Effective: June, 2021
Please note that anonymized information or purely statistical data used by VENT will not be considered personal data.
Who are we?
VENT is a limited liability company of Spanish nationality whose corporate information is:
- Name: VENT FINANCE S.L.U
- TAX ID: B06897995
- Registered Office: Paseo de la Castellana, 43, 28046 (Madrid)
- Registration Date: 14.06.2021
Information and consent
Furthermore, in case of being the necessary legal basis for the processing of your data, your free, informed, specific and unequivocal consent will be requested so that the personal data you provide through the website www.vent.finance (hereinafter, the "Website") and the application launchpad.vent.finance (hereinafter, the "Application") or any forms dependent on the Website and the Application, are processed by VENT, as well as the data derived from your navigation and any other data you may provide in the future.
The data requested in the forms on the Website and in the Application are, in general, mandatory (unless otherwise specified in the required field) to fulfill the purposes for which they are being collected.
Therefore, if the same are not provided or are not provided correctly, the same may not be met, without prejudice to the fact that you may freely view the content of the Website and the Application, except for specific content or certain functionalities of the Website and the Application, limited to registered Users.
What personal data does VENT access about me?
If you register on the Website and/or the Application, we will process the following information about you:
Identification data: full name, full identity document, date of birth (age), gender and image.
Contact and communication data: telephone number, e-mail address and mailing address, country of residence
Browsing Data: The Website and Application servers may automatically detect your IP address, domain name, unique device identifier, browser fingerprint, device fingerprint and cookie IDs when you have set them in your browser.·
Data we obtain from third parties: we may obtain data from third parties such as personal data or information on international lists for the prevention of money laundering and terrorist financing.
Your Wallet’s public address.
If you do not register, but merely browse the Website, we will process the following information about you:
Browsing Data: The Website and Application servers may automatically detect your IP address, domain name, unique device identifier, browser fingerprint, device fingerprint and cookie IDs when you have set them in your browser.
Email: if you consent to receive the newsletter.
Where does the data we process about you come from?
From the User: This is the data that you provide us by filling out forms on the Website and/or the Application, or through any interaction that you make with VENT.
From third parties: such as business partners with whom VENT has signed a collaboration contract, third parties who provide a service to VENT for the effective provision of the service, or data obtained from international lists for the prevention of money laundering. Also VENTmay obtain your personal data from third parties to whom you have provided your information, among others, data available on social networks (Facebook, Google, etc.).
What are the purposes and legal bases for processing the User's data?
We may only process your personal data if we have an adequate legal basis for doing so. We may process your personal data for any or all of the purposes specified below and on the legal bases indicated:
i. Processing Activity and Purpose
Registration and use of the Website and the Application to manage the registration, access and required use of the Website and the Application (contact details, bank details). Respond to questions raised by Users. Use of the products and services, interactions with the Website and the Application. Send you notifications related to the provision of the service or use of the Website and/or the Application.
i. Legal Basis
Formalize the contract between the parties and legitimate interest in providing Users with access to VENT services and the management of its products and services.
ii. Processing Activity and Purpose
ii. Legal Basis
VENT's legitimate interest in diagnosing problems with the servers and in managing the Web Site efficiently.
iii. Processing Activity and Purpose
Marketing purposes, sending commercial communications about VENT products.Improvement of products and services and sending of promotions.
iii. Legal Basis
Legitimate interest in advertising and improving our products and services, unless the user expresses his/her desire not to receive commercial communications (in case of registered users).
User's consent (in case of non-registered Users).
iv. Processing Activity and Purpose
Processing of your image to verify your identity and prevent fraud and money laundering prevention.
iv. Legal Basis
Legitimate interest in preventing fraud and verifying the identity of Users and legal obligation to comply with applicable regulations.
v. Processing Activity and Purpose
Navigation data obtained through cookies to analyse your preferences and improve our products and services.
v. Legal Basis
With which recipients will the User's data be shared?
They may access the personal data of VENT’s Users:
- VENT’s authorized personnel.
- Collaborators who provide services on behalf of VENT in order to manage the provision of services. In this case, such access to data on behalf of third parties will be regulated in the corresponding data processing contract in compliance with the applicable regulations.
- Authorities: We may share certain strictly necessary information with authorities such as the police, tax agencies or other authorities, if required by law.
- VENT’s company in Dubai Vent Platform FZCO as companies belonging to the same corporate group, the transfer of data from the current controller to VENT DUBAI is done on the basis of a legitimate interest in transferring personal data within the corporate group for internal administrative purposes, including the processing of personal data of Users.
