Data Controller

• Data controller: APIS VTN LTD., (hereinafter APIS VTN)
• Registered address: Ellen L. Skelton Building, Road Town, Tortola, British Virgin Islands (BVI)
• Email: [email protected]

Purposes and basis of legitimacy

Personal data collected by APIS VTN will be processed according to the purposes and on the basis of legitimacy indicated below:

In relation to consent-based data processing, the user may revoke their request at any time and free of charge, although this does not affect the lawfulness of any previously carried out processing.

To revoke your request, you can contact APIS VTN by email at [email protected]

In relation to legitimate interest-based data processing, users may object to the processing of their data for reasons related to their particular situation. APIS VTN will stop processing the data, except for compelling legitimate reasons, or for the exercise or defense of possible claims.

To object to processing when it is based on legitimate interest, you can contact APIS VTN by email at [email protected]

Processed data

Data to be processed by APIS VTN within the framework of the relationship with the data subject and depending on the purpose of the processing will include, among others, the following categories:

• Private contact data and identification data (name and surname, address, email, landline or cell phone number, ID card or similar document, IP address).
• Data related to employment and organization, (company, department, position, responsibilities, functions).
• Data relating to professional and training circumstances (career, job data, period of employment, tasks, activities, studies, qualifications, evaluations).
• Financial data for billing management (bank account).
• Data relating to photographs and videos on personal image. When attending activities and events organized by APIS VTN, the person concerned may be photographed or videotaped. Such photographs and videos are used by APIS VTN to inform you of the events it organizes as well as to provide you with information or communications that may be of interest to attendees.
• Data related to entry onto the SVTN token presale whitelist, such as: name, last name, email address (required data). This may also include data such as the declared amount of funds in USD to be invested in the SVTN token presale, Twitter (X) account name, Telegram account name, and/or information on where the data subject heard about APIS VTN (optional data).

In addition, to analyze the performance of our services, data derived from the use and contracting of our products and services will be used.

Obligation to provide data

Forms provided on the Website will identify the information that must be completed. If the user does not provide the information marked as mandatory, APIS VTN will not be able to process the request.

Data retention

APIS VTN will retain users' personal data only for the time necessary to fulfill the purposes for which they were collected, as long as the granted consents are not revoked. Subsequently, if necessary, it will keep the information blocked for the legally established periods.

In the case of data that you provide to us in relation to sending applications, they will be retained for one year, from the date of the last update. After this period, without being updated, the data will be deleted, unless you indicate otherwise.

You can get more information at [email protected].

Data recipients

Processed personal data will not be disclosed to third parties, except with prior information and express consent of the data subject.

In addition, we inform you that certain data, within the framework of current regulations or the contractual relationship you maintain with APIS VTN, may be disclosed to:

• Public administrations with competence in APIS VTN's sectors of activity, when so established by current regulations.
• The State Security Forces and Corps by virtue of the provisions of the Law.
• Banks and financial institutions for the collection of the services offered.
• Other professionals in the legal field, when such communication is required by law, or for the execution of the contracted services.

International transfers

In the event that we transfer personal data or exchange personal data with third parties outside the European Economic Area, we will ensure that we and the persons or companies to whom we transfer personal data take appropriate protection measures in accordance with existing data protection legislation, in particular through the use of Chapter V safeguards of the GDPR, such as standard contractual clauses or other mechanisms that may be appropriate at each time.

Rights of the data subject

• Access: allows the data subject to obtain information on whether or not APIS VTN is processing personal data concerning him/her and, if so, the right to obtain a copy of the personal data being processed.
• Rectification: allows you to correct errors and modify data that are inaccurate or incomplete.
• Deletion: allows data to be deleted and no longer processed by APIS VTN, unless there is a legal obligation to keep it and/or there are no other legitimate reasons for APIS VTN to process it.
• Limitation: under the legally established conditions, allows the processing of data to be stopped, so that APIS VTN avoids processing in the future, and will only keep the data for the exercise or defense of claims.
• Opposition: in certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data.
• Portability: allows the data subject to receive his or her personal data and to be able to transmit it directly to another controller in a structured, commonly used and machine-readable format.

APIS VTN guarantees the adoption of the necessary measures to ensure the exercise of these rights free of charge, it being necessary for such exercise that you identify yourself properly and communicate with us through the following channels:

• By writing an email through the following address, providing the same information set out in the previous section to: [email protected]
• By sending a letter by post, indicating in the request which right is being exercised, to the address Ellen L. Skelton Building, Road Town, Tortola, British Virgin Islands (BVI), to the attention of APIS VTN customer management.

Likewise, and especially when the data subject considers that they have not obtained full satisfaction in the exercise of their rights, they may file a complaint with the Spanish Data Protection Agency located at Calle de Jorge Juan, 6, 28001, Madrid or through www.aepd.es.

Security measures

APIS VTN is committed to keeping your Personal Data secure, taking all reasonable precautions to do so. To this end, we implement all necessary technical and organizational measures in accordance with this Policy and applicable laws and regulations to protect your Personal Data against any unauthorized access, modification or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.

We also contractually require our service providers and partners to apply an adequate level of security for the proper protection of personal data.

Changes to the privacy policy

This Policy may change over time due to possible changes in the criteria followed by the supervisory authority responsible for data protection at each time. APIS VTN therefore reserves the right to modify this policy in order to adapt it to these criteria, as well as to new health, jurisprudential or legislative developments.