PRIVACY POLICY

Posting Date: 9/6/2018

Effective Date: 9/6/2018

Digital Asset Holdings, Inc. Privacy Policy

Digital Asset Holdings, Inc. is committed to respecting the privacy and security of your personal information. This Privacy Policy describes the information collected on our website (https://ktctoken.io/) (the “Site”). This Privacy Policy applies only to the Site. By using the Site or by providing your information to us, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy, the Terms and Conditions (), and any written agreement(s) executed and in effect in connection with any of our products or services.

1. What Information is Collected by Digital Asset Holdings, Inc. or its Service Providers and When The information we receive and how we use it depends on what you do when visiting the Site. The Site and related services may require registration for access. As part of registration and related services, we ask you to provide us certain information about you. You may provide us and our service providers personal information using the Site in a number of ways, for example by entering that information into data fields on the Site (e.g., by creating an account) or in communications with us using the contact information at the end of this Privacy Policy or in the Terms and Conditions (). Personal information includes data that specifically identifies you, such as your name, email address, mailing address, telephone number, and payment information. To invest in a token offering, you will be asked to provide information such as your name, date of birth, address or principal place of business, identification number (e.g., Social Security Number, Tax Identification Number, or Passport), government-issued documents, a valid public key to a digital wallet, and other information required under the Know Your Customer (KYC) and Anti-Money Laundering (AML) laws, as well as the applicable laws of the respective jurisdiction. Investors in the United States may be required to provide documents relating to their income or net assets, such as Internal Revenue Service (IRS) forms, bank statements, brokerage statements, tax assessments, reports from national consumer reporting agencies, and certain written representations and confirmations. Public information is that information that you make publicly available through your account or by posting or otherwise communicating via the Site.

We may receive personal information from other sources. For example, if you connect your social media account(s) to your account, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We shall have no responsibility for the data collection and use practices of those social media sites. If you use the Site to make a payment, we or our service providers may collect information about the transaction. This includes the date of the transaction, payment information, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing and contact details. Digital Asset Holdings, Inc. and its service providers also collect certain non-personal information, data that does not identify you as an individual person. This information tells us about how people use the Site so that we can analyze its effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including “cookies” and analysis applications, as discussed below.

(a) Server Information

Like every website, the Digital Asset Holdings, Inc. servers automatically and temporarily store the following information in the server log files. This information is provided by your browser, unless you have deactivated the function.

  • IP address of the enquiring computer
  • File query by the client
  • The http response code
  • The Internet page from which you visited us (referrer URL)
  • The time of the server query
  • The browser type and version
  • The operating system used on the enquiring computer

The server log files are not analyzed with respect to individuals. At no time can this data be attributed to specific individuals. [Please confirm] All interactions with our servers through the internet are encrypted via SSL.

(b) Site Visit Tracking Technologies

As is standard practice on many websites, the Site may use “cookies” and other technologies to help Digital Asset Holdings, Inc. understand which parts of the Site are the most popular and the preferences of the Digital Asset Holdings, Inc. users. Digital Asset Holdings, Inc. may also use cookies and other technologies to study traffic patterns on the Site, to improve its functionality and usability as well as to improve the effectiveness of our communications with users. Digital Asset Holdings, Inc. may also use cookies to customize your experience and provide greater convenience to you during your interactions with the Site.

A cookie is a unique alphanumeric identifier that websites use to help identify the number of unique visitors to a website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus and thus pose no threat to you. Servers and sites other than the one placing the cookie on your hard drive cannot read the cookie, and no personal information can be gathered by other servers from the cookie. If you prefer not to enable cookies or to disable them, you may do so through your web browser’s security settings. Please note that certain features of the Site may not be available once cookies have been disabled.

