Privacy Policy

1. Introduction

1.1 Purpose of This Privacy Policy

This Privacy Policy explains how TOKELYTICS LTD ("Tokelytics," "we," "us," or "our") collects, uses, discloses, and otherwise processes the personal information of individuals ("you" or "user") in connection with your use of our website, platform, and all other online services that link to or reference this Privacy Policy (collectively, the "Services").

1.2 Legal Entity

TOKELYTICS LTD is a company registered in England and Wales with company number 14877327, having its registered office in 167-169 Floor 5, Great Portland Street, London, England, W1W 5PF. We are committed to complying with applicable data protection laws and ensuring that your personal data is handled responsibly and in accordance with this Privacy Policy.

1.3 Acceptance

By using our Services, you confirm you have read and understood this Privacy Policy. If you do not agree with any part of this Privacy Policy, please discontinue use of the Services immediately.

2. Information We Collect

We collect or receive information in different ways. The types of personal data we may collect include:

2.1 Account Registration Information

• Contact Information: Such as your name, email address, and phone number if you provide these to create an account or sign up for a newsletter.
• Login Credentials: Such as username and password you create for access to our Services.

2.2 Transactional Data

• Payment Information: If you purchase a Tokelytics report or upgrade to a paid subscription plan, we (or our third-party payment processors such as Stripe or Coinbase Commerce) collect payment details, including billing address, card information, or cryptocurrency wallet details.

2.3 Property and Financial Data (Asset Operators)

• Property Information: If you are an asset operator uploading details for a Tokelytics report, we may collect information related to the property's valuation, ownership structure, location, historical performance, mortgage or debt data, or any other data you submit via our intake form.
• On-Chain Data: Where relevant, we process on-chain addresses and transaction details to present aggregated real estate analytics. This may include blockchain addresses, transaction IDs, or other publicly available on-chain data.

2.4 Usage Data

• Device & Log Information: When you visit our site or use our Services, we automatically collect technical information such as IP address, browser type, operating system, device identifiers, referring URLs, pages visited, and timestamps.
• Cookies & Similar Technologies: We use cookies, web beacons, and similar technologies to collect information about your interactions with our Services. This may include pages visited, links clicked, and other usage metrics. (See "Cookies and Tracking" in Section 9.)

2.5 Communications

• Customer Support & Inquiries: When you contact us or sign up for information, we collect your name, email, and any additional details you provide in your message. We store these communications to address your inquiries or improve our Services.
• Marketing Communications: If you opt in, we may collect information related to your marketing preferences and how you interact with marketing emails or other promotional content.

2.6 Other Information You Choose to Provide

You may choose to voluntarily provide other data about yourself or your property that is not specifically requested. Such information will be treated in accordance with this Privacy Policy.

3. How We Use Your Information

We use the personal data we collect for the following purposes:

3.1 Provision of Services

• To operate, maintain, and provide our Services, including facilitating account creation, portfolio tracking, and generating Tokelytics reports.

3.2 Payment Processing

• To collect fees for pro subscriptions or Tokelytics reports, process transactions via third-party processors, and maintain transaction records.

3.3 Analytics and Aggregation

• To analyze usage patterns, conduct market research, and improve the performance of our Services.
• To provide aggregated on-chain real estate data insights and analytics to both Asset Operators and individual users.

3.4 User Communications

• To respond to inquiries, provide customer support, and send service-related notifications (e.g., property updates, new marketplace listings, new Tokelytics reports).
• To send marketing or promotional communications if you have opted in, with the option to unsubscribe at any time.

3.5 Legal and Compliance

• To enforce our Terms of Service and other policies, comply with applicable laws and regulations, protect our rights, and respond to lawful requests by public authorities.

3.6 Other Legitimate Interests

Where necessary, we may process your data for other legitimate business interests, such as internal administrative purposes, detecting security incidents, protecting against fraudulent or illegal activity, and maintaining the safety of our Services.

