Privacy & Policy

This Privacy Policy governs how TLaunchpad collects, uses, maintains, and discloses information collected from users (each, "Users") of the *website address and/or mobile apps ("Site" or “Platform”). This Privacy Policy applies to the Site and all products and services offered by TLaunchpad.

TLaunchpad (“TLaunchpad,” “We” or “Us”) is committed to protecting Users’ privacy. This Privacy Policy document is a statement that states how We collect, use, maintain, and disclose Users’ personal data. This Privacy Policy document also states what personal data and information We collect that could be used to identify our Users (“Personal Data”) and why We collect it. We reserve the right to change any of our policies and practices at any time without prior notification to the Users but this page will always show the latest version of our Privacy Policy.

1. Personal Data We Collect and How We Use It

   • Personal Data We Collect from Users

     • Identification information that could be used to identify the Users, such as but not limited to name, address, email address, wallet address, and telephone number.
     • Transaction history, such as but not limited to order, buy, and sell activities.
     • Correspondence that is provided when Users interact with TLaunchpad or accessing the Platform, such as but not limited to when they contact the TLaunchpad Help Center.
     • Media that Users upload to the Platform for various purposes, such as but not limited to uploading pictures onto the Platform.

   • Personal Data We Collect from Platform Partners

     In the Platform, We partner with third parties (“Partner”) for various purposes, including but not limited to products and services, and other services. For such partnership purposes, the Partner may be required to collect some Personal Data to continue the services, such as but not limited to:

     • Identification information that our partners might require from our users in order to proceed with activities within our platform and ecosystem
     • Claiming activity that occurs when Users use their NFTs to claim products and/or services provided by our partners

   • Personal Data of Other Individuals

     In some situations, the Users may provide Personal Data of other individuals (such as spouse, family members or friends) to Us. For example, the Users may add them as emergency contacts or when the Users use the in-app chat. If the Users provide Us with their Personal Data, the Users represent and warrant that the Users have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Policy.

   • Personal Data of Minors

     As a parent or legal guardian, please do not allow minors under the Users’ care to submit Personal Data to TLaunchpad. In the event that such Personal Data of a minor is disclosed to Us, the Users hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Privacy Policy and take responsibility theis actions.

   • How We Use Users’ Personal Data

     We will use the Users’ Personal Data exclusively for the purpose for which you have acknowledged it. Unless expressly stated otherwise, We will not pass on the Users’ Personal Data to third parties other than the Partner and other than for the purposes We have mentioned in this Privacy Policy. The Users’ Personal Data may be used by the authorities, if legally required.

     If the Users’ ask Us a question, We may need to involve another third party to answer this question. The data that we exchange with these third parties will only be used by them to answer the Users’ questions.

     When the Users transact in the Platform, We will be able to capture the Users’ pattern, such as but not limited to the Users’ preferences. From that We will save the Users’ preferences for as long as the Users are registered in TLaunchpad.

     Research and Development: We may use the Personal Data We collect for testing, research, analysis and product development. This allows Us to understand and analyse the Users needs and preferences, protect the Users Personal Data, improve and enhance the safety and security of the Platform and Services, develop new features, products and services, and other facilities.

2. When We Collect Personal Data

   • Provided by The Users

     We collect the Users’ Personal Data when the Users voluntarily provide it to Us. For example, the Users may provide their Personal Data to Us when:

     1. Completing a user profile or registration forms (such as name, contact information and other identification information where needed);
     2. Providing information to assess eligibility to use the Services as a buyer or project owner (such as project information and background check results (as legally permissible));
     3. Interacting with TLaunchpad social media pages (such as social media account ID, profile photo, and any other publicly available data);
     4. Participating in contests or events organised by Us (such as the pictures, audio files, or videos the Users may submit, which may include images of them);
     5. Verifying the Users’ identity through various means (such as social media logins, submission of selfie images or wallet information);
     6. Filling up demographic information in surveys (such as age, gender, and other information the Users’ may volunteer such as marital status, occupation, and income information); and
     7. Agreeing to use the Services and features within the Platform.

