Created
Sep 12, 2024
Palisade platform and mobile application privacy policy
[Palisade Financial Limited] ("Palisade", "we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any information from which you can be identified ("Personal Data") and that we collect from you, that you provide to us or that we otherwise obtain, will in each case be processed by us when you access and use the Palisade Platform (being the web-based platform made available at https://app.palisade.co) or the Palisade Mobile Application (the "Palisade App"). Please read the following policy carefully to understand our views and practices regarding your Personal Data and how we will treat it. We will ensure that your Personal Data is handled in compliance with the law. Here, the relevant law is: (i) the Data Protection Act 2018; (ii) the UK General Data Protection Regulation (as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019/419); (iii) the General Data Protection Regulation (EU) 2016/679 (as applicable); (iv) the French Data Protection Act; and (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together, the "Data Protection Legislation").
For the purposes of the Data Protection Legislation, [Palisade Financial Limited of 48 Warwick Street, London, England, W1B 5AW], is the Data Controller. Palisade is registered with the UK Information Commissioner's Office under registration number 13980052.
Collection of Personal Data
We may collect and process the following Personal Data about you:
Personal Data that you give to us
The Personal Data that you give to us may include details such
Title
Business address
Job title
Full name
Date of birth
Residential address
Email
Telephone number
Income
Occupation
Passport / driver's License Information (e.g. ID number, expiry dates etc.)
Personal Data that we collect about you
The Personal Data that we collect about you includes technical information about you and the device that you use to access the Palisade Application and the Palisade Platform, such as information regarding: (i) the type of device you use, a unique device identifier, network information, the type of operating system and browser you use, time zone settings, and other device-related information; and (ii) the date, time and duration of access to the Palisade App and the Palisade Platform, including pages viewed. From time to time, we may also receive Personal Data from third parties who have your consent, or are otherwise entitled, to pass your details to us. This includes Personal Data that is: [derived from the analysis of public blockchain data, such as timestamps of transactions, digital signatures and transaction amounts]; and provided by your employer, in order to facilitate your access to the Palisade App and the Palisade Platform (and identify you as an authorised user of the same).
Cookies
Palisade uses cookies on the Palisade App and the Palisade Platform.
A cookie is a small text file that is stored on your device by a web server, but cannot be used to launch programs or transmit viruses to your device.
The following cookies are used on the Palisade App and the Palisade Platform:
Palisade Platform Essential cookies required for the operation of the Platform Analytics and data usage metrics cookies
Palisade App Essential cookies required for the operation of the App Analytics and data usage metrics cookies
Use of your Personal Data
Palisade will only use your Personal Data in a manner that is appropriate considering the basis on which that data was collected, or otherwise obtained.
In particular, we will use your Personal Data:
As is necessary to perform our contract with you, including to: enable the creation of your Palisade Platform and Palisade App user account (and facilitate your access to the same); facilitate the processing of any transactions that you request be carried out via the Palisade Platform and the Palisade App; provide you with information and services that you request from us (including technical support in respect of your use of the Palisade App and the Palisade Platform); correspond with you via phone, e-mail or otherwise for the purposes of sending service updates relating to the Palisade App and the Palisade Platform; verify your identity with your employer, on behalf of which you will be accessing and using the Palisade Platform and the Palisade App; and notify you of any activity that occurs (including transactions that are carried out) via your account on the Palisade Platform and the Palisade App.
As is permitted for our legitimate interests, including for the purposes of analysing the use of, and improving, the Palisade App and the Palisade Platform.
As is necessary to enable us to comply with our legal and regulatory obligations.
Sharing of your Personal Data
From time to time, Palisade may share your Personal Data with other entities forming part of the Palisade group of companies and/or third parties. In particular, Palisade may disclose your Personal Data to third parties: in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; if Palisade or substantially all of its assets are acquired by a third party, in which case Personal Data held by us will be one of the transferred assets; if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation; which act as service providers to Palisade, including ComplyAdvantage, Notabene, Xapien, NorthRow; in order to enforce or apply the Palisade Platform and the Palisade App End User Terms and Conditions and/or Wallet Terms and Conditions, or to protect the rights, property, or safety of Palisade, our clients, or others.
Palisade asks all third parties to treat your Personal Data securely and in accordance with the Data Protection Legislation. We will take reasonable steps to enforce this.
International Transfers of Personal Data
[In order to facilitate our international business operations, it may be necessary for us to transfer your Personal Data to third parties located in jurisdictions outside of the UK and European Economic Area (EEA). In such circumstances, we will only transfer your Personal Data to third parties that (a) are located in countries that have been confirmed by the UK Government and/or the European Commission (as applicable) to provide adequate protection to Personal Data; or (b) have agreed (by way of a written contract or some other form of data transfer mechanism approved by the UK Government or European Commission (as applicable)) to provide all protections to your Personal Data as required by the Data Protection Legislation.]