Is my data transferred outside the European Union?
As the information will be transferred to VENT’s company in Dubai Vent Platform FZCO, (as both companies belong to the same corporate group and transfer will be made for internal administrative purposes), Users personal data outside the European Union is foreseen. As Dubai is not considered safe, VENT has formalized the corresponding Standard Contractual Clauses approved by the European Commission between the data exporter and importer.
How long will VENT keep the data?
Your personal data will be kept for the time strictly necessary for the purposes of the processing for which they have been provided, and, in any case, following the principle of data minimization provided for in the applicable regulations.
If you are a VENT User, your data will be kept for the duration of your business relationship with VENT and from the moment you exercise your right to cancel your data or cancel your account, your data will be kept blocked for a period of five years in order to meet the legal responsibilities that may arise from the services provided and ten years in the case of conservation of personal data in compliance with the rules of prevention of money laundering.
How can I exercise my rights?
You can (i) send a letter to VENT, at the address indicated in the header of this Policy, (ii) access your User’s area in the Application or the Website; or (iii) send an email to the address firstname.lastname@example.org, attaching a photocopy of your identity document, at any time and free of charge, to:
- To revoke the consents granted.
- Obtain confirmation as to whether VENT is processing your personal data.
- Access to your personal data.Rectify inaccurate or incomplete data.
- Request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
- Obtain from VENT the limitation of data processing when any of the conditions provided for in the data protection regulations are met.
- Request the portability of the data provided in those cases provided for in the regulations. Contact VENT’s DPO at the following address: email@example.com
- In case you consider that the above rights have not been properly addressed by VENT you may file a complaint with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 - Madrid.
In the event that such changes relate to the consent provided by the User, we will send you a separate and independent notice to collect it again.
Privacy and blockchain
Your investment of cryptoassets available through the Website and the App will be recorded on the relevant public Blockchain. Public blockchains operate like ledgers, intended to immutably record transactions on computer system networks. Many of these public blockchains allow forensic analysis that can lead to de-anonymization and inadvertent disclosure of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks that are not controlled or operated by VENT, we cannot delete, modify or alter personal data on such networks.
VENT: VENT FINANCE, S.L.
VENT Group: Vent Platform FZCO
Blockchain: the decentralized and distributed public network that VENT uses in each case for the proper provision of the Service.
Platform: www.vent.finance, launchpad.vent.finance and equivalent mobile application through which the User accesses the Services.
Service/Services: sale of platform tokens, provide information of blockchain projects and enable social interaction.
Wallet: set of cryptographic elements that allow the custody of the balance of Cryptoassets deposited in it by a single User.
Cryptoassets: digital assets issued through computer protocols and not backed by an entity or Central Bank. For the purposes of these Terms and Conditions, the following digital assets shall be considered Cryptoassets: VENT tokens.
User: natural person registered on the Platform who accesses the Services.
Welcome to the VENT web and mobile application (the "Platform", or "we" or "us" collectively). Below, we will detail the license agreement that governs the terms on which you, as a User, may use the Platform and the Services offered therein:
This document (together with all documents referred to herein) sets forth the terms and conditions governing your use of this Platform www.vent.finance and your use of the Service provided through this Platform ("Terms and Conditions").
If the User has any questions regarding the terms and conditions or the Privacy and Cookies Policy, he/she can contact us through our contact channels.
2. LEGAL INFORMATION
In compliance with the duty of information contained in Article 10 of Law 34/2002, of July 11, of Services of the Information Society and Electronic Commerce, the following data of the owner are reflected below:
- Name: VENT FINANCE S.L.U
- TAX ID: B06897995
- Registered Office: Paseo de la Castellana, 43, 28046 (Madrid)
- Registration Date: 14.06.2021
3. USERS AND CONSENT
The use of the Platform attributes the condition of User, who accepts, from the access, download and / or use of the same, the Terms and Conditions reflected here.
To make use of the Services offered on the Platform, the User must be over 18 years of age.
In the event that a minor under 18 years of age accesses the Platform, the parent or guardian of the minor shall be responsible for such access and use.
Likewise, the User declares that the use of this Platform is done on a personal basis, without performing any type of professional service.
The Platform will allow the User to access the Services specified in these Terms and Conditions.
Before making use of the Services, the User must take into account that the risk of loss in the purchase and sale or holding of Cryptoassets may be considerable. As with any asset, the value of Cryptoassets can vary considerably and there is a substantial risk of losing money buying, selling, holding or investing in Cryptoassets. Therefore, by using the Platform, the User acknowledges and accepts the risks involved in buying and holding Cryptoassets.
