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Privacy and data protection are important for ICO Headstart Foundation and all legal entities involved with the MOAT Token and the platform it runs on (all together “ICO Headstart”). Protecting information which is stored on ICO Headstart systems or provided to us and relating to individuals is key. We collect “Personal Data”. This means any information relating to an identified natural person, or identifiable natural person on the basis of the data provided to us or stored and processed by us, or for us.

This Data Protection Policy informs how we ensure privacy and the confidentiality of Personal Data. We undertake all legally required measures to be compliant with applicable privacy laws in the jurisdictions we are active. ICO Headstart is committed to maximizing your experience on its website and its systems in accordance with the General Data Protection Regulation (GDPR). This policy describes the information we gather, how we may use those Personal Data, the circumstances under which we may disclose such information to third parties and what we undertake to be compliant with applicable privacy laws in the jurisdictions we are active


When you access or use the ICO Headstart website or communicate with us, we may collect some information, including: your email address, virtual currency addresses, mobile phone number, alias, password, mobile PIN code, and any other information you choose to provide. In addition we may also log information, including use of the services, the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to us and features of your mobile device and network used to access us online.

We may also obtain information from other sources and combine that with information we collect through our services. We may use third-party services co-branded as ICO Headstart. We will personalize your online experience with us by applying “cookies”, small text files stored on your computer to make the site more useful by providing us. Any Personal Data collected through cookies will be treated in accordance with this Data Protection Policy. If you have set your browser to warn you before accepting cookies, you should receive a warning message with each cookie. You may refuse cookie by turning them off in your browser, however, you should be aware that our site, like most other popular sites, may work less well when cookies are disabled.


ICO Headstart only collects data when there are legal ground to do so. These legal grounds consist of:

  • The performance of a contract
  • In case there is a legitimate interest: for example, when the processing enables us to enhance, modify, personalise, or otherwise improve our services to the benefit of the websites users. Or, to enhance the security and protection of our services and for marketing purposes.
  • Based upon your consent: for example, when you contact us through our websites chat function or when subscribed to our newsletters


Save for exceptions under law where we will notify if legally allowed, we will not use your Personal Data without your consent and only use/process/or disclose Personal Data internally in order to:

  • Determine your preferences;
  • Improve on service and product;
  • Manage and develop our business and operations;
  • Be compliant with relevant laws, rules and regulation ICO Headstart is subject to from time to time in its jurisdiction.

We also reserve the right to use aggregated Personal Data not relating to any individual and such Data may be collected, stored and/or processed by third party service providers or by affiliated entities to perform functions on our behalf. All subject to this Data Protection Policy.

Occasionally, we may employ and share your personal information with vendors who use it solely to provide support for the internal operations of our website (e.g., technical support and network delivery) or social features of our products. These entities will not use your personally identifiable information for any other purpose, and have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us.

Except when required by law or subject to a lawful exception or consent, we will require any person to whom we provide Personal Data to agree to comply with our Data Protection Policy as it reads from time to time. We will require any third party, seeking access to data we hold to have obtained a Court Order of a court, or proof that they are legally allowed to access your data and that the request is valid and within their respective powers.


We will not use/collect/ or disclose Personal Data outside of the purposes of which we have informed you in this Privacy Policy. So far as it is under our reasonable control we shall ensure that your Personal Data is accurate and up to date.


Appropriate safeguards and security measures are in place. Please note however, your Personal Data comes to us via the internet and as such we cannot give any warranty or assurance that the means where information is conveyed to us are safe, reliable or have integrity.

We audit our procedures and security measures regularly to ensure they are effective and appropriate. Our site has security measures in place to protect against the loss, misuse and unauthorized alteration of the information under our control. The length of time we retain Personal Data outside back up systems varies depending on the purpose for which it was collected and used. This period may extend beyond the end of the particular relationship with us but only for so long as we are contractually bound to do so, or so far as is necessary for audit or other accounting purposes. When Personal Data are no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form. We reserve the right to maintain your Personal Data as part of our standard back up procedures.


Personal Data is stored in accordance with applicable laws of the jurisdiction of the data subject, at secure locations in the EU and appropriate security standards are in place. In regard to data subjects resident in the EU, where required, we will register with appropriate national data protection / information protection authorities.


Your rights regarding the information ICO Headstart collects:
As a subject have the following rights:

  • The right of inspection. This means that you can request access to the personal data we have collected from you. We will send you your data in a .csv-file.
  • The right to rectify your data if it is incorrect.
  • The right to delete your data
  • The right to object to (future) processing of your data or to limit it, provided there is no legal bases that prevents this.
  • The right to revoke your consent to processing that you have issued. For instance, if you don’t want to receive our newsletters anymore.
  • The right of data portability. This means that you can request us to hand you over the (digital) information we have collected from you (with your consent) so you can hand this over to another data controller.

If you want to make such a request please contact us via email at [email protected]. We will take action upon your request within one month and send you a confirmation.


Except as required or enabled by applicable law, we will not use or disclose Personal Data for purposes for consent has either been refused or withdrawn, all to the extent that we may be legally obliged to do so and to the extent necessary to enforce any obligation you may have towards us under law. Some data must be shared with third parties, failure to do so may render a token, product or service inoperable or defective.


If we make changes to this Data Protection Policy that may impact you, we will provide notice of such changes as appropriate, such as by sending you an email notification to the address you’ve provided, and/or providing notice through the Services. If we make an administrative change, we may update the “Last Updated” date at the top of this Privacy Policy.


Questions about this policy, collection, processing, use and disclosure of and access to Personal Data which is required by law to be disclosed should be directed to [email protected]. If you feel like having to you can also file a complaint at the Dutch Data Protection Authority in The Hague (https://autoriteitpersoonsgegevens.nl/).