Privacy Statement

1. Introduction and objective

As a data controller, BlockTech B.V. (hereinafter: “BlockTech”) collects and processes personal data as part of its business activities in compliance  with the applicable laws and regulations, such as the General Data Protection Regulation (GDPR). BlockTech respects the privacy of its employees and contractors, business partners and prospects, (BlockTech) event participants and website visitors. Therefore, we strive to adequately protect the personal data we collect. This Privacy Statement  (hereinafter: “Statement”) outlines how BlockTech collects, controls, processes, and transmits personal data. The Statement  covers the following topics:

• Personal data that BlockTech collects;
• How BlockTech collects personal data;
• Purpose and lawfulness of processing;
• Sharing personal data with third parties;
• Transferring personal data to third countries;
• Privacy rights of data subjects;
• Retention periods of personal data;
• Handling of questions and/or complaints; and
• Review and update of this Statement .

2. Personal data that BlockTech collects

BlockTech collects and processes personal data as part of its daily business operations in compliance with applicable laws and regulations. This includes, but is not limited to:

• Personal data of potential candidates (e.g., name, nationality, date of birth);
• Identification details (e.g., passport screenshot, social security number);
• Pre-employment screening information (e.g., statement of conduct);
• Financial and tax information of staff (e.g., bank account details);
• Counterparty information (e.g., company details, due diligence records); and
• Information collected from cookies.

3. How BlockTech collects personal data

BlockTech primarily collects and processes personal data directly from individuals. However, BlockTech may also use personal data collected and processed by third parties, such as:

• Publicly available sources (e.g., newspapers, internet);
• Pre-employment screening agencies;
• Regulatory authorities; or
• Any other party that has collected and processed personal data of the relevant individual.

4. Purpose and lawfulness of processing data

BlockTech processes personal data for various lawful business and regulatory purposes, including but not limited to:

• Provided consent by the relevant individual: Consent may be withdrawn at any time;
• Compliance with applicable laws and regulations: BlockTech collects and processes personal data to fulfill legal obligations (e.g., anti-money laundering regulations) and regulatory requests;
• Performance of contractual obligations: When entering agreements with business partners or counterparties or employees, BlockTech may collect and process personal data (e.g., contact details of the authorized signatory);
• Legitimate interests: Necessary for performing business activities effectively;
• Establishing, exercising, and/or defending legal claims.

Special categories of personal data and/or criminal records will only be collected and processed by BlockTech if:

• The relevant individual provides explicit and specific consent;
• Required by applicable law and regulations; and 

In accordance with the safeguards prescribed by GDPR.

BlockTech emphasizes the lawful processing of personal data during the recruitment process. In addition to the lawful grounds mentioned above, the following purposes apply:

• Sustaining the application process: Personal data collected may include:
  
  • Contact information (name, email, phone number, address)
  • Copy of passport
  • CV, cover letter
  • Educational details (institution, degree, discipline, grades)
  • Assessment results (if applicable)
  • Compensation, job characteristics, start date.
• Personnel administration: Personal data collected may include:
  
  • Name, email, phone number, address
  • Date of birth, gender (as required by law)
  • Employment contract type, payment structure
  • Nationality (as required by law), relevant permits (if applicable).
• Employee relations and talent management: Personal data collected may include:
  
  • Full name, employee ID, start date, location, department
  • Full-time or part-time status, gender (with consent if required)
  • Performance ratings, licenses, or certifications.
• Regulatory obligations: Personal data collected may include:
  
  • Tax information, social security information, and other legally required information.
• Policy and procedure enforcement: Personal investments and compliance.

Special categories of personal data may be collected during pre-employment screening.

5. Sharing personal data with third parties

BlockTech limits the disclosure of personal data to third parties to the minimum necessary. However, in certain situations, BlockTech may be required to provide personal data to third parties or other BlockTech entities. To process this data adequately, BlockTech may use third-party processors. Reasons for sharing personal data include:

• Daily operations between different BlockTech entities globally;
• Fulfilling daily operations with trading venues or counterparties;
• Complying with legal obligations pertaining to financial reporting, auditing or regulatory oversight functions;
• Responding to regulatory authorities' requests; and/or
• Conducting recruitment processes, such as pre-employment screenings.

6. Transferring personal data to third countries

BlockTech may transmit personal data collected and/or processed inside the EEA to entities outside the EEA, such as those in Singapore. Additionally, BlockTech entities outside the EEA may process this personal data for the purposes mentioned in this Statement. When transferring or processing personal data in third countries, BlockTech shall protect this data adequately and in accordance with applicable data protection laws and regulations.

7. Privacy rights of data subjects

Relevant individuals may have certain privacy rights, including:

• The right to withdraw consent at any time;
• The right to be informed about the collection of personal data;
• The right to access the retained personal data;
• The right to rectify incorrect personal data;
• The right to be forgotten (request the erasure of retained personal data);
• The right to data portability;
• The right to object; and/or
• The right to restrict the processing of personal data.

To exercise your privacy rights, please send an email to legal[at]block-tech[dot]io, with the subject 'Exercising Privacy Rights'. BlockTech may request proof of identity and/or additional information to verify your identity. BlockTech will respond to your inquiry without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests

Additionally, in certain situations, BlockTech is obliged - pursuant to contractual or legal obligations - to process and disclose personal data of relevant individuals to third parties. In such cases, you may be required to provide the relevant personal data. Refusal to provide this data may result in consequences, such as termination of the contract and/or not entering into an agreement.

8. Retention periods of personal data

At BlockTech, personal data is retained in accordance with (i) all applicable laws and regulations, such as GDPR, and (ii) BlockTech's Data Record and Retention Policy. This means that personal data will not be retained longer than necessary to achieve the purpose for which it was collected as set forth in this Statement. Once the personal data is no longer required for the performance or enforcement of our contractual or legal/regulatory obligations, we will proceed to remove it. However, please be aware that information relating to personal data may persist in copies made for backup and business continuity purposes for longer, in which case BlockTech will strive to (pseudo)anonymise it such that these backups will not be accessible as individually identifiable data. BlockTech may retain your personal data for additional time if it is still necessary to: a) establish, exercise and defend a legal claim; b) fulfil statutory obligations to which BlockTech is subject to; and c) deal with and resolve requests and complaints. 

9. Handling of questions and/or complaints

If you have any questions or complaints regarding this Statement, the practices of this website, or any other privacy-related issues at BlockTech, please contact us via email at  legal[at]block-tech[dot]io for specific queries and at info[at]block-tech[dot]io or by phone at +31(0)202090230 for general queries.

It is also possible to file a complaint externally with the Dutch Data Protection Authority via www.autoriteitspersoonsgegevens.nl.

10. Review and update of this Statement

BlockTech periodically reviews and updates this Statement as needed. The most recent version can be found on our website www.block-tech.io.