Likewise, by using the Platform the User accepts that VENT does not provide any kind of investment advice in relation to the Cryptoassets that can be purchased through the Platform, but will only provide information on projects in which it is involved, which in no case shall constitute financial or investment advice and shall not be construed by the User as such. Any decision to purchase
Cryptoassets is the sole decision of the User, and VENT shall in no event be liable for any loss suffered as a result of such decision.Cryptoasset services are not currently regulated by the financial authorities nor do they fall under the umbrella of protection that may be offered by financial services clearing schemes in Spain, therefore, the User should carefully consider whether trading or holding Cryptoassets is appropriate.
4. USE OF THE PLATFORM
VENT offers through the Platform the Services specified in these Terms and Conditions, which consist of (i) information about projects based on Blockchain technology; (ii) the possibility of acquiring VENT tokens through the Platform; (iii) access to certain projects based on Blockchain technology by virtue of the points obtained by the User as a result of the maintenance of VENT tokens; (iv) the User can interact with projects by upvoting and commenting and can interact with others Users within specific project related forums/chats .
The User assumes responsibility for the use of the Platform. This responsibility extends to the registration required to access the Services. In such registration the User shall be responsible for providing truthful and lawful information.
In the event of obtaining VENT Tokens, the User will be required to provide the personal data necessary for his or her effective identification, as well as the corresponding supporting documentation, in order to prevent any potential money laundering and terrorist financing behaviour and to be able to adopt appropriate due diligence measures. The User irrevocably undertakes to guarantee that the information provided is truthful. In the same way, the User must complete the responsible declarations that may be requested in each case.
VENT reserves the right to request that the information be updated if it becomes aware that it has undergone any modification. Similarly, VENT reserves the right to make the appropriate checks in order to confirm the legal origin of the contributions of funds that are made. If it becomes aware of irregularities in the registration process and in the subsequent use of the Platform by the User, VENT will proceed to take action for the purpose of preventing any conduct to prevent money laundering and terrorist financing.
In the registration process, the User will be provided with a password, for which he/she will be responsible, committing to use it diligently and confidentially.
In the event of unauthorized access to the User's account, the User agrees to immediately notify VENT through the means of contact made available to the User and indicated in these Terms and Conditions (firstname.lastname@example.org).
The User undertakes to make appropriate use of the content and services that VENT offers through the Platform and, by way of example but not limited to, not to use them for (i) engaging in illicit or illegal activities or those contrary to good faith and public order; (ii) disseminating content or propaganda of a racist, xenophobic, pornographic-illegal nature, in support of terrorism or against human rights; (iii) cause damage to the physical and logical systems of VENT, its suppliers or third parties, introduce or disseminate computer viruses or any other physical or logical systems that are likely to cause the aforementioned damage; (iv) attempt to access and, where appropriate, use the email accounts of other Users and modify or manipulate their messages.
5. DISCLAIMER OF WARRANTIES AND LIABILITY
VENT reserves the right to interrupt access to the Services at any time and without prior notice, whether for technical, security, control, maintenance, power failure or any other justified cause. Consequently, VENT does not guarantee the reliability, availability or permanent continuity of the Platform or the Services, so that the use of the same by Users is carried out at their own risk, without, at any time, VENT can be held liable in this regard.
Furthermore, VENT assumes no liability whatsoever arising from, including but not limited to:
The use that Users make of the materials available on the Platform, whether prohibited or permitted, in violation of intellectual property rights and / or industrial content of the website itself or third party portals.
For possible damages to Users caused by a normal or abnormal operation of the search tools, the organization or location of the contents and/or access to the Services and, in general, of the errors or problems generated in the development or instrumentation of the technical elements that form the Service.
Of the contents of those pages to which the Users can access from links included in the Platform.
The acts or omissions of third parties, regardless of whether these third parties may be contractually bound to VENT.
Similarly, VENT excludes any liability for damages of any kind that may be due to the presence of viruses or the presence of other harmful elements in the contents that may cause alterations in computer systems, as well as in the documents or systems stored therein, so that VENT shall not be liable in any case when they occur:
Errors or delays in accessing the Services by the User when entering his/her data in the corresponding form or any anomaly that may arise when these incidents are due to problems in the Internet network, acts of God or force majeure and any other unforeseeable contingency beyond the good faith of VENT.
Failures or incidents that may occur in communications, deletion or incomplete transmissions, so that there is no guarantee that the Platform Services are constantly operational.
