POMZ Privacy Policy

Last updated: May 24, 2018.

This is a Comprehensive Privacy Policy that highlights the different methods that POMZ LC ("POMZ"/we/us/our, as appropriate) employs for gathering, storing, using, and managing the data and statistics that you provide to us. In addition, it includes the information that POMZ collects whenever you use the Website. When you decide to submit your personal details to us and use our website, you're deemed to have agreed to the terms and conditions of our Privacy Policy.

In doing so, you also permit us to process the Information you submitted, which includes personal details, as per the terms of this policy. In the event that you aren't in agreement with the policy terms, please refrain from using the website.

1.   Definitions

Let's begin by defining the most important terms that you'll encounter in our privacy policy:

  • Terms: this refers to the POMZ Terms of Use;
  • User/you: the term refers to people who are users of the Website;
  • Website: this refers to the site that you will find at https://pomz.com. It comprises the subdomains, guide, programming code, databases, design, and the pertinent related technologies;
  • Personal Data: this entails information, which in sufficient quantity will be used to identify you as an individual, such as your full name;
  • Usage Data: this term is used to describe your usage of the website, information that can't be used for personal identification. This information can be used alone or together with other related information, but can't be used for identification purposes;
  • Information: This is a collective term that is used to describe any information, Personal Data, or Usage Data that are publicly available, as well as any other information that is protected.

2.   Personal Data

In order for a future user to obtain access to the website and use it, he or she will have to undergo the KYC check and participate in the token sale. This is to be done in accordance with the POMZ KYC Policy. Furthermore, we might process or collect from you the details listed below:

  • First name;
  • Last name;
  • Email address;
  • Residential address;
  • Date of birth;
  • Identification document, proof of your source of funds, and proof of residency.

These details include copies of your national ID card/passport and your utility bills). We will also process the data contained in these documents, which include your physical address, gender, landline number, and mobile phone number.

In the case you decide against submitting your personal data, we will be unable to offer some or all our products and services to you.

3.   Usage Data

With an eye to render operation of the website more convenient, we usually collect Usage Data each time you access it, even if you are not a registered user/or have not logged in as one. These data are collected from your browser, computer, and mobile device. By using Google Analytics along with other analytics services, we automatically collect details such as:

  • Your IP address;
  • The serial numbers or IP address of your device;
  • The device type that you use;
  • The browser type you use, the language it’s in, as well as the version you’re using;
  • The version and type of the operating system that you use;
  • The number of people who visit the website and the frequency at which they visit the website.

In addition to the details listed above, we also collect the details from all the transactions that you carry out through the Website, records of your internet communication, and the details of your visits and activities on the website.

4.   Cookies and Other Tracking Technologies

A cookie basically refers to a small segment of text that's sent to the user's browser via the website that they have visited. Cookies are important, as they help websites remember the details of your visit. This function will render your experience on the website more convenient, since the stored data help us personalize it. POMZ employs both persistent cookies and session cookies. Persistent cookies refer to cookies that still remain after you close your browser. This type of cookies is engaged in personalizing your subsequent visits to the website.

Cookies can also be removed by just following the directions on your browser’s help file. Yet another type of cookies is session cookies, which are temporary and usually disappear after the browser is closed.

POMZ uses its own persistent cookies to:

  • Retain your preferred choice of which cookies to use on the Website;
  • Recognize you any time you pay a visit to the website;
  • Retain your personal preferences;
  • Perform certain important security measures.

