Privacy Policy – Private Token Sale

This Privacy Policy establishes the rules for the collection, use, and protection of personal data of users (hereinafter referred to as “you” and/or the “User”) participating in the private token sale for centavracoin.xyz (hereinafter referred to as the “Site” and/or “Token Sale”), administered by the site owner (hereinafter referred to as “we” and/or the “Administration”) in accordance with the General Data Protection Regulation (GDPR) and applicable securities laws. **This policy specifically addresses the data collection and use practices associated with the private token sale.**

1. Data Collection and Use Specific to the Token Sale

1.1. We collect and process various categories of users’ personal data required for participation in the private token sale. This data collection is essential for KYC/AML compliance, token distribution, and ongoing communication related to the token sale. This data may include:

  • **Identity Verification Information:** Full name, date of birth, address, nationality, government-issued identification (e.g., passport, driver’s license), utility bill or other proof of address.
  • **Accreditation Status (if applicable):** Documentation demonstrating accredited investor status (e.g., income verification, net worth verification), if required by applicable regulations.
  • **Wallet Address:** The cryptocurrency wallet address to which tokens will be distributed.
  • **Financial Information:** Information related to the source of funds used for the token purchase (e.g., bank statement excerpts, information regarding the origin of cryptocurrency).
  • Information provided by users through online forms, including contact details (name, email address, phone number) and other identifying information related to the token sale.
  • Data on interaction with the Site, such as IP addresses, cookies, information about sessions and user preferences.
  • Communication records related to the Token Sale (e.g., email correspondence, chat logs).

1.2. The collected data is used *specifically* for the following purposes related to the private token sale:

* KYC/AML (Know Your Customer/Anti-Money Laundering) compliance and verification.
* Determining eligibility to participate in the token sale.
* Token distribution to the designated wallet address.
* Communicating updates, announcements, and other information related to the token sale.
* Compliance with applicable securities regulations.
* Responding to user inquiries and providing support related to the token sale.
* Preventing fraud and ensuring the security of the token sale.
* Analyzing token sale participation to improve future offerings (in aggregated and anonymized form where possible).

2. User Rights

2.1. We respect your right to control and manage your data. Therefore, you have the right to:

  • Request access to your personal data and request its correction if necessary.
  • Demand the deletion of your data or restrict its processing, **provided that such requests do not conflict with our legal and regulatory obligations relating to the token sale (e.g., KYC/AML compliance).**
  • Withdraw your consent to the processing of personal data, **subject to the same limitations as above.** Withdrawing consent may preclude you from participating in the token sale.

2.2. We strive to ensure transparency regarding data processing and provide the ability to control your personal data, to the extent permitted by law.

3. Data Protection

3.1. The security of your data is our priority. We take all necessary measures to ensure its protection against unauthorized access, loss, alteration, or destruction. These measures include encryption, access controls, and regular security audits. **Given the sensitive nature of data collected for the token sale, we implement enhanced security protocols.**

3.2. All personal data is treated confidentially and may be disclosed to third parties *only* for the following purposes related to the private token sale:

* KYC/AML compliance providers.
* Legal counsel.
* Auditors.
* Regulatory authorities, as required by law.
* Other service providers necessary for the operation of the token sale (e.g., token distribution services).

Data will *not* be disclosed for marketing or other unrelated purposes without your explicit consent.

4. Transfer of Data to Third Parties and Cross-border Transfer

4.1. Your personal data may be transferred to third parties only in cases provided for by law, with your explicit consent, or as necessary for the legitimate operation and compliance of the token sale.

4.2. We may carry out cross-border transfers of your data to countries where different data protection rules apply. In such cases, we guarantee an adequate level of protection for your data in accordance with legal requirements, **and will ensure that appropriate data transfer agreements (e.g., Standard Contractual Clauses) are in place where required.**

5. Use of Cookies and Analytical Tools

5.1. To improve the operation of the Site and analyze information about your preferences, we may use cookies and analytical tools. **We will clearly disclose the use of cookies and obtain consent where required by applicable law.**

6. Data Retention Periods

6.1. We store your personal data only for the period necessary for the purposes for which it was collected, or in accordance with the law. **Given the regulatory requirements associated with the token sale, data may be retained for a longer period than data collected for other purposes.** We will determine the appropriate retention period based on applicable legal and regulatory obligations.

7. Legal Responsibility

7.1. We comply with all applicable data protection laws and securities laws and provide you with the right to appeal to supervisory authorities regarding the processing of your personal data.

8. Acceptance of Changes to the Privacy Policy

8.1. We reserve the right to make changes to this Privacy Policy. All changes will be published on the Site. **We will provide prominent notice of any material changes to this Privacy Policy, particularly changes affecting the use of data collected for the token sale, and will seek your consent where required by law.**

**Important Considerations & Disclaimers (Consider adding these to the document itself):**

* **Legal Advice:** This is a sample Privacy Policy and should not be considered legal advice. You should consult with legal counsel to ensure that your Privacy Policy complies with all applicable laws and regulations.
* **Token Sale Specifics:** This policy should be tailored to the specific details of your token sale, including the jurisdictions in which it is offered, the types of data collected, and the regulatory requirements that apply.
* **GDPR Compliance:** This policy is intended to be GDPR-compliant but must be reviewed and adapted to meet the specific requirements of your organization and the token sale.
* **KYC/AML Compliance:** Ensure your KYC/AML processes are robust and compliant with all applicable regulations.
* **Securities Laws:** Comply with all applicable securities laws in the jurisdictions where you are offering the token sale. This policy may need to be modified to address specific securities law requirements.
* **Risk Disclosure:** Include a clear risk disclosure statement in your token sale documentation.
* **Data Breach Notification:** Have a data breach notification plan in place in case of a security incident.
* **Regular Review:** Review and update this Privacy Policy regularly to ensure that it remains accurate and compliant with applicable laws and regulations.
* **Contact Information:** Provide clear contact information for users to reach out with questions or concerns about the Privacy Policy.
* **Terms of Service:** Make sure this Privacy Policy is consistent with your Terms of Service for the token sale.

This revised version takes into account the specific data collection and usage practices associated with a private token sale, emphasizes compliance with KYC/AML and securities laws, and provides more detailed information about user rights, data protection, and data retention. It also includes important disclaimers that should be considered before using this as a template. Remember to always consult with legal counsel.

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