Privacy Policy
Last Updated on June 7, 2022
BlockTrans Syndicate (referred to herein as “Block Transfer”) reserves the right to change this Privacy Policy without notice. The last revision date is identified above. You are responsible for periodically visiting https://www.blocktransfer.io/privacy to check 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.

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.

IV. 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:

Email: privacy@blocktransfer.io
Regular Mail: Block Transfer, Attn: Legal Department, 131 Ponce De Leon Ave NE, Suite 405, Atlanta, GA 30308

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.




Computershare collects 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 Computershare-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. At your direction, we may share your information with third parties on a referral basis in connection with products and/or services not offered by Computershare.
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 Computershare's service providers, all in accordance with this Privacy Statement. As Computershare forms part of a global group of companies, we may also disclose your personal information to overseas entities within the Computershare Group who assist us in supplying our services including through data storage solutions, back-up services and IT support. These entities are generally located in Canada, New Zealand, the United Kingdom and Australia. We may also disclose your personal information to other overseas affiliates and service providers who assist us in supplying our services or who perform functions on our behalf, all in accordance with this Privacy Statement.
Data Collection Technologies
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 Computershare 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. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
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. Currently, Computershare does not respond to "Do Not Track" signals from browsers.
If you access an online service maintained by Computershare or one of its subsidiaries (for example, Investor Center, which is maintained by Computershare Inc.) we may use a tool called "Google Analytics" which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use the information we get from Google Analytics to help us understand website traffic and webpage usage. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.
We may share the information we collect via cookies and Google Analytics with our related entities within the Computershare Group including entities located outside of the United States who assist us in supplying our services including through data storage solutions, back-up services and IT support. These entities are generally located in Canada, New Zealand, the United Kingdom and Australia. We may also disclose it to others if required to do so by law.
Third Party Collection of Personal Information
Links to third party websites may be provided on this site for informational or other purposes. Computershare is 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 and have consented to such service. Text messages will be sent in accordance with the terms of consent and any applicable terms and conditions.
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. 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), Computershare 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). Computershare 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 in the section "How to Contact Us".
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.
How to Contact Us