Errors or damages caused to the website or the application due to inefficient and bad faith use of the Service by the User.
Non-operability or problems with the email address provided by the User to send the requested information, or with the mobile telephone networks.
In any case, VENT undertakes to solve any problems that may arise and to offer all the necessary support to the User to reach a quick and satisfactory solution to the incident.
6. PURCHASE AND SALE OF VENT TOKENS THROUGH THE APPLICATION
The availability of certain services (access and participation in blockchain projects proposed by VENT) will depend on the points the User has which will depend on the following objectives:
1. How many vent tokens the user is staking
2. How long the user has been actively staking vent
3. How many vent tokens are staked on the network in total
4. The inflation rate
5. Other factors
The User will be informed in any case of the number of points required to access such projects.
VENT tokens may be purchased in exchange for MATIC cryptocurrency.
Any transaction shall be subject to the User reading and accepting the Terms and Conditions of the Platform.
In the event that, due to certain circumstances, VENT is unable to complete the orders placed, the User will be notified by means of the notification service.
Transactions are subject to the exchange rate as displayed on the Platform, that is the USDC MATIC or ADA cryptocurrency equivalency of the value of VENT Tokens, and which represents the purchase price that is updated on an ongoing basis. However, VENT cannot guarantee the purchase of VENT Tokens at any particular price or at any exact time.
When the User makes a purchase of VENT Tokens through the Platform, a popup with the confirmation and the link to Polygonscan will appear.
The User should verify that the details in the confirmation email are correct as soon as possible.
By clicking on "Confirm transaction" the User authorizes to start the transaction. Cancellations are not allowed.
On the other hand, VENT does not own or control the underlying software protocols that govern the operation of the Blockchain linked to the VENT tokens supported by the Platform. For the most part such protocols are open source or open source and may be used, copied, modified and distributed by any third party. Accordingly, VENT assumes no responsibility for the operation of such protocols nor does it guarantee their functionality, security or availability.
7. USER PROHIBITIONS
Without the list being exhaustive, the User undertakes to refrain from performing the following actions, either directly or through a third party:
- Use the Platform, the Services or any of its contents in a manner or for purposes that VENT considers different or contrary to these Terms and Conditions, laws, morals, good customs or public order.
- Use the Platform to send, reproduce or publish files or any type of information whose content is obscene, abusive, defamatory, libelous, slanderous, pornographic, political or contrary to law, morals and good customs, or that contains malicious software such as viruses, worms or that contains any other feature capable of destroying or damaging the operation of an electronic device, the Platform, or VENT systems or servers, or a third party.
- Use the Platform to send, reproduce or publish files in violation of intellectual property rights of third parties.
- Exploit or exploit an attack on the Platform, or a vulnerability or bug in the Platform, for your own or a third party's benefit.
- Use the Platform on behalf of or for the account of any third party or permit any person other than the User (including, without limitation, through assignment, license or transfer) to use your account and the Services associated with your account.
- Use automatic or manual programs, software or devices to monitor or copy the information or any type of content or element of the Platform.
- Linking the Platform or the Services in any way to unsolicited promotions, political campaigns or commercial messages (SPAM) or any chain letters or messages with untruthful content for personal or third party gain.
- Perform actions that restrict, deny or prevent third parties, access and use of the Platform, as well as the content and services offered through it.
- Attempt to violate any authentication and security systems of the Platform.
- Attempt to obtain any kind of material or content accessible through the Platform using procedures or means other than those that, as the case may be, have been expressly indicated or made available to the User.
- Include frames, links, deep links, or links to the Platform, either from other websites or from any software or electronic device.
- Take any action that imposes a disproportionate or unreasonable burden on the Platform's technological infrastructure.
- Use meta tags or any other type of hidden text with the name "VENT", or any other name or trade name and/or intellectual property rights that belong to or are owned by VENT.
VENT reserves the right to deny or withdraw access to the Platform and/or the services offered therein without prior notice to those Users who perform any of the actions indicated in this section.
8. ACCOUNT TERMINATION AND CLOSURE REQUEST
The User may request the cancellation of his/her user account through the Platform, or via email to email@example.com only from the email address with which he/she registered.
The contractual relationship shall not be considered terminated until VENT has cancelled the account, terminated the User from the Platform and notified the User of the termination.
The document number and e-mail address associated with the User will remain blocked, so that no other person will be able to create a new user account using them.
9. SECURITY. PASSWORD RECOVERY
In line with the provisions of these Terms and Conditions, VENT assumes that any movements made in a User's account have been made by the User, and therefore the User acknowledges and agrees to be solely responsible for the use made of his or her account and for the direct and indirect consequences and damages arising therefrom.