   • Provided Through The Operation of The Platform

     Personal Data may be collected through the normal operation of the Platform and Services. Some examples but not limited to are the following:

     1. location (to detect where the transaction happened);
     2. feedback, ratings, and compliments;
     3. transaction information (such as payment method and amount);
     4. information about how the Users interacted with the Platform or Services (such as features used and content viewed);
     5. device information (such as hardware model and serial number, IP address, file names and versions, and advertising identifiers or any information that may provide indication of device or app modification);
     6. Personal Data the Users enter in messages when use the Platform in-app communication features; and
     7. Personal Data that may be captured through the Users’ interaction with Us, employees, and/or agents (such as image or voice or both, and its related metadata).

   • Provided by Other Sources

     When We collect Personal Data, including but not limited to name, contact information, and other identification information where needed from other sources, We make sure that data is transferred to Us in accordance with applicable laws. Such sources include:

     1. Third party programs such as referral;
     2. TLaunchpad business partners;
     3. Insurance and financial providers;
     4. Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
     5. Publicly available sources of data;
     6. Governmental sources of data;
     7. When the Users add another individual as an emergency contact;
     8. When the Users use in-app chat; and
     9. Marketing services providers or partners.

3. Why We Collect Personal Data

   We collect Personal Data for several reasons but not limited to the following:

   • To check the eligibility and perform the KYC process of the Users;
   • To provide Services to the Users;
   • To update you on technical progress and maintain the Users’ Account;
   • To run marketing and promotional activities in the Platform and send the Users information regarding TLaunchpad marketing and promotional activities, and other notifications to the Users through email and any other communication platform;
   • To run the operations and Services of TLaunchpad; and
   • To improve the operations, Services, and Platform of TLaunchpad;
   • In rare cases, specified in the Section 4, provision of some of the Users Personal Data to the original data controller;
   • To gain insights on the operations, Services, and Platform of TLaunchpad for improvement purposes. This involves contacting the Users and sending them questionnaires before and after accessing TLaunchpad Services and Platform;
   • To create aggregate data about Users through demographic profiling, statistical analysis of the database to provide to potential and existing TLaunchpad’s Users, and to allow for more efficient operation of TLaunchpad’s businesses;
   • To manage the legal and statutory obligations and to establish, exercise or defend any legal claims; and
   • To manage job applications.

4. Personal Data Disclosure

   We do not sell, trade nor rent Users’ Personal Data to anyone. We may share generic aggregated demographic information that is not related to any personal identifying information about visitors and Users with TLaunchpad’s business partners, trusted affiliates, and advertisers. As we take seriously the Users’ privacy and the confidentiality of Users’ Personal Data, We will not share the Users’ Personal Data with any third parties except for the following purposes:

   • Service providers that engage with Us in providing their services related to business and commercial purposes. In an event where this information disclosure happens, the sharing of Users’ Personal Data is strictly limited to the necessities required in order to have their services provided to TLaunchpad. All Personal Data will still be kept by Us without allowing the other parties to have control over the Users’ Personal Data. We also prohibit any other parties from disclosing the Users’ Personal Data for any other purposes.
   • Law enforcement in an event where We are obliged to disclose the Users’ Personal Data to comply with laws and regulation.

   We only share Personal Data if necessary. TLaunchpad cooperation with third-party partners is strictly limited to purposes within the operations of the Site. If TLaunchpad as a data processor uses third parties to process the Users’ Personal Data, these third parties must always act as sub processors for TLaunchpad and will sign specific agreements with TLaunchpad. They will be bound legally to the agreement, TLaunchpad data privacy and security requirements, and applicable laws and regulations. The Partners will only process the Personal Data for the specific purposes outlined in the agreement between the third parties and TLaunchpad.

   Disclosure to outside the European Union: We do not transfer the Users’ Personal Data to parties located in a country outside of the European Economic Area (EEA), unless we have ensured an adequate data protection regime is in compliance with TLaunchpad data privacy policies.

5. How We Protect Personal Data

   We apply appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Data, usernames, passwords, order activities, and data information stored on the Site.

   We do not store the Users’ Personal Data for longer than is required by TLaunchpad internal policies and the applicable laws . For example, if the Users’ close down their Account following the provisions set out in the Terms of Use, We will delete the Users’ Personal Data after a period of time allowed by TLaunchpad internal policies which will be subject to the applicable law. We will process and protect the Users’ Personal Data with due care.