Security of your personal data
The security of your Personal Data is important to us. We comply with accepted industry standards to protect the Personal Data that we hold. We use strict procedures and security features to try to prevent unauthorised access, however, no method of information transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Data.
Storage and retention of your personal data
Palisade will only hold your Personal Data for as long as it is reasonably required to fulfil the purpose for which it was collected and, in any event, for no longer than is permitted by the Data Protection Legislation. This will vary depending on the type of Personal Data and the purpose for which the Personal Data was collected and is being used.
Links to third party websites
[The Palisade App and the Palisade Platform may from time to time contain links to third party websites, such as blockchain explorers, defi app etc. If you follow a link to any of these websites, please note that you will be leaving the Palisade Platform or Palisade App (as applicable) and accessing the website of the third party. These websites have their own privacy policies which determine and explain how they collect and use your Personal Data, and Palisade does not accept any responsibility or liability for any such related policies.]
Your rights
Pursuant to the Data Protection Legislation, you have the following rights that can be exercised in relation to the Personal Data that we hold about you (save where an exemption exists): The right to request and obtain details about your Personal Data that Palisade holds about you; The right to request that inaccuracies about your Personal Data be rectified, and to have any incomplete Personal Data that Palisade holds about you completed; The right to have the Personal Data that we hold about you erased in certain circumstances; The right to object to or restrict the processing of your Personal Data in certain circumstances; and The right to withdraw your consent to Palisade's processing of your Personal Data, in circumstances where the relevant processing is being carried out based upon your consent. If you wish to seek to exercise any of the above right, please contact Palisade using the details set out in Section 10 of this Privacy Policy.
Changes to this privacy policy
Palisade reserves the right to update and amend this Privacy Policy at any time without notice. By continuing to use the Palisade App and/or the Palisade Platform, you agree to the updated Privacy Policy. Any amendments to this Privacy Policy will be made available on the Palisade App and the Palisade Platform and, where appropriate, notified to you by e-mail.
Contact us and complaints
If you have any comments, questions or requests regarding this Privacy Policy, please contact Palisade using the following contact details: privacy@palisade.co If you are unhappy about how Palisade is using your Personal Data, or if you feel that your rights have not been adequately respected, you have the right to complain to the relevant data protection regulator. For the purposes of the United Kingdom, this is the Information Commissioner's Office (ICO), which can be contacted via the ICO website at https://www.ico.org.uk/concerns or via email to casework@ico.org.uk. For the purposes of France, this is the CNIL, which can be contacted via the CNIL website at https://www.cnil.fr/en/plaintes.
Palisade platform and mobile application privacy policy
[Palisade Financial Limited] ("Palisade", "we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any information from which you can be identified ("Personal Data") and that we collect from you, that you provide to us or that we otherwise obtain, will in each case be processed by us when you access and use the Palisade Platform (being the web-based platform made available at https://app.palisade.co) or the Palisade Mobile Application (the "Palisade App"). Please read the following policy carefully to understand our views and practices regarding your Personal Data and how we will treat it. We will ensure that your Personal Data is handled in compliance with the law. Here, the relevant law is: (i) the Data Protection Act 2018; (ii) the UK General Data Protection Regulation (as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019/419); (iii) the General Data Protection Regulation (EU) 2016/679 (as applicable); (iv) the French Data Protection Act; and (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together, the "Data Protection Legislation").
For the purposes of the Data Protection Legislation, [Palisade Financial Limited of 48 Warwick Street, London, England, W1B 5AW], is the Data Controller. Palisade is registered with the UK Information Commissioner's Office under registration number 13980052.
Collection of Personal Data
We may collect and process the following Personal Data about you:
Personal Data that you give to us
The Personal Data that you give to us may include details such
Title
Business address
Job title
Full name
Date of birth
Residential address
Email
Telephone number
Income
Occupation
Passport / driver's License Information (e.g. ID number, expiry dates etc.)
Personal Data that we collect about you
The Personal Data that we collect about you includes technical information about you and the device that you use to access the Palisade Application and the Palisade Platform, such as information regarding: (i) the type of device you use, a unique device identifier, network information, the type of operating system and browser you use, time zone settings, and other device-related information; and (ii) the date, time and duration of access to the Palisade App and the Palisade Platform, including pages viewed. From time to time, we may also receive Personal Data from third parties who have your consent, or are otherwise entitled, to pass your details to us. This includes Personal Data that is: [derived from the analysis of public blockchain data, such as timestamps of transactions, digital signatures and transaction amounts]; and provided by your employer, in order to facilitate your access to the Palisade App and the Palisade Platform (and identify you as an authorised user of the same).
Cookies
Palisade uses cookies on the Palisade App and the Palisade Platform.
A cookie is a small text file that is stored on your device by a web server, but cannot be used to launch programs or transmit viruses to your device.
The following cookies are used on the Palisade App and the Palisade Platform:
Palisade Platform Essential cookies required for the operation of the Platform Analytics and data usage metrics cookies
Palisade App Essential cookies required for the operation of the App Analytics and data usage metrics cookies
Use of your Personal Data
Palisade will only use your Personal Data in a manner that is appropriate considering the basis on which that data was collected, or otherwise obtained.