Like most websites, the Site gathers certain information automatically and stores it in log files. This information includes internet protocol (“IP”) addresses, browser type, operating system, internet service provider (“ISP”), referring/exit pages, date/time stamp of access, and clickstream data, and information about the content you view on the Site. When you visit the Site, the servers automatically log your IP address, the time and duration of your visit, and the time and duration spent on the pages of the Site which you view. If you arrive at the Site by clicking a paid advertisement or a link in a communication, then the server will capture information that tracks your visit from that link. If you arrive at the Site by clicking on a non-paid source, such as a search engine result or link on another website, the server may capture information that tracks your visit from that source, to the extent available. Some of our communications to you may contain a “click-through URL” which links to content on the Site. When you click one of these URLs, it passes information through the Digital Asset Holdings, Inc. web server before you arrive at the destination web page. Digital Asset Holdings, Inc. tracks this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from Digital Asset Holdings, Inc.

Certain features of the Site may use local stored objects (“Flash cookies”) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. Digital Asset Holdings, Inc. additionally may use web beacons or pixel tags, which are tiny invisible graphic images, in the Site. Web beacons and pixel tags may be used by Digital Asset Holdings, Inc. to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

(c) Different Devices

If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access the Site, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information.

(d) Third-Party Analytics and Remarketing

We may use third-party service providers (e.g., Google Analytics) to collect and analyze information about use of the Site. These service providers may utilize cookies and related technologies to collect personal information.

We may use remarketing services (e.g., Google AdWords) to advertise on third party websites after you visit the Site. You may adjust your ad personalization settings by visiting the Google Ad Settings webpage: http://www.google.com/settings/ads. To opt-out of Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage: http://www.google.com/intl/en/policies/privacy/.

2. Use of Information

Digital Asset Holdings, Inc. and its service providers may use your personal information to provide our services and to contact you in response to inquiries you submit. Digital Asset Holdings, Inc. and its service providers may use your information to manage our contractual relationship with you, because we have a legitimate interest to do so, and/or to comply with a legal obligation:

  • to present our Site and related content to you;
  • to conduct our token offering;
  • to evaluate and determine your eligibility to participate in our token offering;
  • to verify your, or any beneficial owners’, identity and source and use of funds used to purchase any interest at the time of a token offering or after completion of a token offering;
  • to verify the identity and source and use of funds related to a transfer of tokens;
  • to provide you with information, products or services that you request from us;
  • to provide you with notices about your account;
  • in combination with other information for Site improvement and marketing and promotional purposes;
  • to provide more consistent and personalized services across the Site, including to personalize our advertising, marketing, and promotional efforts;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to notify you about changes to the Site or any products or services we offer or provide though it;
  • to allow you to participate in interactive features on the Site.

On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time. You have the right to withdraw your consent at any time; however, we may have other legal grounds for processing your information, including those identified above.

3. When Digital Asset Holdings, Inc. Discloses Your Information

We may disclose aggregated information about our users without restriction. This data cannot be attributed to any specific individual. Digital Asset Holdings, Inc. may disclose aggregated user data in order to describe our services to current and prospective affiliates, and to other third parties for lawful purposes.

Digital Asset Holdings, Inc. and its service providers may transfer information between them for business purposes. For example, our service providers may handle technical support, payment processing, marketing, advertising delivery and tracking, or information analysis. We furnish our service providers the information they need to perform these and other services, and we work with our service providers to respect and protect your information. We may also provide your information to our affiliates. The entities with which we share information may be located in the United States or other countries.

In the event that Digital Asset Holdings, Inc. or some of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on the Site may be transferred or shared with third parties as part of that transaction or negotiation. We may also provide information or provide access to information to any of our affiliated businesses or to our business partners.

On rare occasions, we may disclose specific information without your consent and without notice to you as required to comply with laws and regulations, or to comply with court orders, subpoenas, lawful discovery requests, or requests from regulatory, governmental or tax authorities or agencies. Information collected from you may also be used to investigate security breaches or otherwise cooperate with authorities. We may also share information with companies assisting in fraud protection or investigation.

We may disclose information about you without your consent and without notice to you as required to enforce or apply the Terms and Conditions (), or other agreements, including for billing and collection purposes.

