Last updated: June 22, 2018

This is the privacy policy for the InventoryClub ecosystem (“InventoryClub”, “we”, “us”, “our”, “the Service”), which consists of but is not limited to, the InventoryClub Marketplace and the VNTPay Mobile Application. The InventoryClub Marketplace is the world’s first peer-to-peer inventory finance marketplace to connect Commonwealth merchants with a global membership of financial backers and the VNTPay Mobile application is a digital wallet created by InventoryClub to hold VNT and associated cryptocurrencies.


We respect and diligently protect the privacy of those who access and use our Service. Please read our privacy policy carefully before using the InventoryClub ecosystem and corresponding services operated by InventoryClub ("us", "we", or "our").


By signing up to use the InventoryClub ecosystem or any of our associated websites, APIs, or corresponding services (collectively the “InventoryClub ecosystem”, “InventoryClub”), you agree that you have thoroughly read, completely understood, and accept our Privacy Policy.


Your access to and use of the Service is conditioned on your acceptance of and compliance with our Privacy Policy. Our privacy policy applies to all visitors, users and others who access or use the Service.


By using the InventoryClub ecosystem and corresponding services, you signify your agreement to this Privacy Policy. We reserve the right to change this Privacy Policy at any time. If we make any material changes to this Policy, the revised Policy will be updated on to here and notified to our users at least 30 days prior to the changes taking effect, so that you are always aware of what information we collect, how we use this information and under what circumstances we disclose it.


These notices may supplement or clarify our privacy practices or may provide you with further choices about how InventoryClub processes your data. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Regardless, we advise you to check this page often to see any updates or changes to this Privacy Policy.


If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.



Personal data and the information we collect:

The data we collect is classed as personal data, define as data that can be used to identify you directly or indirectly, or enable third parties to contact you. All personal information that you voluntarily submit to us and that we receive from our partners, is covered by our Privacy Policy. Anonymous data is not covered by this privacy policy, as you cannot be identified with this data.


When engaging with the InventoryClub Marketplace, VNTPay and associated services of the InventoryClub Ecosystems, you may be asked to provide personal information. Your personal information may be shared between associated companies within the InventoryClub Ecosystem. They will use it in accordance with this Privacy Policy and may also combine it with other information, enabling the improvement of our services, content and user experience.



Outside of what is described within this Privacy Policy, we will not give, sell, rent or loan any of your personal Information to any third party.


For us to be able to provide you with our services, we must collect personal information. It is either by law that we are required to obtain certain information from users or it is relevant for specified purposes. Information that you provide to us that is not required is classed as voluntary. Users are free to choose whether to provide us with voluntary information that may be requested, but without this information we may not be able to serve you as effectively or offer and provide all the services available from the InventoryClub ecosystem and associated services.


Below is the type of information we may collect:


Personal Identification Information: Full name, age, date of birth, nationality, gender, utility bills, photographs, phone number, signature, home address, and/or email.


Formal Identification Information: Tax ID number, National Insurance number, passport number, driver’s license details, photograph identification cards, national identity card details, and/or visa information.


Employment Information: Workplace location and job title.
Transaction Information: The details, including but not limited to monetary size and fulfilment in terms of Inventory purchased and Inventory sold, of proposals you as a Member or Merchant are or were involved with. Also, information about the transactions you make on the VNTPay Mobile Application or associated services for all purposes, such as the name of the recipient, your name, the amount, and/or time of transaction.


Note, all transactional information involving a cryptocurrency created by InventoryClub and used within the InventoryClub ecosystem will collected, with respect to this Privacy Policy, our Terms and Conditions and applicable law (England & Wales).


How we use your personal information:


Providing a secure, frictionless and enjoyable experience is our primary reason for collecting users’ personal information. We may use your data to provide more relevant customer service, engage in marketing activities and to ensure quality control, including network and information security. We may also use personal information for research and development purposes, aiming to enhance user experience.

User information from third parties:


In some cases, as required or permitted by applicable law, we may obtain personal information from third parties sources. These sources include but are not limited to public databases. Identification (ID) verification partners, marketing partners and social media platforms. Third parties such as ID verification partners will only receive your personal information to prevent fraud. Through such third parties, we can confirm your identity by comparing all the information we have obtained both from you and the third parties.


