Privacy Policy
Last Updated on October 30, 2022
BlockTrans Syndicate (referred to herein as “Block Transfer”, "we", "our") reserves the right to change this Privacy Policy without notice. The last revision date is identified above. You are responsible for periodically checking https://www.blocktransfer.io/privacy for any changes.

Personally Identifiable Information and Non-Personally Identifiable Information
Block Transfer may collect two different types of information, Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”). PII that we collect is information that identifies you as an individual – and includes your name, address, email address, physical address, direct deposit information, and federal tax identification number. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools, your Stellar public address, and other information that does not reveal your specific identity. PII and Non-PII may be collected at any time when you access or use Block Transfer's website. PII and Non-PII may also be collected by Block Transfer during in-person discussions, telephone conversations, and electronic or other written communications including live chat and email tickets. On certain issuer webpages, Block Transfer also collects information via cookies to track marketing conversions.

Anyone can see your full account history, including all private sales executed using the Stellar Decentralized Exchange, as associated with you Stellar public address (GEXAMPLEKMHSY4...4H72C7TRWVX5NADDRESS) or an account nickname address, optionally defined by you during signup (happy.shareholder*blocktransfer.io). By interacting with your account wallet, you consent that this information be made public and associated with your account address on the Stellar distributed ledger. Your automatic pseudorandom account address does not reveal any of your PII, but you may choose to include PII in your nickname address. You consent that Block Transfer is not liable for any and all incidents due in any way to your identity being linked to your account, including due to the use of a public nickname address with PII.

Generally, you control the amount and type of information you provide to us when using our website. The personal information that we collect depends on the context of your interaction with Block Transfer's website, the choices you make, and the products and features you use. Block Transfer uses PII to respond to your inquiries, provide you with services you have requested, keep you informed of corporate updates for securities you hold, otherwise personalize your experience with Block Transfer, and other reasons. Block Transfer does not sell or lease PII about you to others, and may in some cases be liable for so doing under the Privacy Shield Framework outlined below. Block Transfer shares your PII with issuers as described in the Client Terms available at https://www.blocktransfer.io/terms. Third parties contracting with Block Transfer to provide services to you, including financial institutions, integrators you have chosen including Plaid, and other third party software services that you have consented to associate with your account by adding. Block Transfer employees who design our databases and software, client service staff, and our client service software partners also have access to PII as part of their job to provide You services.

Block Transfer reserves the right to disclose and use your PII if Block Transfer believes it is necessary to: respond to legal process; satisfy legislative requirements; respond to a law enforcement agency’s request including the FBI and FinCEN; enforce the Terms; or protect the rights, privacy, safety, property, or operations of Block Transfer or third parties, including instances where Block Transfer at its sole discretion suspects financial crime or money laundering. Because Non-PII does not personally identify You, Block Transfer reserves the right to use and disclose to third parties Non-PII for any purpose.

Block Transfer maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Block Transfer enforces its Privacy Policy via self-assessment. If a shareholder links a financial adviser to their wallet, block transfer may discuss the investor's personal information with such adviser.

Links to or From Other Sites
Block Transfer disclaims any responsibility for the accuracy or content of information found on third party websites that link to or are linked from blocktransfer.io. Block Transfer disclaims any responsibility for the security of any information (including without limitation PII) that you may provide to any third party.

Information; Registration; User Names and Passwords
As a client, you will be required to link your wallet to an identity maintained internally by Block Transfer. You warrant that the information you provide Block Transfer is truthful and accurate, and that you are not impersonating another person. You are responsible for maintaining the confidentiality of any password you may use to access your blockchain wallet, although we do not manage such platforms. You agree not to transfer your password or User name, or lend or otherwise transfer your use of or access to your account, to any third party. You are fully responsible for all transactions with, and information conveyed to, Block Transfer under your account. You agree to immediately notify Block Transfer of any unauthorized use of your password or User name or any other breach of security related to your account. You agree that Block Transfer is not liable, and you will hold Block Transfer harmless, for any loss or damage arising from your failure to comply with any of the foregoing obligations.

EU-US and Swiss-US Privacy Shield Frameworks
Block Transfer complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. Block Transfer has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov. For full definitions of the Privacy Shield Principles, please visit www.privacyshield.gov/EU-US-Framework.
Under the Privacy Shield, you have the right to access, correct, or delete your personal data. You also have the right to limit Block Transfer’s use of your data – including the right to opt-in or out of receiving communications from Block Transfer. To exercise any of these rights, please send an email to privacy@blocktransfer.io.

Third party data transfer. Block Transfer may be liable for the transfer of EU and/or Swiss personal data to third parties acting as our agents unless we can prove we are not responsible for the event given rise to the damages.

The Choice Principle. Note that we may be required to release personal data of EU and/or Swiss individuals in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Block Transfer commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should contact Block Transfer at the address or email listed below.

Block Transfer has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. Under certain limited conditions, individuals in the European Union or Switzerland may have the right to invoke “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. The Federal Trade Commission has jurisdiction with enforcement authority over Block Transfer’s compliance with the Privacy Shield.