6. The Users’ Rights

   We acknowledge that the Users have the right to access (right to request), change (right to rectification), and erase (right to be forgotten) the Users’ Personal Data that is under TLaunchpad’s control by contacting TLaunchpad Help Support (or fill this form and send it to (*email address), TLaunchpad team will help to liaise with you on the matter.

   A request to access, change, or erase the Users’ Personal Data is free of charge. If the Users’ request is manifestly unfounded or excessive, TLaunchpad can decide not to process the request.

   The Users are also entitled to the right to revoke Users’ consent to share the Users’ Personal Data. Please note that by revoking the consent, the Users need to stop accessing and using the Platform and the Services.

   Exception: We cannot remove the Users’ Personal Data if We need them to carry out an agreement We have with the Users, or if We need to store the Users’ Personal Data for another reason. For those reasons, We will take care of the Users’ Personal Data based on the separate agreement.

7. Users’ Representations and Warranties

   The Users acknowledge that We may process Personal Data in relation to you. Accordingly, you represent and warrant that:

   • The Users are eligible to share any of their Personal Data to Us and the disclosure was or will be made in accordance with all applicable data protection and data privacy laws, and those data are accurate, up to date and relevant when disclosed;
   • The Users will provide their updated Personal Data to Us and maintain the update from time to time;
   • Whenever the Users provide any Personal Data other than their own Personal Data, the Users already obtain prior approval from the owner of such Personal Data before disclosing it to Us;
   • Before providing any such Personal Data to Us, the Users have read and understood this Privacy Policy
   • The Users acknowledge that this Privacy Policy is an integral part to the Terms of Use, so that all terminology that begins with capital letters and is not defined in this Privacy Policy has the same definition as stated in the Terms of Use; and
   • We will update the Privacy Policy from time to time and the Users agree to promptly read the updated version of the Privacy Policy and provide a copy to any third parties whose Personal Data has been provided by the Users to Us.

8. Amendment

   We reserve the right to amend this Privacy Policy within the framework of the applicable laws and regulations relating to privacy and data protection, more specifically the General Data Protection Regulation (GDPR). We will inform the Users about any amendments in our Privacy Policy by updating this page or any other communication method.

9. Use of Cookies

   In connection with the use of the Platform, TLaunchpad and third parties with whom We collaborate may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers, and similar technologies ("Cookies"). Users may be given the option to disable the use of mobile identifiers (such as Apple's IDFA) depending on the type of phone and operating software they are using. Cookies may contain unique identifiers and may reside on your computer or mobile device, in emails We send to Users, and on the Platform, among other places. Cookies may transmit Personal Data about Users and their use of the Service, such as browser type, search preferences, IP address, data relating to advertisements displayed to Users or clicked on by Users, and the date and time of use. Cookies can be persistent or only stored for the duration of a single session.

   TLaunchpad may permit third parties to use Cookies on the Platform to collect the same type of Personal Data that TLaunchpad collects for its own purposes. Third parties may be able to link the Personal Data collected by them to other Personal Data they have about the Users from other sources. We may not have access to or control over the Cookies they use.

   Furthermore, We may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), in order to facilitate the display of targeted advertising.

   Disabling Cookie Collection on the Platform: Users may deactivate Cookies by adjusting their internet browser settings to disable, block, or deactivate cookies, as well as by deleting their browsing history and clearing their internet browser's cache.

10. Users’ Acceptance of This Privacy Policy

    By using this Site, you signify your acceptance of the terms of this Privacy Policy. If you do not agree to this Privacy Policy, please stop accessing the TLaunchpad Site. Continuous use of the Site after the announcement of this policy change will be treated as your acceptance of such changes.

    If the Users do not agree with the way We process the Users’ Personal Data, the Users may contact TLaunchpad Help Centre.

    For purposes such as detection and prevention of fraud, we may also collect the Users’ Personal Data without consent, by relying on legitimate interests or other exemptions provided by the applicable data privacy laws.

11. The Data Protection Officer

    If you have any questions about or not agree with this Privacy Policy, the practices of this Site or the Users’ activities within this Site, please contact TLaunchpad Help Center or you may contact our dedicated Data Protection Officer (DPO) at:

    (*name)

    (*address)

    Telephone: (*)

    (*) works as a senior adviser for the Privacy Company in The Hague and will supervise the application of and compliance with the GDPR at TLaunchpad.