WEBSITE PRIVACY POLICY

This Privacy Policy applies to all personal information collected by the Qoin Foundation (we, us or our) via the website located at qoin.com (Website), in accordance with the Data Protection Act (DPA) 2017 of the Cayman Islands.

1. What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the Website.  The Personal Information which we collect and hold about you may include:

1. Device and browser information (e.g. browser type, operating system, screen resolution, and device type)
2. Usage data (e.g. pages visited, time spent on each page, navigation patterns, click events)
3. Geographic location (approximate) – based on your IP address, we may know the country, region, or city you are in.  Note: IP addresses are anonymised and not stored in full.
4. Online identifiers – Google Analytics assigns a unique ID to your browser to distinguish repeat visits.  This is stored via a cookie.
5. Traffic source information (e.g. how you arrived at our site — direct visit, search engine, or link from another site)

2. Types of information

Under the DPA, Personal Data means any information relating to an identified or identifiable natural person.  This includes information such as your name, contact details, or online identifiers if they can be used to identify you.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Data” and will not be subject to this privacy policy.

Sensitive Personal Data (referred to in the DPA as “special category data”) includes information such as an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, and data concerning a person’s sex life or sexual orientation.

3. How we collect your Personal Information

1. We may collect Personal Information from you whenever you input such information into our Website or provide it to us in any other way.
2. We may also collect cookies from your computer which enable us to tell when you use our Website and help customise your experience.  As a general rule, however, it is not possible to identify you personally from our use of cookies.
3. We generally do not collect Sensitive Personal Data, but when we do, we will comply with the preceding paragraph.
4. Where reasonable and practicable, we collect your Personal Information from you directly.  However, sometimes we may receive information from a third party.  In such cases, we will take steps to make you aware of the information that was provided.

4. Purpose of collection

1. We collect Personal Information to provide you with the best service experience possible on our Website and keep in touch with you about developments in our business.
2. We customarily only disclose Personal Information to our service providers who assist us in operating the Website.  Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
3. By using our Website, you consent to the receipt of direct marketing material.  We will only use your Personal Information for this purpose if we have collected such information directly from you, and if it is material of a type which you would reasonably expect to receive.  We do not use sensitive Personal Information in direct marketing activity.  Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe link.

5. Security, Access and Correction

1. We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure.  When we no longer require your Personal Information for the purpose for which it was obtained, we will take reasonable steps to destroy or anonymise it.  Most of the Personal Information that is stored in our client files and records will be kept for a maximum of 7 years to fulfil our record-keeping obligations.
2. Under the DPA, you have the right to:

1. access the Personal Information we hold about you;
2. correct inaccurate or incomplete information;
3. request erasure of data; and
4. to object to or restrict processing.

1. Where you would like to obtain such access, please contact us in writing using the contact details set out at the bottom of this Privacy Policy.

6. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us using the contact details at the bottom of this policy.  All complaints will be considered by our support team, and we may seek further information from you to clarify your concerns.  If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem.  If you remain dissatisfied with the outcome, you may refer the matter to the Cayman Islands Ombudsman.

7. Overseas transfer

Your Personal Information may be disclosed to recipients outside the Cayman Islands, such as our cloud-based or analytics service providers.  Where this occurs, we take reasonable steps to ensure that the overseas recipient handles your Personal Information in accordance with the DPA, including through the use of appropriate contractual safeguards.

8. How to contact us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through:

Email: [email protected]

1. Effective Date

These Terms of Use are effective from July 2025