Privacy Policy

StackinSat “the Company” attaches the greatest importance to the privacy and protection of the personal data of its current or potential Users.

This is why the Company pays particular attention to collecting and processing their personal data with the greatest care and in strict compliance with the applicable legal framework.

The Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data ” RGPD” affirms that personal data must be processed in a lawful, fair, and transparent manner.

In order to inform in the most transparent way possible, the Company has drafted the Privacy Policy below. It is intended to explain in detail why and how the personal data of Users are processed when they navigate on the stackinsat.com website (the "Site") or use the services offered by the Company (the "Services").

The present Privacy Policy aims to inform You, as a User, about the way in which the Company, as the processor of the data, treats the information enabling You to be identified, directly or indirectly (the "Personal Data"), when You use the Site.

La présente politique accessible à tout moment sur le Site est la seule politique applicable et prévaut sur toutes les versions antérieures.

When a User uses the Services, the Company processes its Personal Data for various purposes detailed below, each of which being duly justified by a valid legal basis.

Information on navigation. In order to enrich the User experience, the Company wants to understand their interactions with the Services. That is why the Company needs to analyze various navigation information collected through Cookies allowing to analyze the performance related to the use of the Services.

For this, the Company relies on its legitimate interest which consists in (i) understanding how its Platform is used by Users; and (ii) improving the Platform if necessary.

Correspondences and communications. The Company collects and processes Personal Data in order to satisfy any question, request or feedback that Users may submit to the Company, initiated or not by the latter.

Thus, the collection and processing of Personal Data through this means can only take place after a question, request or feedback that is directly addressed by postal mail or e-mail to the Company. Outside of this situation, Personal Data will never be collected through this means.

This processing involves the collection of the following categories of Personal Data: (i) identification data (i.e. the information provided, including name and e-mail address) and (ii) the content of the or messages you send to the Company.

This processing is based on the Company's legitimate interest in having to manage its relations with Users.

Management of accounts. Users must create an account on the Platform to access the Services, involving having to go through an important customer identification procedure (KYC). To manage this account, and in particular to allow Users to access content reserved for account holders only, the Company collects and processes the following categories of Personal Data:

• concernant les données des personnes physiques : prénoms et noms ; date et lieu de naissance ; numéro de téléphone ; nationalité ; catégorie socioprofessionnelle ; secteur d’activité ; revenus ; avis d’imposition ; domicile ; justificatif de domicile ; adresseélectronique ; adresse IP ; coordonnées du portefeuille d'actifs numériques ; copie d’un document officiel d’identité; identifiant et mot de passe pour accéder au compte ;
• concernant les données des personnes morales : nom commercial ; raison sociale ; numéro d'immatriculation ; adresse du siège social ; adresse électronique de la personne physique représentant de la personne morale ; coordonnées du portefeuille l’adresse électronique ; adresse IP ; coordonnées du portefeuille de la personne morale ; numéro de téléphone mobile de la personne physique représentant la personne morale ; copie de ses Statuts à jour ; copie d’un document permettant l’identification de la personne morale, à savoir, s’agissant de sociétés françaises : un extrait Kbis datant de moins de 3 mois, s’agissant de sociétés étrangères : un certificat de validité juridique ou une attestation de constitution de la société (certificate of incorporation) et s’agissant d’une association : d’un extrait du Journal officiel constatant sa déclaration en préfecture ; les noms, prénoms, adresse la personne physique représentant la personne morale si cette personne physique n’est pas un représentant légal ; les prénoms, noms, date et lieu de naissance du représentant légal ; copie d’un document officiel d’identité de la personne physique représentant la personne morale et des bénéficiaires effectifs ; secteur d’activité ; chiffre d’affaires ; liasse fiscale, attestation ou situation comptable ; identifiant et mot de passe pour accéder au compte.

The legal basis for this processing is the need for the Company (i) to execute a contract to which the User is a party and (ii) to comply with its obligations in the fight against money laundering and the financing of terrorism (LCB-FT).

Management of Operations. The Company is required to collect Personal Data necessary for the management of Operations and billing, under the following conditions:

concerning the data of natural persons: first name and last name; address; e-mail; IP address; and digital asset wallet coordinates; address

concerning the data of legal persons: name, registration number, headquarters, e-mail address; IP address; and digital asset wallet coordinates. The legal basis for this processing is the need to execute a contract to which the User is a party.

Users are never required to provide Personal Data that the Company may ask them for. However, the Company draws their attention to the fact that if they refuse, access to the Services may be limited, suspended or even impossible.

In any case, and regardless of the purpose sought by the processing in question, the Company will comply with a strict principle of data minimization and will therefore only collect and process the Personal Data necessary for the purposes mentioned above.

