Privacy Policy

This Privacy Policy tells you what to expect when HeroDev OÜ  (referred to as “the Company”, “we” “us” or “our”) collects personal information. The Company is committed to safeguarding the data that our website visitors and service users share with us. This privacy policy explains how the Company processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through the use of its website and platform.

For the purposes of this Policy, the Company defines the term “User”, “Visitor”, “Client” or “You” as a natural or legal person, either a visitor of the Company’s website or as the user with a trading account with the Company.

Any information stored on the Company’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. The Company implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

IMPORTANT INFORMATION

OUR SERVICES ARE NOT AVAILABLE TO CHILDREN

Our products and services are not directed to persons under the age of 18, hereinafter “Children”, “Child” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. The Company will require the user to close his or her account and will not allow the use of our products and services. If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us at info@hero-dev.com and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

CONTROLLER

HeroDev OÜ is the controller and responsible for your personal data in accordance with the applicable data protection laws, including, without limitation, the Estonian Data Protection Act and the EU General Data Protection Regulation (GDPR).

This website is owned and operated by HeroDev OU, a legal entity incorporated and established under the Laws of Estonia under Registration No: 16097562 having its registered address Laki tn 14a Kristiine linnaosa, Tallinn Harju maakond 10621, Estonia.

We have appointed a Data Protection Officer (hereinafter referred to as “the DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: HeroDev OÜ  

Email address: info@hero-dev.com

Postal address: Laki tn 14a Kristiine linnaosa, Tallinn Harju maakond 10621, Estonia Telephone Number: +372 668 0328

The supervisory authority responsible for us is:

Name of the supervisory authority: Estonian Data Protection Inspectorate 

Address: 39 Tatari St., 10134 Tallinn

Email: info@aki.ee

Tel: +372 627 4135

COOKIES

When you use our products and services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used when engaging with us. We use Cookies to (i) help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with AML obligations or any other applicable Legislation.

Please refer to our Cookies Policy for further information.

INFORMATION WE MAY COLLECT ABOUT YOU

In order to provide you with our services we may collect from you the following information:

  • Full Name
  • Date of birth
  • Country of birth
  • Gender
  • Citizenship
  • Email address
  • Phone number
  • Identity document information
  • Residential address
  • Information on whether you hold a prominent public function (PEP);
  • Full legal and trade name (for legal entity client)
  • Company number (for legal entity client)
  • Legal status (for legal entity client)
  • Legal form; (for legal clients)
  • Legal address (for legal entity client)
  • Controlling persons and their legal capacity (for legal entity client)
  • Authorised representatives (other than controlling persons) and their legal capacity (for legal entity client)
  • Shareholders and ultimate beneficial owners (for legal entity client)
  • Purpose of account (for legal entity client)
  • Expected activity on the platform (for legal entity client)
  • Source of entity’s funds
  • Other information which may be required for conducting identification and verification of the legal entity.
  • Verification information, which includes information necessary to verify your identity such as a passport, driver’s licence or Government-issued identity card);
  • Bank account information, credit card details, including details about your source of funds;
  • Trading account balances, trading activity, your inquiries and our responses;
  • Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations, such as under the European Union’s AML Directives and/or Estonian Money Laundering and Terrorist Financing Act, as amended from time to time and/or any other applicable Legislation.

Information we collect about you automatically.

  • Location Information: Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
  • Log Information – Information that is generated by your use of BLK TRADE Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

Information we receive about you from other sources.

We obtain information about you in a number of ways through your use of our services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of on-going support service communications. We also receive information about you from third parties such as your payment providers and through publicly available sources. For example:

  • The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
  • Your business partners may provide us with your name and address, as well as financial information;
  • Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website;
  • Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us.

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We will process your personal information on the following bases and for the following purposes:

  • To perform our contractual obligations

We process personal data in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients. In addition, the processing of personal data takes place to enable the completion of our client on-boarding process. In view of the above, we must verify your identity in order to accept you as our client and we will use your personal data in order to effectively manage your trading account with us. This may include third parties carrying out credit or identity checks on our behalf. The use of your personal information is necessary for us to know who you are, as we have a legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations.

  • We have a legal obligation to do so

There are a number of legal obligations imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g. anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. There are also various supervisory authorities whose laws and regulations apply to us. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls. These obligations apply at various times, including client on-boarding, payments and systemic checks for risk management.

  • To provide you information about our services and products

Once you successfully open an account with us, or subscribe to information, we must use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to try to ensure that we are providing the best products and services so we may periodically review your needs based on our assessment of your personal information to ensure that you are getting the benefit of the best possible products and services from us.

LEGAL OBLIGATION TO DISCLOSE PERSONAL INFORMATION

  • Disclosure to third parties

In processing your transactions, we may share some of your Personal Information with third party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide to you the Company’s services or as required by law. By using our services and accepting our Terms of Service, you consent to the disclosure of your Personal Information as described in this Privacy Policy.

  • Disclosure to prevent damage and disclosure to legal authorities.

We will reveal user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to the Company or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required and when the competent authorities have required to present them with such Personal Information.

  • Data analysis

Our website pages and emails may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services.

If your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. If your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.

INTERNATIONAL TRANSFERS

If you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA, to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. If such a transfer is necessary, we will make sure that the country in which the recipient processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with the respective processor that ensures such protection. Such safeguards will ensure that your personal data stays safe and secure.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us at info@hero-dev.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

PRIVACY WHEN USING DIGITAL ASSETS AND BLOCKCHAINS

Your funding of bitcoin, XRP, etherium, and other Digital Assets, may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by BLK Trade or its affiliates, we are not able to erase, modify, or alter personal data from such networks.

DISCLOSURE OF YOUR PERSONAL INFORMATION

The Company will not disclose any of its clients’ confidential information to a third party, except:

  1. to the extent that it is required to do so pursuant to any applicable laws, rules or regulations;
  2. if there is a duty to disclose;
  3. if our legitimate business interests require disclosure;
  4. in line with our Terms of Service;
  5. at your request or with your consent or to those described in this Privacy Notice.

The Company will endeavour to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notify the third party regarding the confidential nature of any such information.

SECURITY OF PERSONAL INFORMATION

We use a variety of security measures to ensure the confidentiality, integrity, availability and privacy of your Personal Information and to protect your Personal Information from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, among others:

  • Password protected directories and databases.
  • Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.
  • Vulnerability Scanning to actively protect our servers from hackers and other vulnerabilities.
  • Regular penetration testing.
  • Secure coding principles.
  • Encryption of sensitive data during transfer and at rest.
  • 2-factor authentication.
  • Logging of activities performed in the platform.
  • Access controls and
  • other measures to mitigate risks identified during the risk assessment process.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized personnel of the Company are permitted access to your Personal Information, and this personnel is required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine -readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us to the following email: info@hero-dev.com.

In your email, please explain in detail your request.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

INFORMATION, COMPLAINTS AND CONTACT

If you have any further questions regarding the data the Company collects, or how we use it, then please feel free to contact us by email at: info@hero-dev.com.

You have a right to lodge a complaint with supervisory authority, to enforce your rights, as specified above. You can find out how to do this at the Estonian Data Protection Inspectorate (AKI) http://www.aki.ee/en/ inspectorate or European Data Protection Supervisor https://edps.europa.eu/.

 FEES

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

AMENDMENTS TO THE POLICY

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of the Company. When we make changes to this Privacy Policy, we will notify all users on our website, and make the amended Privacy Policy available on our website. We encourage you to review this Privacy Policy from time to time to stay informed. For significant material changes in the Policy or, where required by the applicable Laws, we may seek your consent.