Blockchain Industry
Compliance & Regulation
Association

BICRA opens dialog between Blockchain players and Regulators



PRIVACY POLICY

July 2018 V1.2

The Blockchain Industry Compliance and Regulation Association (“BICRA”) believes in protecting your privacy and the confidentiality of your Personal Information. The BICRA website and other Products are designed to be robust portals and collaboration tools that allows for the free flow of information between the BICRA, its partners, its members, and visitors to the Site. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our products and services to you. To this end, we have developed this Privacy Policy to balance the functionality of our Site and other Products with your control over your Personal Information.

Personal information is any combination of information, in the possession of or likely to come into the possession of BICRA, that can be used to identify, contact, or locate a discrete individual (“Personal Information”) and will be treated in accordance with this Privacy Policy. Any information that cannot be used to identify a discrete individual (such as aggregated statistical information) is not Personal Information.

By using this Site, or providing your Personal Information to the BICRA via other Products, you hereby consent to the transfer of your Personal Information to the United States, for the purposes described in this Privacy Policy.

PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

BICRA collects, uses, and discloses your Personal Information in its normal course of business. The information may be used to plan new products or services, gauge customer satisfaction, measure awareness of products or services, or to test reaction to products, services or communications. The Blockchain Industry Compliance and Regulation Association is committed to respecting and protecting your privacy as a research respondent who is participating in a study. This policy explains how BICRA collects and uses data that BICRA obtains via surveys and other primary research methods that BICRA uses. If you are participating in one of BICRA’s research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. Below are the primary uses of this information supplied to us:

WHAT INFORMATION WE COLLECT

The information gathered by BICRA from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and other Products, and (2) tracking information gathered as visitors navigate through our Site.

Information Voluntarily Provided by You

When using this Site, you may choose to provide us with information to help us serve your needs. “Personal Information” or “PI” is information recorded in any form that identifies an individual or can be used to identify an individual. It includes an individual’s name, identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. It may include information about an individual’s personal opinions and preferences.

You provide “PI” to the BICRA in the course of participating in research directly to the BICRA and utilizing BICRA products and services. In such cases, BICRA will comply with the contact limitations and data protections to which you agreed when you provided that permission. The BICRA may collect and use PI obtained from publicly available sources, where this is permitted by law. Most research surveys include demographic questions such as racial or ethnic origin, age, gender or income. BICRA uses these questions to help confirm that the research reflects a representative sample of the population the BICRA is studying. The BICRA also automatically collects information that is made available by the device you use to access BICRA’s website for system administration, surveys, service improvement, data analysis, and data integrity purposes to ensure that survey respondents do not impermissibly duplicate participation in the same survey. The information automatically collected for this purpose, as well as other “PI”, may be shared with third parties for the purposes of detecting and preventing impermissible duplicate participation in the same survey.

Your participation is voluntary. You are entitled at any stage of the interview or survey, research, or afterward, to ask that part or all of your personal data be destroyed. Wherever reasonable and practical, we will carry out such a request.

Below are some additional ways we collect data:

1. When you request content

2. When you register with us and/or join the BICRA as a member

3. When you submit content

4. When you submit a resume


Website Navigational Information

As you navigate the Site, we may also collect information through commonly used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (e.g., browser type, browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).

Like many companies, we may use cookies on this Site. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user. A cookie cannot read data off your computer's hard drive.
There are different kinds of cookies with different functions:

  1. Session cookies: a session cookie is only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
  2. Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
  3. First-party cookies: the function of a first-party cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between BICRA’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
  4. Third-party cookies: the function of a third-party cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.

We use cookies for the following purposes:

Use of Web Beacons

Use of IP Addresses

DISCLOSURE OF INFORMATION TO OTHERS

We do not disclose any Personal Information about you to any third parties except as stated in this Privacy Policy, as otherwise permitted by law, or as authorized by you.

Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:

If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us on info@bicra.org for more information on these third parties.

Affiliate Sharing

In the normal course of performing services for our clients, Personal Information may be shared within BICRA and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third-party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information and the fact that it may be disclosed to third parties such as BICRA, and that they have consented to such disclosure and use.

Service Providers

Because many of the service providers we use are located in the United States, including certain BICRA affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.