Your information may be shared with third party service providers, under partnership or contract who assist with some aspects of InventoryClubs operations, including but not limited to financial institutions, marketing, technical and technology services. Such service providers are prohibited from using your information outside of the instructed guidelines and/or selling your personal information.


In some circumstances, when we are compelled by a court order, subpoena or applicable legal procedure to share your information with third parties such as law enforcement and authorised officials. Disclosure of user information in such cases will always be in good faith, with the intent of preventing harm or loss, physically or financially to users and third parties.


Please note that Non InventoryClub merchants, suppliers and third parties you choose to interact with may have their own privacy policies and we are not responsible for ANY of their operations, such as how they handle their required, volunteered or third party sourced user information. We advise you to thoroughly assess their terms, policies and practices before engaging with such third parties. Regardless, unless you state otherwise or provide further authorisation, such third parties are prohibited from using your information for any purpose other than to facilitate the required purpose.


Digital currency transfer between you and a third party, such as a Non InventoryClub merchants, suppliers and third parties may involve third parties sharing your information with us; including but not limited to your mobile phone number or email address, used to notify you that a transfer has been received or sent by the third party. We may use such information for purposes, including but not limited to confirming your identity and validating your status as an InventoryClub user.

Protection and storage of personal information:


Privacy is not simply a feature of our services but a fundamental component. Therefore, we ensure our services or third-party partners maintain appropriate safeguards, technical, administrative and even physical to keep your personal information confidential and secure.


However, the misuse, unapproved acquisition or loss of your information cannot be guaranteed not to happen. It is important to also keep in mind that you, the user, play a crucial role in the protection of your own data. During registration for our services and after, as a user within the InventoryClub ecosystem, ensure to create a very strong password, of suitable complexity and length. Not revealing your password will be essential to ensure the security of your account. If, for any reason, unauthorised access occurs, you must notify us immediately.


Note, we can only protect your data once we receive the information. Confidentiality and security cannot be guaranteed before and when you send the information, only once we have received. Whether this information is sent to us via the Internet, on a wireless or non-wireless connection and/or whether this information is in the form of an SMS (text message), phone call or email (electronic mail), our protection policy only applies once we receive the information. If, for any reason, you believe the security of your information has been breached, you must notify us immediately.

Access and alterations to your personal information:


You have the right to view, access and amend your personal information. Information which is covered by this entitlement can be altered at your convenience via the particular component of the InventoryClub ecosystem. You can also delete/remove information when it is inaccurate or voluntary.

Closing your account:

If you choose to close your account, which may be your Member and/or Merchant account or VNTPay account, your account will be marked as “shut down” in our systems. Once your account is closed, we will not use your data for any further purposes or facilitate the use of your data by third-parties. Your information will not be sold or shared. Only at the request of law enforcement, in correspondence with this Privacy Policy or as required by law will your information be shared. However, we will retain your account information in our database for a variable period. We do this to deter and tackle potentially fraudulent behaviour. Keeping the information will prevent persons who attempt to commit fraud from avoiding exposure by closing their account and/or opening a new account.

Your rights regarding how we use your data:

You have the right to access, correct and delete your personal information. Under European data protection legislation, you have the right to access the personal information that InventoryClub holds regarding you. You may also require any incorrect personal information that we hold about you to be corrected or removed.


You also have the right to object. We may use your personal information for marketing purposes or in other circumstances in which you can object to the use of your data. Ensure to notify us immediately if you wish to exercise either of these rights.

Storage of your personal information:

Throughout the duration in which you have an account with InventoryClub, we will store your personal information and corresponding data securely. Your information will only be kept for a period necessary to fulfil the purposes the information is intended to serve, as stated in our terms of use or this Privacy Policy, but also for standard accounting, legal, reporting obligations and to resolve any disputes and/or assist with investigation of potentially fraudulent activity. Note, retention requirements differ by jurisdiction. Also, personal information, required and voluntary, will be kept for marketing purposes once you subscribe and will be used for such purposes until you unsubscribe.

Privacy and direct marketing:

We will only contact you for marketing purposes if you have given your consent, we will ensure that the information sent to you about VNTPay and/or associated services are familiar to those which you have are currently or have previously engaged with. Customers within the European Economic Area (EEA) will only be contacted by electronic means such as email or text message (SMS).