We also work with particular reputable companies that can employ their own cookies when people visit this Website. This type of cookies is called third-party cookies. These third-party cookies can be used for counting the total number of visitors that we receive on a page and assist us in analyzing the way the website is used (for instance, Google Analytics cookies). The information that we collect in this fashion is used for compiling reports and helping us improve the website. Cookies usually collect these data in anonymous fashion. This includes tracking of the number of people who visit the website, their location, as well as the webpages that they’ve visited. A good number of browsers will allow the user to control most cookies in the browser's settings. In such instances, you will be in a position to reset the browser to automatically reject all cookies. Alternatively, you can also reset the browser for indication of when cookies are being sent. However, it's important to remember that certain website features might not function well if you disable cookies. By choosing to browse without disabling or blocking cookies, you will have agreed with our use of cookies in accordance with the stated terms. You also grant us permission to use any Information collected using these technologies. In the case that you disagree with use of cookies on the website, please make sure that you've blocked or disabled them. We don't use cookies to store any Personal Data. Instead, POMZ uses local storage, an industry-standard technology which enables us to locally store Information according to your mobile device or computer. We might also use local storage to store Information on your authorization credentials or personal preferences.

5.   Use of Google Analytics and Related Third-Party Services

Google Analytics is used for the purposes of collecting information on your use of the website. Google Analytics generally collects a wide range of information like the frequency of people’s visits to the site, the specific pages that are visited, and other websites that users went on before visiting our website. The information that we receive from Google Analytics is only used for improvement of the website. Google Analytics doesn't collect your name or any other personal identification information. The only information that they collect is the IP address that's assigned to you when you visit the website. The information that's collected with the help of Google Analytics won't be combined with your Personal Data.

Even though Google Analytics usually places a permanent cookie on the web browser for identification purposes, when you visit the website later, the cookie can only be used by Google alone. Google’s ability to use/share information from Google Analytics during your visits is restricted by the Google Privacy Policy and the Google's Analytics Terms of Use. Google Analytics uses cookies for defining user sessions. This provides a basis for data collection on how visitors are using the website. Google Analytics uses first-party cookies for data analysis only. This simply means that cookies are usually linked to a certain website domain, and Google Analytics  uses those cookies data only for analysis purposes in relation to your browsing patterns on that website.

According to Google, the data collected cannot be retrieved or altered by other domains. You must disable cookies on your browser if you want to prevent Google Analytics from identifying you on subsequent visits. To decline being tracked by Google Analytics across other websites, visit Google Analytics' Opt-Out page. However, we might still use other analytic tools that operate in the same manner as Google Analytics.

6.   Why We Collect Information

The information that we collect is used for:

  • Providing you with the opportunity to take part in the POMZ token sale and payment processing;
  • Creating, operating, and handling your account;
  • Verification and identification purposes;
  • Monitoring your own transactions to prevent fraud, deception, and money laundering;
  • Statistical and analytical purposes;
  • Your interaction with our website;
  • Website security;
  • Recording the ways in which you interact with the website;
  • The development or improvement of the Website;
  • Regulatory and legal purposes, which include the enforcement of our Terms and Policy;
  • Sending you information that's related to our services.

These include promotions, newsletters, updates, security alerts, special offers, and confirmations. Using your email address and name, we will send you information on products, alerts, promotions, and bonuses related to our products/services on a regular basis. However, you can decide to opt out of these notifications at any time.

7.   How Long We Retain Information for

The time period that we will retain your details for depends on our intended purposes of use. We will keep the Information as long as you are still a User. Thereafter, we will keep the information for a period that's reasonably required for reconciliation and reporting purposes with regards to legal requirements. The period should be enough to offer you any information or feedback that you might require or request.

8.   Your Consent

You must express your consent to our collection, transferring, processing, storage, and disclosure of your information, as it's required in the POMZ privacy policy. Consent to the terms is required when:

  • You register with POMZ;
  • You provide information to POMZ via the website;
  • You use and browse the website.

Your use and interactions with our website enables you to consent to our subcontractors and suppliers. This information is normally collected via an automated fashion, such as local storage, cookies, or the projected functionality of our website. There is normally a subsequent use and processing of your information that is in agreement with the POMZ Terms and Policy. They include:

  • The transferring and processing of your Personal Data if you are outside the European Economic Area;
  • The transfer and storage of your personal data to facilities to which we and our service providers have access.

9. Legal Arrangements for the Protection of Your Data

If you want to view, change, or get access to the personal data we store from you, you are free to do so each time you log onto the website, using your login and password.