BICRA's service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.

Business Transactions

As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. In addition, if either BICRA itself or substantially all BICRA assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.

Other Legally Required Disclosures

BICRA preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site or other Products if BICRA has a good faith belief that such action is necessary to (1) protect and defend the rights, property, or safety of BICRA, employees, or other users of this Site or the public; (2) enforce the terms and conditions that apply to use of this Site; (3) comply with a legally valid request from a competent governmental authority; or (4) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.

In this Privacy Policy, the purposes identified above and in “Collection, Use, and Disclosure of Personal Information” will be referred to as the “Identified Purposes.”

Public Forums

This website or other products may make public chat rooms, forums, message boards, and/or news groups available to you from time to time. We impose terms of use regarding content and activity at such public areas. Further, we monitor and/or edit posts to those areas. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding whether to disclose any personal information via such forum.

CALIFORNIA’S “SHINE THE LIGHT” LAW

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes for the preceding calendar year, as well as the addresses and names of such third parties. BICRA does not share any personal information collected from this site with third parties for their direct marketing purposes.

European Union’s “General Data Protection Regulation (GDPR)” Law

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. In compliance of this law, BICRA does not utilize data for any reasons other than to fulfill commitments to existing products and services. BICRA does not share any personal data or information collected from this site with third parties for their direct marketing purposes. The BICRA has data retention and storage mechanisms in place to control who has access to the data and has placed limits on what purposes the data can be used for.

CONSENT

Your knowledge of and consent to BICRA’s collection, use, and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:

Where BICRA relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. BICRA will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for BICRA to collect, use, or disclose your Personal Information could mean that we cannot obtain insurance coverage or other requested products, services, or information for you.

If you wish to withdraw your consent, please refer to the “Questions or to Withdraw Consent” section below.
However, there are several instances in which BICRA does not require your consent to engage in the processing or disclosure of Personal Information. BICRA may not solicit your consent for the processing or transfer of Personal information for those purposes that have a statutory basis, such as in the following instances:

LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION

BICRA will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose and, subject to your consent (where appropriate), that new purpose will become an Identified Purpose.

BICRA will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.

SAFEGUARDS

We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution, and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and BICRA expressly disclaims any such obligation.

EXTERNAL LINKS

BICRA Sites may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you cannot find the privacy policy of any of these websites via a link from the website's homepage, you should contact the website directly for more information.

ACCURACY, ACCOUNTABILITY, OPENNESS, AND CUSTOMER ACCESS

Our knowing about changes to some of your Personal Information (e.g., email address) may be key to effectively communicating with you at your request. If any of your details change, you can update us by emailing us. Please keep us informed of changes to your Personal Information.

You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete, or incorrect. However, to secure your Personal Information, BICRA does not provide online access to its customers to view or amend Personal Information in its database.

Your Personal Information may also be stored, and can also be accessed, at the local BICRA chapter office with which you are a member.

A copy of this Privacy Policy (and any significant changes) can be obtained from our Web site at  BICRA.org. BICRA is responsible for all Personal Information under its control and has designated a privacy officer who is accountable to Management for BICRA’s compliance with this Privacy Policy.

QUESTIONS OR TO WITHDRAW CONSENT

You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that BICRA provides to you) by either (1) making changes to your profile via our online portal or (2) writing or sending an email to us at the following address:

Blockchain Industry Compliance and Regulation Association
61 Broadway, Suite 1105
New York, NY 10006

info@BICRA.org

We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.

Normally, we will respond to access requests within 30 days.

COMPLAINTS

Complaints can be directed to:

Blockchain Industry Compliance and Regulation Association
61 Broadway, Suite 1105
New York, NY 10006
info@BICRA.org

CHANGES TO THIS PRIVACY POLICY

If there is any material change to your rights under this Privacy Policy, BICRA will provide you with notice of such change 30 days prior to the changes going into effect. As part of this notice, BICRA may post a notice of the change on the site in a clear and conspicuous manner for the 30-day notice period. BICRA may also communicate the change via email or postal mail if this is the way that BICRA normally corresponds with you. Please note that your continued use of the Site or Services once this 30-day period is over, indicates your agreement to the changes that were the subject of the notice.