Privacy Policy

This Privacy Policy was updated on 6 March 2019

1. Introduction

Cartan Group LLC (“Cartan” or “we” or “us”) and its affiliates understand that your privacy is important to you. We are committed to protecting the privacy, confidentiality and security of the personal data we collect and hold via www.cartan.ky, including all pages within this website (collectively referred to herein below as this “Website”), by complying with the requirements under applicable laws and regulations. This Privacy Policy covers how we collect, handle, use, disclose, transfer, store, and protect your personal information. For more information about the general terms and use of this Website, click here.

Here are the ways in which we collect data:

  • When you register your email address on the Website
  • When you submit a query or request to us
  • When you respond to a survey that we run or fill in forms on one of our websites
  • When tracking your use of our websites and mobile applications
  • From third parties who are entitled to disclose that information to us
  • Applying for a job with us.

In some cases we may be required by law to collect certain types of personal data about you.

Where we collect personal data from you, we will generally do so ourselves. However, in some cases we may collect personal data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

2. Information we collect

The kinds of personal data that we collect and hold about you may include:

  • Identifying information, such as your name and email address
  • Contact information, such as email address and telephone number
  • Social media handles and other social media profile information that you make available to us or to the public blockchain identifiers, such as blockchain addresses and public keys
  • Details of any products or services that we provide to you
  • Information about how you use the products and services we provide
  • Records of our communications with you, including any messages you send us

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

3. Use of information

The personal data we collect may be used where we have your specific consent to do so, or where Cartan may be required for the operation of the Website or to provide certain products or services to you. We may keep your personal data on file and the use of your personal data may include:

  • To verify your identity when you are dealing with us
  • To determine your eligibility for any of our products or services
  • To law enforcement authorities or other government officials
  • To improve our website based on your information and feedback
  • To answer your queries and requests
  • To carry out market analysis and research
  • To monitor use of our products and services
  • To assess, maintain, upgrade and improve our products and services
  • To carry out education and training programs for our staff
  • To carry out planning and forecasting activities and other internal business processes
  • To keep you informed about our activities, including by sending out newsletters

Furthermore, we may disclose information about you:

  • When we believe it is necessary to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity
  • To enforce our Terms of Use
  • To protect our property, services and legal rights
  • To comply with any and all applicable laws
  • To manage and resolve any legal or commercial complaints or issues

We may also use and disclose your information for other purposes in accordance with your requests or instructions.

We may from time to time use your personal data in order to send you marketing materials about our products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at info@cartan.ky.

We may use your following personal data for the purpose of direct marketing:

  • Identifying information, such as your name and date of birth
  • Contact information, such as your email address and telephone number
  • Products and services portfolio information and demographic data held by us from time to time.

4. Transfer of information

We may share personal data about you with:

  • Your representatives, advisers and others you have authorized to interact with us on your behalf
  • Our staff who need the information to discharge their duties
  • Related entities within our corporate group
  • Our business partners, agents and service providers with a need to know in order to discharge their duties to us
  • Professional advisers who we engage to provide advice on our business
  • Government authorities who require us to disclose that information, or to other people as required by law.

In some cases, the people to whom we disclose your personal information may be located overseas.

5. Security and storage of information

We generally store the personal data that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal data in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that you become aware of.

We also take steps to monitor access to and modification of your information by our staff, and ensure that our staff are aware of and properly trained in their obligations for managing your privacy.

6. Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website analyze how users use our website.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

7. Your rights

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at info@cartan.ky.

We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us at info@cartan.ky.

8. Consent and changes to Privacy Policy

By using our site, providing personal data or using any of our products or services, you agree that:

  • You consent to this privacy policy, as updated from time to time; and
  • If you have provided personal data to us relating to any other person, you:
  • have a right to provide that information;
  • have provided a copy of this privacy policy, as updated from time to time, to that person; and
  • each such person has agreed to those terms.

Data protection, privacy and security is of the utmost importance to us. We intend to make changes to this policy from time to time, to take into account changes to our standard practices and procedures, where necessary to comply with new laws and regulations. The latest version of this policy will always be available on our website. We reserve the right to make changes to this Privacy Policy from time to time.

9. Contact Us

If you have any questions about our Privacy Policy, please contact us at info@cartan.ky.