Further Resolution and Federal Disclaimer
We collect personal information through our websites or text message service or receives personal information about you to enable us to provide our online and text message services to you and/or our clients. When we say personal information, we mean information that is about you or that can help identify you. You may be asked to provide personal information such as your name, address, phone number, Social Security number, date of birth, employee identification number, e-mail address, bank account details, credit card and/or debit card information, proxy voting preferences or information on your current shareholdings. We may also collect your IP address.

We use Social Security numbers for many purposes, including to verify your identity and to comply with federal and state laws such as tax laws and anti-money-laundering laws. We also may receive personal information about you from a third party authorized by you, such as a company in which you directly own shares, your broker, a class action defendant or another intermediary acting on your behalf. We may also receive personal information about you from third parties in connection with verification of your identity and services provided to our client.

We may share your information with affiliated companies and with other service providers or state/governmental agencies as necessary to process a transaction or service your account or provide services to our clients. All such parties will be obligated to maintain the confidentiality and security of your personal information and, except as may be required by law or governmental regulation, will be prohibited from further disclosing the information except in furtherance of the purposes for which it was disclosed, in which case such further disclosure will be subject to the same confidentiality and security obligations. We will not disclose your personal information to anyone outside these parties or sell to any parties for unsolicited marketing purposes. Given written permission, we may share issuer information with third parties on a referral basis in connection with products and/or services not offered by us.

Your personal information is processed and stored in the United States and may be transferred to, processed and stored in countries outside the United States by our service providers, all in accordance with this Privacy Policy. We may also disclose your personal information to overseas entities who assist us in supplying our services including through data storage solutions, back-up services, support, and identity verification systems. 

Tracking
In order to improve the quality of our website and services, we may from time to time send you what is known as a "cookie" as permitted by applicable laws and regulations. A cookie is a piece of text that a website transfers to your computer's hard drive. This cookie does not allow us access to your hard drive, but it assists in identifying, for example, whether you have visited our website on a previous occasion. Only the site that posted the cookie can read it. You may refuse to accept browser cookies by activating the appropriate setting on your browser.

Please note that the websites to which this site may be linked may also make use of their own cookies to collect information from you. Most browsers will automatically accept a cookie, but it may be possible to set your browser to notify you prior to a cookie being sent at which point you can accept or reject it. Additionally, we may collect information through the use of pixels, device IDs and similar technologies. A pixel is a line of code that is used by a website or third party to assign online activities to a computer or browser. The use of a pixel allows websites and us to record, for example, that a user has visited a particular website. Additional information from an earlier period or interaction may be included in the pixel.

Third Party Collection of Personal Information
Links to third party websites may be provided on this site for informational or other purposes. We are not responsible for any personal information you may choose to submit to a third party website accessed from this site.

Security Precautions to Protect Personal Information
We employ appropriate administrative, technical and physical safeguards designed to protect your personal information and to ensure that it is not accessed by unauthorized persons. Information is encrypted for transfer wherever this is possible. Our security procedures may require you to provide proof of identification before we will release personal information to you. This proof may be in addition to any password required to gain access to our online service. Multiple incorrect attempts or invalidation will result in a lockout from the information. We undergo periodic reviews of our security policies and procedures to help ensure that our systems are secure and protected.

You should never divulge your identification numbers, username, or password to anyone else. You should also never write your password down or store it on your computer and you should make sure you change it regularly. f you have further questions about Identity Theft, you may find the US Federal Trade Commission website helpful.

Users will only receive text messages if they have provided a mobile phone number or one is provided from a prior transfer agent. You consent to receiving text messages regarding your account including those pertaining to security notices. NOTE: Support will never ask for your login details or private key/seed phrase.

Public disclosure of registration address state and other financial information associated with your public key
For purposes of complying with Regulation A Tier 1 offing requirements relating to blue sky laws, we will make public the state of your registered address (or international if abroad), associated with your public key. By using our services, you represent that you are a resident of the state in your registered address, as you may periodically update on our books. Moreover, should you request custom Regulation A/CF contribution limits as a non-accredited investor based on income or net worth, you consent that the resultant limits will be made public and associated with your public key if duly approved. In addition, we may post publicly and associate any other information about your account with your public key as we see fit including whether or not you're an accredited investor (to our knowledge), securities for which you are or have been an affiliate per SEC Rule 501(a)(4/11) or Exchange Act Section 3(a)(4-1), whether or not you are a qualified institutional buyer, whether or not you are a securities dealer, whether or not you are a securities underwriter, whether or not your account is active, and the date your on-file accredited status expires.

Accessing and Updating Your Information
You may request a copy of the information that we hold about you by contacting us at the address below or emailing info-request@blocktransfer.io, after which you will be prompted to validate your identity. There may be a small charge for this service unless prohibited by law. We also try to ensure that all information we hold about you is accurate. If you find any inaccuracies we will delete these or correct them promptly, subject to our policies and procedures. Communication with you may be impeded if the information we hold is inadequate or inaccurate.

