Privacy Policy
1. Definitions
a) Brokkr – Brokkr is a limited liability commercial entity incorporated under the laws of The British Virgin Islands, company no. 2069997, of Craigmuir Chambers, Road Town, Tortola, VG 1110, British Virgin Islands.
b) T&C – T&C refers to the Terms and conditions for the operation and use of products and services, that are, or may be, offered by Brokkr. The T&C outlines the requirements, definitions, circumstances and services, and the way these services are offered by Brokkr.
c) Platform – The platform refers to the website or application provided and maintained by Brokkr.
d) Service/Services – A service or services refers to one or many functionalities that are provided through the Platform.
e) Product/Products – Represents the Platform, the application, both the Platform and the application or other code deployed by Brokkr or the Brokkr DAO that is used to access the Services.
f) User/Users – User is a person who uses or benefits from the use of the Platform, regardless of whether the User has consented to the T&C.
g) Digital item – A Digital item may represent what is commonly referred to as a coin, token, crypto currency or an NFT item, which is either programing code that provides unique identifiers for digital collectibles or programming code that is used to generate identical, generic or unique, fungible or nonfungible items that can be traded for one another or used for other purposes by Users on the Platform.
h) Risk/Risks – Represents unforeseen and uncontrollable factors and events, that, with or without the knowledge or recognition of the User, determine the safety, possession, value, transferability, of the User’s Digital items, and which is an inseparable element when choosing to use the Platform.
i) Guidelines and Documentation – Can consist of various proprietary and/or nonproprietary analyses, considerations, that may or may not be presented to the User. If presented to the User, Guidelines and Documentation will be presented in either digital or paper form.
j) Strategy/Strategies – Represent the proprietary and/or nonproprietary considerations of various factors, indices and events that are used by the Platform to provide the User with Guidelines and Documentation for how Risk is assessed and managed.
k) Wallet – Represents a digital address on a DLT network to which any other user of the DLT network can deposit Digital items into, while only the user with access parameters can operate the deposited Digital items.
l) Brokkr DAO – The Brokkr DAO represents the organization that will be governed by the holders of the native Digital item of the Platform, through holder pre established governance models, at which point Brokkr will relinquish and be striped from any influence (managerial, financial and factual), partial or full, over the functionality, image and branding of the Platform
m) Personal information – Personal information represents any piece of information, data point or data set, which can be used by any party to identify the User.
2. Introduction
Brokkr or the Brokkr DAO Limited and its affiliates are committed to protecting and respecting your privacy.
This Privacy Policy, together with our Terms and conditions governs our collection, processing and use of our User’s and visitor’s Personal Information.
Please find below some basic definitions which may help you to understand this Privacy Policy:
● Personal Information (personal data): any information which identifies you personally or which may help us to identify you (e.g. your name, address, e-mail address, trades etc.).
● Data subject: an identified or identifiable person (our User).
● Data controller: a company which determines the purposes and means of personal data processing.
● Data processor: a company which processes personal data on behalf and upon instructions of the Data controller.
● Our Products: The website for the Brokkr or the Brokkr DAO Platform used for providing our services to you is used for the purposes of informing our Users regarding products and our promotional, marketing campaigns and special offers.
● Personal data processing: any operation or set of operations performed on personal data (e.g., collection, storage, use, disclosure erasure).
Other capitalized terms, not defined above, have the meanings as defined in the T&C and the applicable data protection legislation (namely, the General Data Protection Regulation 2016/679 as of April 27, 2016 and where applicable The California Consumer Privacy Act of 2018 (CCPA)).
The purpose of this Privacy Policy is to inform you of:
who Brokkr or the Brokkr DAO is and how you may contact us;
the kinds of Personal Information we may collect about you, the reasons for collecting this information, how it may be used and for how long we will keep it;
our use of information regarding IP addresses and our use of cookies;
disclosure of Personal Information to third parties;
information on international data transfer;
your ability to access, correct, update, restrict use, ask us to transfer and/or delete your Personal Information;
the extent of automated decision-making or profiling that we carry out using your Personal Information;
the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control, and
your rights to lodge a complaint.
(The Introduction represents a user-friendly elaboration of the Privacy Policy, that is not legally binding.)
3. General provisions
3.1 We may collect your Personal Information if you use Brokkr or the Brokkr DAO and link your Wallet to use the Platform or perform any operation on the Platform. This is defined as collection for the purpose of provision of service(s) to you in accordance with our T&C . Please note that if you refuse to share your Personal Information for this purpose, we will not be able to provide our services to you.
3.2 The types of Personal Information which we collect may include:
3.2.1 your name;
3.2.2 your photographic identification
3.2.3 details from your identity documents (such as driver license, passport), number of the document, date of issue and expiration, photographic identification, address etc.
3.2.4 your address;
3.2.5 your phone number;
3.2.6 your email address;
3.2.7 your IP address, Browser and Operating System information, geolocation details;
3.2.8 your banking details including account numbers and payment card data;
3.2.9 your date of birth;
3.2.10 your employment details;
3.2.11 your wallet address;
3.2.12 your operations; and
3.2.13 information on sources of your Digital items; and
3.2.14 video footage identifying you.