If you would like to delete your account, along with all your personal data, please send us an email to [email protected] and request it. Remember that your request must follow POMZ, LLC’s Terms and Conditions to the full extent for us to fulfill it.

Legal arrangements for users located in the EEA

  • The privacy regulations introduced in the EU may provide additional rights to users within the EEA. These laws imply that you have the right to enquire about additional information on the personal data we retain or you can apply for the deletion of your personal data under applicable circumstances. If you want to exercise your right, you can email us at [email protected];
  • You can enquire about the kinds of data we deem to be your personal details, check your personal information, or introduce corrections;
  • You can write a request to the email above and we will follow your instructions free of charge in the case that they are technically feasible.

You are entitled to instruct us to:

  • Delete your information, limit its processing, or cease use of it by writing to us;
  • Transfer your information or forward it in any other way to you or any third party by informing us;
  • Or you can make a complaint about the way we are processing your information by forwarding the complaint to us. Alternatively, you are entitled to send your complaint to your local authority responsible for data protection.

If you provided your consent to your data being collected by our website, this action can be reversed at any time by forwarding to us the corresponding request. However, if you opt to do so and retain the status of a user or buyer, we will have to deny your request as we need some data in order to process your transactions. This means that in the case that you want to cancel your consent to the collection, use, and storage of your information on our website, you will not be able to participate on the platform as a user or buyer and we will have to cease rendering services to you as soon as we receive your consent withdrawal, as this action shall deprive us of the appropriate means of interacting with you through the Platform or Website and disable the technical features of the Platform that serve essential purposes.

10. The Way We Implement GDPR

We hereby acknowledge our full respect for and compliance with the EU General Data Protection Regulation (GDPR) where applicable. GDPR classifies us as a controller of personal data, including your personal data and the personal data of all Users and Buyers of the Platform, which imposes certain obligations on us and we undertake to take the appropriate technical and organizational measures to meet the requirements of the GDPR and render efficient protection of the rights of all users and buyers on the Platform within reasonable boundaries. Furthermore, we reserve the exclusive right and power to select, authorize, and revoke the authority of data processors to handle personal data, including the personal data of all Users and Buyers. We are entitled to provide data processors access to personal data.

There are cases when we receive your personal data from third parties and act as data processors of your personal data, and in doing so we follow the provisions set forth in this Privacy policy.

European Union residents have extended data protection rights in addition to the terms of this Privacy Policy. These rights include:

  • You are entitled to gain access to, introduce corrections to, and update or ask us to delete your personal details. To do so, you need to send us an email to [email protected]. You must bear in mind that the deletion of your personal details may impose limitations on your use of the services rendered by the platform and render some features of the Website unavailable to you;
  • Moreover, you can express objections to the way we process your personal data and ask us to limit the processing of them or make them portable, i.e. to transfer the personal information you provided to us to any third party of your choice, as indicated in your request. To exercise this right, you can send an email to [email protected], stating your request. However, when we comply with the request it may lead to limited functionality of the website, rendering some Services and technical features inaccessible to you. We must point out that once your personal data are transferred we bear no responsibility for them or the results of the transfer;
  • If you don’t want to receive the newsletters, marketing messages, or notifications we send, you are entitled to opt out of them. To exercise this right, you can follow the “unsubscribe” or “opt-out” link we enclose in each of our marketing letters. If you want to opt out of other forms of marketing, forward your request to [email protected]. You should bear in mind that in this case you may find that you may fail to receive certain significant information for which we bear no responsibility;
  • Should you choose to withdraw your consent to the use of your personal data, contact us to launch the process and, as your data controller, we commit to following your instructions even in the case that your data are stored on the data processors’ server. As soon as we receive the request, we will initiate the process of erasing the data you wish to be removed from our servers and/or instruct the data processors to erase the data you wish to be removed from their servers. Any processing of your data conducted while your consent was still active remains lawful. Furthermore, withdrawal of your consent to the processing of your personal information shall not obstruct processes of your personal data’s processing taking place following legal regulations, regardless of your consent.