4. How Your Information is Protected

Digital Asset Holdings, Inc. has implemented reasonable physical, technical, and organizational safeguards to help protect your personal information from unauthorized access, acquisition, or disclosure, alteration, or destruction. Although we strive to keep your personal information secure, no safeguards can be guaranteed to be completely secure, so you should exercise caution when transferring personal and other sensitive information over the Internet. Please advise us immediately at the address listed below of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

5. Third-Party Sites

The Site may contain links to other websites. Please note that when you click on one of these links, you will leave the Site and will be subject to the policies and privacy practices of the other websites, which may differ significantly. You should review the policies of other websites you visit. Digital Asset Holdings, Inc. is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.

6. Children’s Privacy

The Site is not aimed at or intended for children. We do not knowingly collect information from children under the age of thirteen through the Site. If we obtain actual knowledge that we have inadvertently collected personal information relating to a child under the age of thirteen, we will delete that information from our records. If you believe we might have any information from or about a child under the age of thirteen, please contact us at [insert email address].

7. Applicable Law

We recognize that the Site may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of Wyoming. [Please confirm] Because we cannot practicably prevent users in different jurisdictions from accessing the Site, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the Site or any of its content or functionality, the Site is not intended for you, and we ask you not to use it or submit any information through it.

8. Do Not Track

“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting requests that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals. [Please confirm]

9. Data Retention

We retain personal information for as long as necessary to provide services to you and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations and enforcing our agreements. Retention periods vary depending on the type of information and how it is used. The criteria we use to determine the appropriate retention periods include:

  • How long we have a relationship with you and provide services or products to you.
  • Whether there is a legal, contractual or similar obligation that requires us to keep your information for a certain period of time.
  • Whether you have consented to retention of your information for a longer period of time.
  • When we no longer need to use or retain your personal information, we will remove it from our systems or depersonalize it so that it cannot be used to identify you.

10. Rights to Access and Control Your Personal Information [Please confirm]

    You have choices about the collection, use, and sharing of your personal information, including:
  • Deletion: You can request that we erase or delete all or some of your personal information (e.g., it is no longer necessary to provide services to you).
  • Change or Correct: You can review and edit your personal information by logging onto the Site and visiting your account. You may also send us an email at [insert email address] to correct any personal information that you have provided to us.
  • Object to or Restrict Use: You can request that we stop using some or all of your personal information or restrict our use of your personal information.
  • Access and/or Take: You can request a copy of your personal information
  • Marketing: You may opt-out of direct marketing or profiling we carry out for direct marketing by following the unsubscribe link or instructions provided in our email communications.
  • Withdrawing Consent: If we have collected or processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information based on other lawful processing grounds.

For your protection, we may need to verify your identity before fulfilling your request. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that occurred prior your request. We will also retain your personal information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or enforce the Terms and Conditions (). To learn more about how to make these requests, please contact us at [insert email address].

11. Cross-Border Transfers

Your information, including personal information, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. You should also be aware that data related to the Site is stored on hosted remote servers on Microsoft Azure and/or AWS Cloud. If you are located outside Hong Kong and choose to provide information to us, please note that we transfer the information, including personal information, to Hong Kong and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

12. Updates to this Privacy Policy

Digital Asset Holdings, Inc. may update this Privacy Policy and the Site to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. You should review this Privacy Policy when you visit the Site to understand our current practices. The date at the top of the page shows when this Privacy Policy was last updated. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current practices. You consent to any changes we make to this Privacy Policy if you continue to use the Site after receiving a notice of the change or upon our posting of the new Privacy Policy on the Site.

13. Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our legal counsel. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word “including” is used, it means “including without limitation.”

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Digital Asset Holdings, Inc. any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable privacy laws, this Privacy Policy shall be interpreted in that case to give effect to, and comply with, such privacy laws.

14. Contact Us

If you have questions or comments about this Privacy Policy or the Site, please contact us using the information below. [Please confirm]

Digital Asset Holdings Inc.
999 Vanderbilt Beach Road
Suite 200
Naples, FL 34108
Telephone: [insert telephone number]
Email: [insert email address]