3.2.15 the way in which you use the Platform
3.3 We will process your Personal Information only for the purpose(s) of providing to you service(s) that you ask us to provide to you, to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s) and our legitimate interest.
3.4 Based on our legal obligations and legitimate interest we may request other documents for your identity verification and the sources of your Digital items, for purposes of money laundering and fraud prevention.
3.5 We may use your Personal Information for the following purposes:
3.5.1 to allow you to link your Wallet and perform operations with your Wallet on the Platform;
3.5.2 to enable you to complete operations on the Platform;
3.5.3 if you contact us, to reply to your queries;
3.5.4 to contact you via email or calls;
3.5.5 to ensure security of your Wallet (in whatever way it may be possible to do so);
3.5.6 to analyze use of our Platform and App;
3.5.7 as required for regulatory purposes such as Tax, prevention of Money Laundering, prevention of Fraud, adherence to Brokkr or the Brokkr DAO statistical reporting obligations etc.;
3.5.8 to provide you with information about products and promotions that may be of interest to you, from ourselves and third parties, although only if you have specifically agreed to receive such information;
3.5.9 for market research e.g. surveying our Users' needs and opinions on issues, such as our performance etc. Unless consented, your data for this purpose would be anonymized, to the extent possible.
4. Children’s Personal data
4.1 Please note that our Services are exclusively offered to individuals at least 18 years of age. We do not process any Personal Information of children under this age.
5. Cookies
5.1 Brokkr of the Brokkr DAO may use a browser feature known as a "cookie", which assigns a unique identification to your computer. Cookies are typically stored on your computer's local storage. Information collected from cookies is used by us to evaluate the effectiveness of our Platform, products, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our products are most visited and difficulties our Users may experience in accessing them. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use third party tools such as Mixpanels, Google analytics , Hotjar and other technologies, the purpose of which is to further our legitimate business interest in exploring the way our Users interact with our products, allowing us to provide our Users with a more personalized and pertinent experience when using our Products. Before using the Platform and the App, we would strongly encourage our Users to review the Privacy, Cookie and data protection policies and terms and conditions of the tools we use, the links to which are included in our Privacy policy.
5.2 Brokkr or the Brokkr DAO may use third party service provider(s), to assist us in better understanding the use of our Products. Our service provider(s) will place cookies on your local storage of your device(s) and will receive information that we select that will educate us on such things as how Users navigate through the Platform, what products are browsed, and general operations. Our service provider(s) analyze this information and provide us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our User’s interests in our Sites and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with, information that we collect about you while you are using the Platform.
5.3 You may control the cookies through the browser settings. Find out how to manage cookies on browsers:
Mozilla Firefox Microsoft Edge
6. Disclosure of Personal Information
6.1 Brokkr or the Brokkr DAO use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.
6.2 Brokkr or the Brokkr DAO may make available the Personal Information for the limited purpose indicated for and during the provision of the service that you would have requested in particular to:
6.2.1 our affiliates, agents and representatives;
6.2.2 payment service providers and financial institutions;
6.2.3 customer communications platforms;
6.2.4 our contractors providing software for identity verification purposes;
6.2.5 our contractors providing information on sanctions lists from publicly accessible sources.
6.3 Brokkr or the Brokkr DAO may also share User’s Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organization and notify you of such sharing of your information to be able to exercise any of your rights where applicable.
6.4 Brokkr or the Brokkr DAO may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law. In certain cases, we may not be able to inform you of such sharing of data due to legal restrictions.
6.5 Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for Brokkr or the Brokkr DAO, unless otherwise required or permitted by law. Such a third party, except for regulatory authorities, would be contractually bound to adhere to the same security and confidentiality policies as Brokkr or the Brokkr DAO and assume the same responsibilities as Brokkr or the Brokkr DAO.
6.6 The legitimate exercise of any of your rights with Brokkr or the Brokkr DAO will also be notified to be applied by any such third parties having been given access to your Personal Information.
6.7 Brokkr or the Brokkr DAO will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.
7. Data transfers
7.1 The third-party tool providers are situated in different locations (including countries located outside the EU) and we sometimes need to transfer your personal data to third countries to provide our services to you. We strive to ensure an adequate level of your personal data protection wherever our contractor is located. We may transfer your Personal Information only in the following cases:
7.1.1 if the country where we transfer your Personal Information to, provides the adequate level of personal data protection;
7.1.2 if we take appropriate safeguards to ensure that your rights as a data subject are protected;
7.1.3 if any derogations for specific situations apply (for instance, if such transfer is necessary for the establishment, exercise or defense of legal claims or for an important reason of public interest).
8. User’s Rights
8.1 You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at [email protected] or where possible, you can do these actions in your account profile page yourself.
8.2 Upon your written request at [email protected], we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information we have retained. There may be a minimal charge for providing you with additional copies of your Personal Information to cover administrative costs.
