Privacy Policy

Privacy Policy

Last Updated: June 2022

Please read this privacy policy carefully as it contains important information about RECUR Forever Inc., and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities if you have a complaint.

This privacy policy incorporates by this reference our Terms of Service and any updates and new rules, new polices, and new codes of conduct.  Except as otherwise indicated, any reference to the “privacy policy” shall include the Terms of Service.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our websites, or otherwise), signing this privacy policy, or continuing to use our products or services, you acknowledge that you have read, understood, and agree to be bound by this privacy policy. You “sign” and accept this privacy policy by checking “I agree” on the account creation screen.

This privacy policy may change from time to time and your continued use of our products or services constitutes your acceptance of those changes. We encourage you to review this privacy policy periodically.

If you do not agree with this privacy policy or our practices, you may not use our products or services.

IN THE EVENT OF ANY INCONSISTENCY OR CONFLICT BETWEEN THIS PRIVACY POLICY AND THE TERMS OF SERVICE, THE FOLLOWING ORDER OF PRECEDENCE SHALL CONTROL: (A) THE TERMS OF SERVICE; AND (B) THE PRIVACY POLICY.


1. Personal Information We Collect About You.  

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers

  • Email address
  • Phone number
  • DOB
  • First & last name
  • Billing address
  • Country of residence
  • Display name

Internet activity

  • IP address
  • Referring websites
  • Device fingerprint

2. How Your Personal Information is Collected.

  • From publicly accessible sources (e.g., property records)
  • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers)
  • From a third party with your consent (e.g., your bank)
  • From you, in person
  • From cookies and other website technology

3. How and Why We Use Your Personal Information.  

Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The paragraphs below explains what we use (process) your personal information for and our reasons for doing so:

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Use: To provide NFTs or other products or services to you

Reason: For the performance of our contract with you or to take steps at your request before entering into a contract

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Use: To prevent and detect fraud against you or RECUR Forever

Reason: For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you

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Uses: Conducting checks to identify our customers and verify their identity; Screening for financial and other sanctions or embargoes; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator

Reason: To comply with our legal and regulatory obligations

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Use: Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies

Reason: To comply with our legal and regulatory obligations

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Use: Ensuring business policies are adhered to, e.g. policies covering security and internet use

Reason: For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best products and services to you

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Use: Operational reasons, such as improving efficiency, training, and quality control

Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

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Use: Ensuring the confidentiality of commercially sensitive information

Reason: For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

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Use: Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range, or other efficiency measures

Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best products and services for you at the best price

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Use: Preventing unauthorized access and modifications to systems

Reasons: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you; To comply with our legal and regulatory obligations

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Use: Updating and enhancing customer records

Reasons: For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products and services

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Use: Statutory returns

Reason: To comply with our legal and regulatory obligations

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Use: Ensuring safe working practices, staff administration, and assessments

Reasons: To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best products and services to you

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Use: Marketing our services and those of selected third parties to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.

Reasons: For our legitimate interests or those of a third party, licensors and their agents, i.e. to promote our or their business to existing and former customers

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Use: External audits and quality checks

Reasons: For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; To comply with our legal and regulatory obligations

4. Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone, via our website) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We do not sell your personal information to other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us as described in the “How to Contact Us” section below; or
  • Using the “unsubscribe” link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

5. Who We Share Your Personal Information With.

We routinely share personal information with:

  • Our affiliates, including companies within Recur Forever’s group;
  • Service providers we use to help deliver our products and/or services to you, such as payment service providers and other third party companies;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Our licensors and their agents;
  • Other third parties whose websites you visit through our website; and
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

6. How Long Your Personal Information Will Be Kept.  

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

7. Your Rights Under the GDPR.  

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

8. Your Rights Under the CCPA.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
  • Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, contact us at privacy@recurforever.com with the subject line “Opting-Out.” 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

9. Keeping Your Personal Information Secure. 

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. How to Exercise Your Rights. 

If you would like to exercise any of your rights as described in this Privacy Policy, please email us at privacy@recurforever.com.

11. How to File a GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

12. Children.  

We are committed to protecting the privacy of children. Our products and services are not intended for use by children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are under 18 do not use our products or services or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe that we may have any information from or about a child under 18, please contact us as provided in Section 18 below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.

13. How to Contact Us.

You may contact RECUR at (RECUR may update its contact information in accordance with the terms for modification of this Agreement):

RECUR Forever Inc.

1209 Orange Street

Wilmington, Delaware 19801

Email:  privacy@recurforever.com