

1. GENERAL INFORMATION

1.1 CHAINAR  and general information
CHAINAR is an on- and off chain investigation unit, under Chainar AB, company registration number, 559436-1353 having its registered address at Epicenter Stockholm, Mäster Samuelsgatan 36, 111 57 Stockholm. “CHAINAR”, “we” or “us” acts as the personal data controller for the personal data processed under this Privacy Policy. Therefore, we want to make it clear to you how we work with your privacy and process your personal data. In this policy you will find the information you need to understand our process and the purpose behind the  process. If any questions would occur, you are always welcome to contact us via operations@chainar.se.

1.2 This Privacy Policy describes the information we collect, the purpose for which they are collected, the legal basis for our processing, the way in which you can exercise your rights and how you can contact us. 

This Privacy Policy applies when you register as a client/customer (“Client”) of Chainar for our investigation and consultation service (“Service”), or when a request for assignments is sent to us, where we provide the client with a recommendation for what we can offer in the specific case (“Service Offer”). 

1.3 All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refer to the General Data Protection Regulation (Regulation no. 2016/679) with the connecting national implementations and related national legislation. 

2. PROCESSED DATA 

2.1 Clients
We will process the following personal data for the purpose of providing our Services to you as a client and to fulfill requirements by law, we might process following types of data (a) Name; (b) Address; (c) Phone number; (d) E-mail address; (e) Profession; Company name including organization number or personal identification number; (f) Billing address; (g) Wallet address, (h) Other information that is of necessity for the investigation and service provided.

The legal basis of processing this personal data is the obligations and requirements set by the law, performance of the contract with you as a natural person and/or company, and or on the legal basis of legitimate interest, or consent.

CHAINAR also has a legitimate interest in maintaining a good customer relationship with you, providing you with information relevant to your use of the Services, improving and further developing the Service. CHAINAR further has a legitimate interest in conducting and managing our business to enable us to provide you with the best possible service and a good and safe user experience. CHAINAR needs the above information in order to fulfill our commitments and provide the Services to you as a Client. We only process the personal data that we consider necessary. If we do not get access to the above information, we will also not be able to provide the Services to you or your company/organization.

2.2 The amount of data we will process depends on the characteristics and the size of the request of the Service/Consultation/Investigation. 

2.3 Feedback and security maintenance
Beside the above purposes of processing, we might process your personal data for the following purposes: (i) To ask for your feedback and opinion regarding our Services from time to time; (ii) To check, prevent, investigate or take other actions in connection with abuse of our Services or in connection with the use of the Services in violation of the Terms of Service or other legal procedures, suspected fraud or potential threats against CHAINAR or rights of others. Our legal ground for the above-mentioned purposes is our legitimate interest to provide a well-functioning Service and to constantly provide better Services for our clients. In that we also have a responsibility to check, prevent and investigate any actions in connection with the use of the Services and in violation of Terms of Service, or in violation of the law. In order to improve and develop our Services, ensure the technical functionality of our Services and improve the security of our networks and information systems, we regularly analyze our clients’ use of the Services.

3. DISCLOSURE OF PERSONAL DATA 

3.1 Transfer of personal data to third parties.
We will not divulge, sell, transfer or otherwise disclose personal data beyond the terms of this Privacy Policy, unless we are required to do so by law or as a result of a court order or authority decision or if we have received your consent to such disclosure. CHAINAR can hire external providers to perform tasks on behalf of CHAINAR, e.g. to provide IT services. The execution of these services may mean that CHAINAR suppliers, both within the EU/EEA and outside the EU/EEA, have access to your personal information. These suppliers process personal data on our behalf in accordance with a data processing agreement and in accordance with our instructions. 

CHAINAR only collaborates with partners which are compliant to  General Data Protection Regulation (Regulation no. 2016/679). In case CHAINAR chooses to hire suppliers outside the EU/EEA, CHAINAR will undertake appropriate safeguards for the processing of such personal data. You can acquire further information regarding the transfer by contacting us.

4. RETENTION OF PERSONAL DATA 

4.1 Personal data is processed only for as long as it is necessary for the purposes above or to the extent otherwise required by law. 

4.2 For personal information relating to the Service, we will process your personal data starting from when you become a client and then up to 12 months after the closed case. This is for administrative and accounting purposes, such as any missed payments and the opportunity for you to recreate your account. 

4.3 For accounting information that may constitute personal data, we have an accounting obligation according to the Bookkeeping Act to archive the information for 7 years after the end of the financial year. 

4.4 The same personal data can be stored in several different locations for different purposes. This may mean that a task that has been deleted from a system because it is no longer necessary may remain in another system where it is stored on the basis of another legal ground or for another purpose where the personal data is still needed.

5. YOUR RIGHTS
You have a wide range of rights regarding the information we collect about you. Below we describe these. You may exercise these rights by contacting us by using our contact information below, see the section of “6. CONTACT INFORMATION”. 

5.1 Right to information
You have the right to request access and further information concerning the processing of your personal data. You also have the right to obtain a copy of the personal data that we process relating to you free of charge. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs. 

5.2 Right to rectification 
You have the right to request that we correct, complete or rectify the processing of your personal data. 

5.3 Right to erasure 
You may, in some cases, have the right to have your personal information deleted: (i) If personal data is no longer necessary for the purposes for which they were collected; (ii) If the processing is based on your consent, you have the right to withdraw your consent at any time which means that we will delete your personal data; or (iii) If personal data has been processed illegally or they must be deleted due to legal obligation; However, the right to erasure is not applicable in some cases, for example, if the processing is necessary in order for CHAINAR to comply with a legal obligation or in order for CHAINAR to be able to determine, claim or defend legal claims. 

5.4 Right to restriction
In some cases, you may request that CHAINAR limit the processing of your personal data, such as: (a) if you do not believe that your personal information is accurate for which CHAINAR shall have time to check this; (b) if the processing is illegal and you do not want us to delete the data; (c) if CHAINAR no longer needs the information but you need them for legal claims or if you object to CHAINAR’s processing based on our legitimate interest and it is pending verification regarding if the legitimate reasons of CHAINAR or a third party override your rights and freedoms. 

5.5 Right to object
You have the right to object to the processing of your personal data based on our legitimate interest at any time. CHAINAR may not continue to process such personal data unless CHAINAR cannot provide compelling legitimate reasons for such processing that overrides your interests, rights and freedoms. However, CHAINAR may continue processing such personal data for the determination, exercise or defense of legal claims. You have an absolute right to object to the processing of your personal data for direct marketing, which means that if you object to such processing CHAINAR may no longer process your personal information for direct marketing purposes. You can at any time opt out from receiving marketing communications from us by clicking “unsubscribe” in the email we send you at the time of collection and any subsequent e-mail thereafter.  

5.6 Right to data portability
If the processing is based on the legal grounds of consent or fulfillment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to other data controllers.

6. CONTACT INFORMATION
To exercise your rights, or if you have any questions regarding our processing of your personal data, feel free to contact us by sending an e-mail to: operations@chainar.se. In your email please state your full name and contact information. Note that you should sign the request to receive information about the processing of your personal data yourself.

7. LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY 
If you have any complaints regarding our processing of your personal data, do not hesitate to contact us via the contact information above. Also you may file a complaint to the competent data protection authority.

8. NOTICE OF CHANGES TO THE PRIVACY POLICY
If we make changes to this Privacy Policy we will notify you on our website. 

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