In the event that the User detects that his/her account has been attacked or that a third party has made transactions through the account, he/she must notify VENT as soon as possible in order to proceed to block the account by sending an email to the following address: firstname.lastname@example.org.
In case the User forgets or loses his/her password, he/she can recover it by the means available through the Platform, or contact VENT by sending an email to the following address: email@example.com
10. RIGHT OF WITHDRAWAL
Pursuant to Article 103 of Law 3/2014 of 27 March, the transactions contained in the present terms and conditions are excluded from the right of withdrawal.
11. MODIFICATIONS TO THE TERMS
VENT may modify at any time the conditions set forth herein, being duly published on the Platform and/or, at the sole discretion of VENT.
The User's use of the Platform and the modification of these Terms and Conditions shall constitute the User's full acceptance of these Terms and Conditions; if the User does not agree to the new terms, the User shall cease using the Platform.
12. INTELLECTUAL PROPERTY
All content on the Platform, including without limitation the design of its screens, promotional materials, trademarks, trade names, trade dress, text, graphics, logos, images, icons, buttons, videos, sounds, music, databases, source code, software and color schemes (hereinafter, the "Content"), is owned by VENT or its licensors.
The Content may not be reproduced, modified, transformed, edited, translated, transferred, distributed, represented, marketed, publicly communicated, stored, used for purposes other than those provided for in these Terms, or be the subject of derivative works, without prior written permission of the rights holder.
Your access to the Platform does not grant you any license, right or title to any intellectual property rights in all or any portion of the Content. Users are granted only a non-exclusive, revocable, limited license to access and use the Platform in accordance with these Terms and Conditions.
If the User considers that the Platform or the Content violates any intellectual property rights of third parties, he/she must notify VENT at the address indicated in these Terms and Conditions, attaching all the necessary information and documentation to support the aforementioned consideration.
VENT is committed to the fulfillment of the obligation of secrecy of personal data, therefore it has adopted the necessary measures to avoid its alteration, loss, treatment or unauthorized access, taking into account at all times the state of technology.
14. PRIVACY AND BLOCKCHAIN
Cryptoasset investments can be recorded on a Blockchain or public blockchain. Public Blockchains operate like ledgers, intended to immutably record transactions on networks of computer systems. Many of these public Blockchains allow forensic analysis that can lead to de-anonymization and inadvertent disclosure of private financial information, especially when blockchain data is combined with other data.
15. APPLICABLE LAW AND JURISDICTION
For any interpretative or litigious issues related to the web portal or the app, Spanish law shall apply and in case of dispute, both parties agree to submit, waiving any other jurisdiction that may apply, to the jurisdiction of the Courts and Tribunals of the city of Madrid (Spain) provided that such dispute is not related to any economic transaction, which will be resolved through the jurisdiction of the Courts and Tribunals of the domicile of the consumer or by filing the appropriate claim by filling out the following electronic form: http://ec.europa.eu/consumers/odr/
Under no circumstances shall VENT assume any responsibility for the contents of any link belonging to an external website, nor shall it guarantee the technical availability, quality, reliability, accuracy, comprehensiveness, truthfulness, validity and constitutionality of any material or information contained in any such hyperlinks or other Internet sites. Likewise, the inclusion of these external connections does not imply any type of association, merger or participation with the connected entities.
It is expressly forbidden to introduce hyperlinks for commercial purposes on websites not belonging to VENT that allow access to the Platform without the express consent of VENT. In any case, the existence of hyperlinks on websites outside VENT, does not imply in any case the existence of commercial or mercantile relations with the owner of the website where the hyperlink is established, nor the acceptance by VENT.
In the event that one or more clauses of these Terms and Conditions are declared null and void by any competent authority or judicial body, such nullity shall not affect the validity of the remaining clauses, which shall remain in full force and effect.
VENT may assign its contractual position, this contract, and/or any of the rights and obligations arising from this contract to any of the companies of the VENT Group or to a third party.
The User may not assign its contractual position, this contract, or any of the rights or obligations arising from it to any third party, unless VENT grants its written consent for such purpose.
19. CONSENT TO ELECTRONIC NOTIFICATIONS
The User expressly consents to be notified or informed by electronic means of any information related to his or her User status, account and use of the Platform.
20. CONTACT & CUSTOMER SERVICE
VENT has a Customer Service Department, from Monday to Friday from 10 am to 6 pm, by sending an e-mail to the following address: firstname.lastname@example.org