Introduction

Pyctor, a project led by ING Bank in collaboration with regulated financial institutions, is a decentralized permissioned network that aims to provide digital asset safekeeping and transaction services, with a focus on regulated security tokens issued either on private or public blockchain.

If you visit our website or in any other way contact Pyctor, we process your personal data. By “processing” we mean everything we can do with this data such as collecting, recording, storing, adjusting, organizing, using, disclosing, transferring or deleting that data.

This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it

As Pyctor is a part of ING Bank N.V., please also refer to the ING Privacy Statement located at ing.com for further information about how ING processes data and your privacy rights and obligations.

The type of personal data we collect

Personal data refers to any information that tells us something about you and that we can link to you. If you contact us, we process personal data such as your full name and email address.

What we do with your personal data

We only use your personal data for legitimate business reasons.

This includes:

• validating interest in Pyctor proposed goods and services;
• contacting you about Pyctor and Pyctor’s proposed initiative; and
• if necessary, to comply with our legal obligations.

Who we share your personal data with and why

We may disclose personal data to third parties like regulators if required to do so by law. When we use other service providers we only share personal data that is required for a particular assignment.

Service providers support us with activities like:

• performing certain services and operations;
• designing and maintenance of internet-based tools and applications; and
• preparing reports and statistics, printing materials and designing products.

Cookies

We use cookies on our website for making the website function properly and analysing use of the website. With this information we can improve and further develop the website.

Pyctor uses Google Analytics to perform statistical analyses about the way you use the services of Pyctor. Google Analytics collects information on how you navigate, how much time you spend on our website, how long you visit a particular web page, from which website you came to our website, type of internet browser you use and the IP address of your mobile phone and/or tablet, and websites you visit after visiting our web site. This information is collected and analysed to improve the user friendliness of our website and to improve our marketing activities.

A cookie is a small text file that is stored by your browser on your computer. On each subsequent visit to the website, the browser searches for cookies. If the browser finds cookies, it sends the information stored by the cookie to the website. The website downloads cookies on your computer, tablet or mobile phone which are strictly necessary for the functioning of the website, such as cookies that ensure that you can retrieve information on the website quickly, and cookies that are strictly necessary to provide a service which has explicitly been requested by you, such as a cookie that remembers your cookie settings. To download cookies that are not strictly necessary, such as cookies for gathering statistical information, Pyctor needs your prior consent.

If you have adjusted your cookie settings so that websites are not permitted to place cookies on your computer, the Pyctor website may not be able to download the cookie which remembers whether or not you consented to the placing of cookies. If so, you will be asked to indicate your cookie preferences each time you visit the website. If you do not wish to be asked about your cookie preferences each time you visit the website, you need to adjust your browser’s cookie settings.

Marketing

We will not use your personal data for marketing or promotional purposes.

Data retention

We are only allowed to keep your personal data for as long as it’s still necessary for the purpose we initially required it. After this we look for feasible solutions, like archiving it.

Your rights

We respect your rights to determine how your personal information is used. These rights include:

• Right to access personal data: You have the right to ask us for an overview of your personal data that we process by sending an email to info@pyctor.com.
• Right to rectify personal data: if your personal data is not correct, you can ask us to rectify your personal data by sending an email to info@pyctor.com.
• Right to complain: Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us. If you are still unhappy with our reaction to your complaint, you can escalate it to the ING Bank Data Protection Officer. You can also contact the data protection authority in your country.

Please refer to the ING Privacy Statement for a full overview of your rights and how to exercise them.

Changes

We may change our Privacy Statement from time to time. The date of the last adjustment was 22 July 2020. Please check our Privacy Statement regularly for the latest version.

This Privacy and Cookie Statement may be modified from time to time to comply with applicable laws or to reflect our updated business practices, so please check this Privacy Statement periodically for any changes.

Regulatory information

Pyctor is part of ING Bank N.V. (‘ING’). ING has its statutory seat in Amsterdam at Bijlmerdreef 106, The Netherlands, Trade Register number 33031431. ING is regulated and licensed by the De Nederlandsche Bank (‘DNB’) and the European Central Bank (‘ECB’) for payment services. ING is also regulated and licensed by the Autoriteit Financiële Markten (‘AFM’) and regulated by the Autoriteit Consument & Markt (‘ACM’). Information regarding supervision of ING can be obtained from DNB (www.dnb.nl), AFM (www.afm.nl) or ACM (www.acm.nl).