8.3 You may also request the erasure of Personal Information which may lead to the disconnection of the Wallet and withholding of Digital items in Strategies if any are present in the Strategies at the time of the request.
8.4 The erasure request can be sent to us at: [email protected]. Brokkr or the Brokkr DAO will process your request, unless we have a legal or regulatory obligation or overriding legitimate interest to store your Personal Information (for instance, in cases you have performed certain operations).
8.5 You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Moreover, you have the right to restrict and object to the processing of your personal data in certain circumstances.
8.6 You may also ask us to transfer your Personal Information to another controller of your choice.
8.7 To ensure the confidentiality, integrity and availability of your information to yourself, we may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights.
8.8 If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.
8.9 In the carrying out of our services we may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, operational and behavioral patterns.
8.10 We may not be able to provide you with some or all our services if you do not wish this automated processing to be carried out. If you feel that this processing might be detrimental to you, please contact us on [email protected], and our compliance officer will review your application.
8.11 Please note, if you make a request, we have one month to respond to you.
9. Security
9.1 Brokkr or the Brokkr DAO have implemented technical and organizational security measures to ensure the confidentiality, integrity and accountability of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Such measures may include:
9.1.1 pseudonymization (to the extent permitted by DLT)
9.1.2 TLS 1.2 encryption of personal data;
9.1.3 the access control (through the use of access parameters such as private keys);
9.1.4 the ability to ensure the ongoing confidentiality, integrity, availability and resilience of our processing systems and services;
9.1.5 the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
9.2 Only authorized personnel of Brokkr or the Brokkr DAO have access to your Personal Information, and these personnel are required to treat the information as confidential.
9.3 Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organizational security measure be applied through contractual arrangements, where possible.
9.4 Brokkr or the Brokkr DAO conducts testing, assessment and evaluation of our technical and organizational effectiveness measures on a regular basis. Technical and organizational security measures in place will, from time to time, be reviewed in line with legal and technical developments.
9.5 In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay through our Discord .
10. Link
10.1 There may be links in our Products to other sites and resources provided by third parties. This Privacy Policy applies only to our Products. Accessing those third-party sites or sources requires you to leave our Products.
10.2 Brokkr or the Brokkr DAO does not control those third-party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.
11. Retention of Personal Information
11.1 Your information may be held within blockchain or regular servers located within the European Union or outside of the European Union. Access to this information is provided to Brokkr or the Brokkr DAO contractors or personnel whose place of business may also be outside of the European Union but who adhere to the same principles of data security and processes as those within the European Union (please see the Section on Data transfers for more details), as applicable.
11.2 Brokkr or the Brokkr DAO will hold your Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements.
11.3 In accordance with record keeping activities for Anti-Money Laundering, Tax and Company legal obligations and considering the period during which you may bring legal claims against us under the law of the United Kingdom, we will retain Personal Information for a period of five years after our User terminates legal relationships with us for five years from the end of the tax period in which the User conducts his or her last operation.
11.4 Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.
12. Disposal
12.1 Once we do not have any obligation to provide you with a service you requested, nor an obligation to hold Personal Information for regulatory or legal purpose, we will anonymize or dispose of your Personal Information in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated with you.
12.2 Where we cannot directly remove such records, such as in archived backups, and blockchain data we will retain a log of which Personal Information should be removed if ever the backup data is restored.
13. Promotional and Marketing
13.1 Brokkr or the Brokkr DAO will ask you for your consent when connecting your Wallet or after, by providing you with the ability to check marketing preferences check boxes located when a page is accessed, to allow us to contact you or use your Personal Information for marketing purposes. We may also notify our existing Users on our own products or services similar to those we have already provided based on our legitimate interest.
13.2 You have the right to retract the consent for us to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by unchecking marketing preferences check boxes when accessing the page or in the settings of the device you are using to access the app or by contacting us at any time at [email protected].
14. Amendments to the Privacy Policy
14.1 Our Products policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Brokkr or the Brokkr DAO. If we change this Privacy Policy, we will take steps to notify all Users by a notice on Brokkr or the Brokkr DAO Platform and will post the amended Privacy Policy on the Brokkr or the Brokkr DAO app.
14.2 If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continuing our relationship with you.
14.3 This current version of the Privacy Policy has last been enacted on the 5th of September 2022.
15. Fraud, Phishing and Wallet Disclaimers
15.1 Please be advised that Brokkr or the Brokkr DAO is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and promising to help solve your issues for money. Remember - support is provided only via our Support Discord channel, or team members and moderators active on our Discord channel..
15.2 If you discovered what you believe is a fraud, phishing, or scam which impersonates Brokkr or the Brokkr DAO, please contact us by at
16. Contact us
16.1 If you have any questions, comments, or concerns regarding our Privacy Policy and/or how we process your personal data, please contact us at the email address [email protected].
16.2 You may also wish to check our Help section or our Discord FAQ section where a solution may easily be found ready for you.
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