Additional Information for California Consumers
In addition to the information provided above, if you are a current resident of California, you may have certain rights regarding your personal information. For our clients that meet the definition of a business under the California Consumer Privacy Act (CCPA), we will assist those clients, to the extent possible, with the fulfillment of their obligations to respond to your requests. These may include, depending on the circumstance, the right to access the personal information that has been collected about you in the past twelve months; delete your personal information; restrict our use of your personal information; and opt-out from the sale of your personal information (if applicable). 

We will not discriminate against consumers for exercising their rights under the CCPA. If you would like to discuss or exercise the rights you may have, feel free to contact us via email or mail as described below.

Additional Information for EU/EEA Residents
In addition to the information provided above, if you are a current resident of an EU/EEA country, you may have certain rights regarding your personal information. Computershare will assist our data controller clients, to the extent possible, with the fulfillment of their obligations to respond to your requests. These may include, depending on the circumstance, the right to access your personal information; rectify the personal information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with your local data protection authority; and withdraw any consent you have given to the uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us.
This Privacy Statement only applies to Computershare websites and does not apply to any websites from which you may have linked to this website or to any website to which you may link from this website.

Public Keys
The Stellar ledger is available to the public and will store the complete transaction history from issuance of the Issuer Assets. As a result, robust and transparent data, other than shareholder personal identifying information, will be publicly available via block explorers. Accordingly, data regarding the issuance and redemption of various Issuer Assets (and not a shareholder’s personal identifying information) will be exposed to the public. We maintain the PII necessary to associate a given security with the record owner of that security in a separate, traditional database that is not available to the public. However, if there are data security breaches resulting in theft of the information necessary to link personal identities with Issuer Assets, the stolen information could be used to determine an investor's identity and complete investing history in Issuer Assets

Moreover, outside actors may be able to resolve your public key to your identity based on (i) a public transaction history that matches your public investing profile or (ii) user-provided PII used in wallet federation address. You consent that we are not liable for any damages, materialized or not, which result in anyone knowing the full and total trading, transfer, and miscellaneous public history of your account.

Ownership
In most cases, if mail is returned as undeliverable we are required to take certain steps to try to find you free of charge. If these attempts are unsuccessful, however, we may deduct the costs of any additional efforts to find you from your account at our sole discretion, namely state escheatment fees. These costs may include a percentage of the account when a search company charges a percentage fee in exchange for its location services.

Payments including dividends may be sent to you by electronic funds transfer ("ACH"). Neither Block Transfer nor its agents shall be liable to you or any other person if, for any reason, a redemption request by ACH is not processed properly.

In the event of disputes involving conflicting claims of ownership or authority to control your Issuer Assets, we have the right (but has no obligation) to: (i) restrict the shares and require the written agreement of all persons deemed by us to have a potential interest in the Issuer Assets before executing instructions regarding the Issuer Assets; or (ii) interplead disputed Issuer Assets or the proceeds from the court-ordered sale thereof with a court of competent jurisdiction. Should the Fund be required to defend against joint or multiple shareholders in any action relating to an ownership dispute, you expressly grant us the right to obtain reimbursement for costs and expenses including, but not limited to, attorneys’ fees and court costs, by unilaterally disposing of Issuer Assets from your account.

We may be required (i) pursuant to a validly issued levy, garnishment or other form of legal process, to sell your Issuer Assets and remit the proceeds to a levying officer or other recipient; or (ii) pursuant to a final order of forfeiture or other form of legal process, to sell your shares and remit the proceeds to the U.S. or state government as directed.

As long as we or our agents follow reasonable security procedures and act on instructions we or our agents reasonably believe are genuine, we and our agents will not be responsible for any losses that may occur from unauthorized requests in any form (written, telephone, online, etc.). We will investigate any unauthorized request that you report to us and we will ask you to cooperate with us in the investigation, which may require you to file a police report and complete a notarized affidavit regarding the unauthorized request. We will assist in the claims process, on your behalf, with other financial institutions regarding the unauthorized request.

Using good faith efforts, we attempt to identify class action litigation settlements and regulatory or governmental recovery funds involving bankruptcy proceedings related to issuers, class action litigation settlements, and regulatory or governmental recovery funds involving present or former Issuer Assets ("Claims") in which we may be eligible to participate. When such Claims are identified, the we will file proofs of claim. Currently, such Claim opportunities predominate in the U.S. and in Canada; our efforts are therefore focused on Claim opportunities in those jurisdictions. The investment manager may learn of such class action lawsuit or victim fund recovery opportunities in jurisdictions outside of North America ("Foreign Actions"), in which case we have complete discretion to determine, on a case-by-case basis, whether to file proofs of claim in such Foreign Actions.

Privacy Concern Contact Methods:
Email: privacy@blocktransfer.io
Regular Mail: Block Transfer, Attn: Legal Department, 99 Wall Street #4640, New York, NY 10005.