The Company shares Personal Data with service providers and third-party suppliers who help the Company achieve the objectives specified in the present Privacy Policy and contribute to the provision of the Services. As subcontractors of the Company, service providers and suppliers may have access to Personal Data solely for the purpose of performing the tasks assigned to them. The Company ensures that its subcontractors have sufficient guarantees for the execution of the mission and comply with the applicable laws and regulations.

In the event, the Company shares Personal Data with the competent courts and any other government or public authority requesting access to Personal Data, to the extent that this is legally authorized.

In any case, the Company does not communicate Personal Data to the aforementioned recipients on the basis of the strict need to know and only to the extent necessary for the identification of the processing objectives.

If the Company considers that it is not necessary to keep the User's Personal Data in its active database, the Company will archive them and ensure that their access is limited to a small number of people who have a real need to access the Personal Data.

The Company retains Personal Data for a limited period that cannot exceed the time necessary to achieve the objectives described in Article 3 of the present Privacy Policy.

Information on navigation. The retention period of Cookies is specified below according to the provisions of Article 9 of the present Privacy Policy.

Correspondences and communications. The Personal Data resulting from questions, requests or feedback from Users are not kept for more than five (5) years after the last contact initiated by the User.

Management of accounts. The Company will keep the Personal Data until the closure of the account. However, if the Company must keep Personal Data for proof purposes beyond the date of closure of your online account, the maximum retention period applicable will then be in accordance with the legal limitation periods.

Management of Operations. With regard to the management of Operations, Personal Data will be kept for the entire duration of the commercial relationship and ten (10) years after this duration for accounting purposes.

Management of payments. Personal Data is retained: in the event of a purchase and sale transaction, until the service has been performed; Regarding the retention of means of proof in order to manage any claims, data is retained for a period of 13 months from the date of debit. Data retained for proof purposes must be kept in intermediate archive and only used in the event of a dispute over the transaction.

If the Company considers that it is not necessary to keep Personal Data in the Company's active database, it will be archived and the Company will ensure that access is limited to a small number of people who have a proven need to access the Personal Data.

Personal Data may be processed outside the European Union. In this situation, the Company takes all necessary precautions and ensures, alternatively or cumulatively, that (i) a decision of adequacy has been taken by the European Commission concerning the destination country; (ii) contractual clauses adopted by the European Commission or the control authority have been signed with the recipient; (iii) the recipient adheres to a code of conduct or a certified mechanism.

As a person concerned, you have different rights concerning the processing of Personal Data. These are as follows:

• right to request the Company access to Personal Data and their rectification or deletion;
• right to request the Company to restrict the processing that concerns you;
• right to object to the processing of Personal Data;
• right to portability of Personal Data;
• right to give instructions concerning the use of Personal Data after the death of the User; and
• right to lodge a complaint with the National Commission for Computing and Freedoms (CNIL), the competent control authority.

To exercise their rights or for any question on the protection of Personal Data, Users must make the request accompanied by a proof of identity by letter addressed to the company or by email to the following electronic address contact@stackinsat.com.

The Company strives to respond as quickly as possible and at the latest within a period of one (1) month after receipt of the request. The Company reserves the right to extend this period to three (3) months in the case of a complex request.

The Company commits to protecting Personal Data and to complying with the legal framework applicable to the protection of data.

This is why the Company collaborates with Users. Thus, you undertake to inform the Company if the Personal Data that the Users have shared with the Company become obsolete or inaccurate.

Furthermore, in the case where you provide the Company with information enabling the identification, directly or indirectly, of any other natural person (for example, the Users have sent a request to the Company and share Personal Data concerning another natural person in the email), you declare and guarantee that, before sharing these information with the Company, these other natural persons have received this privacy policy and, to the extent applicable, have consented to the processing of their data.

The Company commits to taking the appropriate technical and organizational measures to ensure the security and confidentiality of the Personal Data processed.

You are informed that information called Cookies may be transmitted to the browser or the User's equipment by the Service when using the Site. When you first navigate on the Site, a "Cookies" banner may appear and ask you to accept, refuse or configure the Cookies.

The maximum duration of the Cookies is thirteen (13) months from the moment they are placed on the browser or the User's equipment. At the end of this period, a new consent will be required.

You can accept, refuse and delete some or all of the Cookies.

You are informed that the refusal of certain Cookies may affect the provision of the Service and navigation on the Site.

The Company informs you that the Cookies can be configured in the help menu of the browser at the following URLs: Google Chrome; Mozilla Firefox; Safari; Edge and Opera.