Aheads Privacy Policy
Introduction
Your privacy is very important to us. We are dedicated to safeguarding the privacy, confidentiality, and security of personal data under applicable laws and regulations. We also require that all our employees, service providers, and agents adhere to these obligations. This policy details how we handle personal data within our organization, including how we process the data of users who utilize our services or interact with our website - aheads.xyz (Aheads).
Before offering our products and services or gathering your personal data, we always refer to this Privacy Policy. By using Aheads Services, providing personal data, and/or utilizing any of our products or services, you acknowledge that:
you understand and agree to our personal data processing practices as outlined in this Privacy Policy, as updated periodically; and
if you have shared personal data relating to another person, you:
have the 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.
How we collect personal data
We collect personal data about you in the following ways:
you provide your personal data directly (e.g., by using Aheads Services, submitting a query or job application, or using our products and services);
third parties who are authorized to disclose your information provide it to us;
we obtain your data from public sources (e.g., public blockchain records, public registries, or public social media profiles);
we collect data automatically (e.g., tracking your use of our websites and mobile applications).
In some cases, the law may require us to collect certain types of personal data about you.
Generally, we gather personal data from you directly. However, we may also collect data through representatives, contractors, or third parties who refer you to us because they believe you may have an interest in our products or services.
Types of personal data we collect, purposes, and legal bases for processing
We process your personal data based on the following legal bases and for these purposes:
Performance of contract: Primarily, we process your personal data to provide products and services per the agreement between us. This includes providing customer support and contacting you about the website, products, or services.
For these purposes, we process data such as:
personal identification information (e.g., full name, date of birth, gender, ID documentation, photographs, employer, tax ID);
contact information (e.g., email, phone, address);
financial details (e.g., credit card, IBAN, bank account information);
communication data (e.g., records of communications with you);
blockchain-related information (e.g., blockchain addresses);
transaction information (e.g., transaction details on our platform);
online identifiers (e.g., IP address, browser fingerprint, geolocation);
Without this information, we may be unable to provide our products or services fully.
Legal obligation: We may process your personal data to meet legal requirements, including AML and CTF obligations.
Legitimate interest: Data received from your use of Aheads Services may be processed to improve user experience, including market analysis, staff training, and business planning.
Consent: With your consent, we may process data for direct marketing purposes. You may withdraw your consent at any time via the ‘unsubscribe’ link in our emails.
Direct marketing and profiling for marketing purposes
With your consent, we may use personal data for direct marketing. We may send you materials we believe may interest you. You can opt out at any time via the ‘unsubscribe’ link in our emails or by contacting us at support@aheads.xyz.
To tailor our marketing, we may create a profile based on:
identifying information (e.g., name, birthdate);
contact details (e.g., postal address, email);
product portfolio information.
People to whom we disclose personal data
We share your personal data when necessary and legally permissible:
Data processors: We use service providers who implement appropriate technical and organizational security measures.
Third parties: We share personal data with third parties only as stipulated, legally required, or with your consent.
Protecting our rights: We may share data with legal representatives to protect our rights.
Mergers and acquisitions: In case of a merger, acquisition, or similar transaction, personal data may be transferred.
Legal obligations: Personal data may be shared with auditors or authorities.
Security
We implement technical and organizational security measures to protect your personal data, considering factors such as the state of the art, implementation costs, nature and purpose of processing, and associated risks.
Retention of personal data
We retain your personal data as long as necessary for the purposes collected, to protect our rights, or as legally required. Typically, data retention periods are:
Legal transaction records: retained for the agreement’s validity and for 10 years afterward;
Billing information: retained for 7 years after the financial year’s end;
Other data: retained for 5 years.
Access, correction, and your other rights
Under applicable data protection laws, you have the right to:
access and obtain a copy of your data;
rectify inaccurate data;
erase data;
restrict data processing;
portability of data;
object to processing based on legitimate interests or for direct marketing.
Complaints
If you believe we have breached privacy laws, contact our privacy compliance team at compliance@aheads.xyz. You may also lodge a complaint with the Estonian Data Protection Inspectorate or the court.
Changes to this policy
We may update this policy to reflect changes in practices or to comply with new regulations. Material changes will be notified via email and a website pop-up. The latest version will be available on our website.
Governing law
If you are a data subject in the European Union or the data processing relates to an agreement with Aheads OÜ of Estonia, processing is governed by Estonian law.
Contact details
For privacy-related information or to exercise your rights as a data subject, contact our privacy compliance team at compliance@aheads.xyz.
This Aheads Privacy Policy is effective from 01.10.2024.