Individual Rights:

You have the right of access to your personal information. This means you have the right to request us to provide you with a copy of all the personal formation we hold regarding you. This information will be provided within an appropriate timeframe and may be subject to a fee, as permitted by law, without affecting the rights and freedoms of others.


You have the right to rectify your personal information. This means you have the right to request us to change and update any of the personal information we hold regarding you that is inaccurate. This information will be provided within an appropriate timeframe and may be subject to a fee, as permitted by law, without affecting the rights and freedoms of others.


Your right to access and rectification of your personal information, stated above, will only be limited where the burden or cost of facilitating access is asymmetric to the risks to your privacy in the case in question or the privacy and rights of individuals, other than you, would also be at risk.


You have the right to withdraw consent. This means you have the right to withdraw your consent to the processing of your personal information. This is information we have collected based on your approval during any point in time. Note, withdrawal of your consent will be affect the legitimacy of our processing based on your consent before your withdrawal.


You have the right to erasure. This means you have the right to request us to erase your personal information. This includes personal information which is not required anymore for the purposes for which it was initially collected and/or processed, and information was obtained in relation to processing to which you now object, and there are no legitimate grounds for our processing which negates your right. This also includes information which was obtained in relation to processing that was previously consented by you, but for which consent have now been withdrawn.


Note, subject to limitations by applicable data protection laws, if the personal information we hold regarding you has been made public by us and you request us, thus obligating us to erase your personal information, we will take appropriate action to inform third parties that are processing your personal information, that you have enforced your right and requested the erasure of your personal information in all forms.


You have the right to data portability. This means you may have the right to request to be given your personal information in a structure, which is common and machine-readable. This may be information we processed based on given consent or a contract. This also means you may also have the right to instruct us to transfer your personal information directly to another “handler”, defined as a legal entity, included but not limited to a person, governing body or private company, which solely or in cooperation with others, determines the processing of your personal information. We say “may” for both rights as this right is limited by cost, technical feasibility and potential affects on the rights and freedoms of others.


You have the right to restrict. This means you have the right to limit or object to us processing your personal information if you contest the accuracy of the personal information we hold regarding you, of which we will stop processing while verifying the accuracy. This also means if we no require your person for the initial purposes of the process but note, legal claims are your responsibility. In addition to the above, if the processing of your personal information is unlawful but you oppose the removal of your data, opting for restrictions of its use and if you have objected the processing of your personal data but we are in the process of verifying the legal grounds of which we have processed your personal information, overrule your stated rights.


If restricted information is processed by us, we will inform you; this will only be for reasons such required legal procedure. You will be notified of relevant erasure, rectification and/or restrictions on your personal information and so will corresponding authorised third-parties whom your data have been disclosed.


You have the right to object to processing. This means you have the right to object to the processing of your personal information, at any point in time, as permitted by applicable law. This will be information which we have processed based on contract, consent or legitimate reasons. This means you also have the right to not be subject to a decision, based on your personal information solely determined by an automated process. However, we will continue to process your personal information if required, in good faith, for any omissions permitted by applicable law.


Note, your rights stated above regarding your personal information are NOT absolute and access may be denied when denial of access is required or permitted by law, when providing access would affect the privacy of others, where the request for access is impractical or burdensome and to protect our rights and properties.

Contact Us: If you have any questions about this Privacy Policy, please contact us. Send Email: hello@inventoryclub.com



About InventoryClub

InventoryClub is the world’s first peer-to-peer inventory finance marketplace to connect Commonwealth merchants with a global membership of financial backers. We have built an ecosystem that enables online merchants to access inventory without the need to go through financial institutions, bridging the gap between the power of Blockchain and the people who can truly benefit from it, within the Commonwealth and beyond.

InventoryClub Ltd (“InventoryClub”), a private limited company incorporated in England and Wales with company number 11008829 and whose registered office is 8 Nursery Road, London, United Kingdom, SW9 8BP.

Complaints

If you have any serious issues with how we handle your personal information, you can complain to the relevant data protection authority. This may be the in the EU member state in which you live and/or work, or in the place where the alleged breach of data protection law has taken place. The relevant data protection authority in the United Kingdom is the Information Commissioner’s Office.