4. Legal Bases for Processing (GDPR and UK GDPR)

If you are located in the UK, EEA, or Switzerland, Tokelytics will only process your personal data when we have a lawful basis for doing so, including:

• Consent: Where you have given consent (e.g., for marketing communications).
• Contract: Where processing is necessary for the performance of a contract with you, such as providing the Services or processing your payments.
• Legal Obligation: Where processing is necessary to comply with a legal or regulatory obligation.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving our Services, provided that your rights and freedoms do not override these interests.

5. How We Share Your Information

Tokelytics does not sell your personal data. However, we may share or disclose information in the following circumstances:

5.1 Service Providers

We share data with trusted third parties that help us operate or maintain our Services, such as:

• Payment Processors (e.g., Stripe, Coinbase Commerce) for transaction handling.
• Hosting Providers or Analytics Platforms assisting us in delivering the Services or analyzing performance.
• Email and Marketing Tools for communication with you.

5.2 Business Transfers

If Tokelytics is involved in a merger, acquisition, financing, reorganization, or sale of some or all of its assets, information may be transferred as part of that deal.

5.3 Compliance with Law

We may disclose personal data to courts, law enforcement authorities, or governmental agencies if we believe disclosure is required by applicable law, regulation, legal process, or an enforceable governmental request.

5.4 With Your Consent

We may share your personal data with other parties when you expressly consent to such disclosure.

6. International Data Transfers

Tokelytics is headquartered in England and Wales. Depending on your location and the location of our service providers, your personal data may be transferred to and processed in countries outside of your country of residence, including countries that may have less protective data protection laws. In such cases, we will take steps to ensure your personal data receives an adequate level of protection, such as entering into Standard Contractual Clauses or relying on comparable transfer mechanisms.

7. Data Retention

We store your personal data only as long as necessary for the purposes described in this Privacy Policy, including:

• Account-Related Information: Retained as long as your account is active or as needed to provide you with Services.
• Transaction Data: Retained to comply with legal, tax, and accounting obligations, and for record-keeping purposes.
• Marketing Data: Retained until you opt out or withdraw consent.
• Other Data: As otherwise required by law or where we have a legitimate interest in retaining it for longer, provided that such interests are not overridden by your privacy rights.

8. Your Rights and Choices

8.1 Access, Correction, and Deletion

Subject to certain legal exceptions, you may have the right to:

• Request access to the personal data we hold about you.
• Correct or update your personal data if it is inaccurate or incomplete.
• Delete your personal data ("right to be forgotten").

8.2 Data Portability

Where applicable (e.g., under UK GDPR or GDPR), you may have the right to request a copy of your personal data in a structured, machine-readable format.

8.3 Objection to Processing

You may object to certain processing of your personal data, such as direct marketing.

8.4 Withdrawal of Consent

If you have provided consent for specific processing, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

8.5 Exercising Your Rights

To exercise any of these rights, please contact us at support@tokelytics.com. We will respond in accordance with applicable data protection laws.

9. Cookies and Tracking Technologies

9.1 Cookies

We use cookies and similar technologies to collect information about how you use our Services. This helps us to:

• Keep you logged in,
• Remember your preferences,
• Analyze site performance, and
• Provide relevant content and marketing.

9.2 Managing Cookies

Most browsers allow you to control cookies through their settings. If you choose to disable cookies, some features of our Services may not function properly.

10. Security

We maintain appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. However, no online service can be guaranteed 100% secure. You are responsible for safeguarding your account credentials.

11. Third-Party Links

Our Services may contain links to third-party websites or applications. We do not control these external sites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our Services are not intended for children under the age of 16. We do not knowingly collect or solicit personal information from children under 16. If you believe we have inadvertently collected such information, please contact us so we can promptly delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated policy and revise the "Last Updated" date. Where required by applicable law, we will also seek your consent to significant changes.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

15. Additional Provisions

Dispute Resolution

Any disputes arising from or related to this Privacy Policy or our handling of your personal data will be subject to the governing law of England and Wales and resolved in accordance with our Terms of Service.

Disclaimer

This Privacy Policy has been prepared by Tokelytics for informational purposes. It does not constitute legal advice, and should not be relied upon as such. You should consult qualified legal counsel to ensure compliance with all applicable data protection and privacy laws.