You retain the inalienable right to file a complaint on how we process and store your personal details to a data protection administrative authority. If you would like to learn more, you can contact your local data protection administrative authority.

You are welcome to email us at [email protected] in the case that you have questions or requests regarding your data protection rights.

All individuals who write to us in order to exercise their rights concerning data protection will receive a reply from us in compliance with applicable law.

11.   Information Disclosure

Information concerning your use of our website may be released:

  • To offer you the functions and services of our Website;
  • If it's set out in accordance with the policy;
  • In the event that we believe the release to be in good faith and it complies with a government request, such as a subpoena, court order, legal process, regulation, or applicable law;
  • To detect, investigate, and prevent any fraud or money laundering issues;
  • To reinforce the POMZ Policy or its Terms;
  • To prevent, detect, or address technical or security issues;
  • To protect the website against unlawful or abusive users;
  • To safeguard users' property, safety, or rights against any third party;
  • If there is a dangerous situation involving injury or death, thus justifying disclosure;
  • If there are other bases described in the POMZ policy and terms.

12.   Who We Share Your Information with

Information collected from you may be shared only under the circumstances described in the terms and conditions of the POMZ policy. We won't share Personal Data that you provide with any third party except if it's within our subsidiary or associated companies. We also share them with suppliers or service providers under an agreement that deals with the ways in which they assist our business operations, such as analytics, information management, fraud investigation, user verification, compliance, and the payment process. Such service providers are restricted from sharing or disclosing your Personal Data and only allow use of it when it's necessary for providing their services to us. We may at times disclose and make inquiries as to your Personal Data to security organizations, agencies, or any other third party endowed with the corresponding powers for money laundering and fraud prevention.

13.   The Security of Your Personal Data

We take commercial and reasonable precautions for the protection of your Personal Data against unauthorized access, alteration, destruction, disclosure, abuse, and loss. We process all of your information, using our industry-standard techniques. We employ the following physical, technical, and administrative measures to protect your Personal Data:

  1. Administrative measures: your Personal Data access is limited to only authorized personnel with a genuine need to access it due to their job descriptions. If a third party contractor processes your Personal Data on our company's behalf, we will impose the same requirements on them;
  2. Technical measures: your Personal Data is transferred in an encrypted format with the use of SSL technology. We employ an up-to-date protection firewall, a high quality antivirus, and antimalware software;
  3. Physical measures: your Personal Data cannot be accessed via the internet except with the use of an encrypted private network. We keep your Personal Data on servers provided by a third party that hosts vendors whom we have already contracted. However, we don't warrant and guarantee that the techniques will prevent totally unauthorized access to the information that we store with your Personal Data included;

14.   Business/Asset Transfer

In the event that an asset of ours or our business is sold, transferred, or merged with another business, your Personal Information will be among the assets transferred and we won't be obliged to tell you or require your permission to transfer the information.

15.   Modifications

We reserve the right, based on our sole discretion, to revise, put into effect, and modify the policy at any time by just revising and posting it on our website. The policy and any changes made to it enter into legal force on the day the revised policy is posted. In the case that any substantial changes are made to our policy, we will use all the possible means to let you know by placing a notice on our website or notify you via email. We therefore recommend that you review the policy every time you visit the website. This will keep you updated on the terms of the updated policy. By continuing use of our website, you acknowledge that you have accepted the changes brought into effect.

16.   Updating and Changing Your Personal Data

We take reasonable steps to ensure that the Personal Data we store from you is up-to-date, complete, and accurate. This heavily depends on you informing us in the case you make changes to your information. We recommend that you contact us or log onto your account as soon as possible in the case that you make any changes to your Personal Information. Or, if you think the personal data that we have on you is incorrect, not up-to-date, or incomplete, please inform us so that we can record them and update them accordingly.

17.   Privacy-Related Inquiries

If you're concerned with the way we use your Personal Data or you have any question concerning the way we handle privacy on the website, please contact us at [email protected].

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