In particular, we will use your Personal Data:
As is necessary to perform our contract with you, including to: enable the creation of your Palisade Platform and Palisade App user account (and facilitate your access to the same); facilitate the processing of any transactions that you request be carried out via the Palisade Platform and the Palisade App; provide you with information and services that you request from us (including technical support in respect of your use of the Palisade App and the Palisade Platform); correspond with you via phone, e-mail or otherwise for the purposes of sending service updates relating to the Palisade App and the Palisade Platform; verify your identity with your employer, on behalf of which you will be accessing and using the Palisade Platform and the Palisade App; and notify you of any activity that occurs (including transactions that are carried out) via your account on the Palisade Platform and the Palisade App.
As is permitted for our legitimate interests, including for the purposes of analysing the use of, and improving, the Palisade App and the Palisade Platform.
As is necessary to enable us to comply with our legal and regulatory obligations.
Sharing of your Personal Data
From time to time, Palisade may share your Personal Data with other entities forming part of the Palisade group of companies and/or third parties. In particular, Palisade may disclose your Personal Data to third parties: in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; if Palisade or substantially all of its assets are acquired by a third party, in which case Personal Data held by us will be one of the transferred assets; if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation; which act as service providers to Palisade, including ComplyAdvantage, Notabene, Xapien, NorthRow; in order to enforce or apply the Palisade Platform and the Palisade App End User Terms and Conditions and/or Wallet Terms and Conditions, or to protect the rights, property, or safety of Palisade, our clients, or others.
Palisade asks all third parties to treat your Personal Data securely and in accordance with the Data Protection Legislation. We will take reasonable steps to enforce this.
International Transfers of Personal Data
[In order to facilitate our international business operations, it may be necessary for us to transfer your Personal Data to third parties located in jurisdictions outside of the UK and European Economic Area (EEA). In such circumstances, we will only transfer your Personal Data to third parties that (a) are located in countries that have been confirmed by the UK Government and/or the European Commission (as applicable) to provide adequate protection to Personal Data; or (b) have agreed (by way of a written contract or some other form of data transfer mechanism approved by the UK Government or European Commission (as applicable)) to provide all protections to your Personal Data as required by the Data Protection Legislation.]
Security of your personal data
The security of your Personal Data is important to us. We comply with accepted industry standards to protect the Personal Data that we hold. We use strict procedures and security features to try to prevent unauthorised access, however, no method of information transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Data.
Storage and retention of your personal data
Palisade will only hold your Personal Data for as long as it is reasonably required to fulfil the purpose for which it was collected and, in any event, for no longer than is permitted by the Data Protection Legislation. This will vary depending on the type of Personal Data and the purpose for which the Personal Data was collected and is being used.
Links to third party websites
[The Palisade App and the Palisade Platform may from time to time contain links to third party websites, such as blockchain explorers, defi app etc. If you follow a link to any of these websites, please note that you will be leaving the Palisade Platform or Palisade App (as applicable) and accessing the website of the third party. These websites have their own privacy policies which determine and explain how they collect and use your Personal Data, and Palisade does not accept any responsibility or liability for any such related policies.]
Your rights
Pursuant to the Data Protection Legislation, you have the following rights that can be exercised in relation to the Personal Data that we hold about you (save where an exemption exists): The right to request and obtain details about your Personal Data that Palisade holds about you; The right to request that inaccuracies about your Personal Data be rectified, and to have any incomplete Personal Data that Palisade holds about you completed; The right to have the Personal Data that we hold about you erased in certain circumstances; The right to object to or restrict the processing of your Personal Data in certain circumstances; and The right to withdraw your consent to Palisade's processing of your Personal Data, in circumstances where the relevant processing is being carried out based upon your consent. If you wish to seek to exercise any of the above right, please contact Palisade using the details set out in Section 10 of this Privacy Policy.
Changes to this privacy policy
Palisade reserves the right to update and amend this Privacy Policy at any time without notice. By continuing to use the Palisade App and/or the Palisade Platform, you agree to the updated Privacy Policy. Any amendments to this Privacy Policy will be made available on the Palisade App and the Palisade Platform and, where appropriate, notified to you by e-mail.
Contact us and complaints
If you have any comments, questions or requests regarding this Privacy Policy, please contact Palisade using the following contact details: privacy@palisade.co If you are unhappy about how Palisade is using your Personal Data, or if you feel that your rights have not been adequately respected, you have the right to complain to the relevant data protection regulator. For the purposes of the United Kingdom, this is the Information Commissioner's Office (ICO), which can be contacted via the ICO website at https://www.ico.org.uk/concerns or via email to casework@ico.org.uk. For the purposes of France, this is the CNIL, which can be contacted via the CNIL website at https://www.cnil.fr/en/plaintes.