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Website Privacy Notice

1
INTRODUCTION
1.1
Important information and who we are
Welcome to our Privacy Notice (“
Privacy Notice
”).
We are The Brookes Project Limited, trading as “
Verseprop
” (“
We
”, “
us
”, or “
our
”). We are incorporated in England and Wales with Company Number: 13714566, and our registered office is at Treviot House, 186-192 High Road, Ilford, Essex, United Kingdom, IG1 1LR.

We are committed to protecting and respecting your privacy and Personal Data in compliance with all data protection and privacy laws and regulations applicable to us or to our processing of your Personal Data.

This Privacy Notice explains how we collect, process and keep your data safe. The Privacy Notice will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

  • Customers and prospective customers, including visitors to our website;

  • Suppliers and business contacts

  • Employees and staff Members

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Notice applies to all our employees and staff members and all Personal Data processed at any time by us.

It is important that you read this Privacy Notice carefully to understand our practices regarding how we handle information we learn about you from your visit to this Website so that you are fully aware of how and why we are using your Personal Data.

1.2
Who is Your Data Controller

The Brookes Project Limited is your Data Controller and responsible for your Personal Data. We are not obliged to appoint a data protection officer and have not voluntarily appointed one at this time.

Any enquiries about your data should either be sent to us by email at: admin@verseprop.com or sent by post to Treviot House, 186-192 High Road, London, IG1 1LR, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2
LEGAL BASIS FOR DATA COLLECTION
2.1
Types of Data / Privacy Notice Scope
Personal Data
” means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed it is not possible to re-identify an individual from that data and any other available data (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

  • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.

  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers, social media account names.

  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

  • Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.

  • Financial Data: This includes your cryptocurrency wallet address(s) (including tokens or digital assets which are associated with that wallet address as owners or otherwise) which we collect when you link your wallet to our website for the purposes of applying to register for our Whitelist(s), participating in any NFT Mint, accessing our platform, marketplace or any other of our services from time to time. This also includes your banking details e.g. your bank account number and sort code, wallet address and any assets that are held within it.

  • Transactional Data: This is information of details and records of all payments you have made for our services or products.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2
The Legal Basis for Collecting That Data

There are a number of justifiable reasons that allow collection and processing of Personal Data. The main avenues we rely on are:

Consent
”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, apply to register for our Whitelist(s), or ‘opt in’ to a service. You will also have the right to withdraw your consent to processing for this specific purpose (please refer to section 4.1 for further information).
Contractual Obligations
”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
Legal Compliance
”: We’re required by law to collect and process certain types of data, such as data relating to fraudulent activity or other illegal actions.
Legitimate Interest
”: We might need to collect certain information from you for the purposes of our legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of your personal data. This includes

activities that can be reasonably expected as part of running our business, such as processing for marketing, business development, statistical and management purposes.

3
HOW WE USE YOUR PERSONAL DATA
3.1
Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identify

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identify

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Notice

(b) Asking you to leave a review or take a survey

(a) Identify

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(d) Marketing and Communications

To consider your application to register for our Whitelist(s), and to register you for a Whitelist

(a) Identify

(b) Contact

(c) Financial

(d) Profile

(e) Usage

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Financial

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) Financial

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(f) Financial

(g) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Employees

If you are an Employee then we will use your personal information for purposes additional to the purposes set out in this notice, as described in your employment contract, our employee policies, and/or any other applicable separate documents provided to you in connection with your position or your application for a position with us.

Customers

If you are a Customer (including an applicant to register for our Whitelist(s) or any other of our services) then we may collect and process additional information about you relevant to (i) your request to register for the Whitelist(s); (ii) your request for us to provide our services; (iii) the provision of our services; and/or (iv) the management and administration of the relationship between us; which will be as described in the Terms of Use and other terms and conditions applicable to the contract between us.

This may include processing information in order to satisfy our obligations under Anti- Money Laundering Regulations and other legislation applicable to the provision of our services. If you do not provide us with the information we need, we will not be able to provide our services to you.

Add Data Subjects

We may process your personal data for purposes necessary for the performance of our contract with you, or for steps preparatory to entering into a contract with you, and to comply with our legal obligations.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of your personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then (i) we will request such consent from you separately, and (ii) you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

3.2
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations, marketing and content updates.

You will receive marketing and new content communications from us if you have subscribed to our newsletter, or have successfully registered for our Whitelist(s) or have chosen to opt into receiving those communications.

From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3
Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in accordance with this notice, where this is required or permitted by law.

4
YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1
What Control Do I Have Over The Brookes Project Limited’s Use Of My Personal Data?

Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.

  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your Personal Data to another party.

  • In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing. This will not affect the lawfulness of processing of your Personal Data before we received notice that you wished to withdraw your consent. You can exercise this option at any time by contacting us using the contact details provided in this Privacy Notice.

4.2
How Does The Brookes Project Limited Protect Customers' Personal Data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.3
Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by unsubscribing.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4
How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to assist our response.

5
YOUR DATA AND THIRD PARTIES

Will We Share Your Data With Third Parties?

We may share your personal data with the External Third Parties described in the Interpretation section at the end of this notice, for the purposes set out in the table at section 3 above.

We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our Terms of Use or this Privacy Notice.

5.1
Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this Website, we encourage you to read the Privacy Notice of every website you visit.

6
HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

When assessing what retention period is appropriate for your personal data, we take into consideration:

  • The requirements of our business and the services provided;

  • The purposes for which we originally collected the personal data;

  • The lawful grounds on which we based our processing;

  • The types of personal data we have collected;

  • The amount and categories of your personal data; and

  • Whether the purpose of the processing could reasonably be fulfilled by other means.

If you are or become a Customer we normally retain information related to our engagement (including personal data) for a minimum period after the end of the relevant engagement or client relationship, or for longer where it is necessary for us to do so for compliance with regulatory or other legal obligations, or for the establishment, exercise or defence of legal claims, or where we agree with you to do so. In some cases it may be necessary for us to retain records indefinitely.

7
MINIMUM AGE FOR OUR USERS

You must not use this Website or any of our services unless you are aged 18 or older. If you are under 18, you must immediately stop using The Brookes Project Limited.

This website is not intended for children and we do not knowingly collect data relating to children.

8
CHANGES TO THIS POLICY

We keep our Privacy Notice under review and will place any updates on this website.

By using The Brookes Project Limited, you consent to the collection and use of your personal data by us as set out in this Privacy Notice.

Continued access or use of The Brookes Project Limited will constitute your express acceptance of any modifications to this Privacy Notice.

9
INTERPRETATION

All uses of the word "including" mean "including but not limited to" and do not in any way limit the term which they serve to illustrate.

LAWFUL BASIS
Legitimate Interest
” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract
” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation
” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
"External Third Parties"
  • Service providers acting as processors based in the UK or EU who provide IT and system administration services, including providers of “know-your-client” identification services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK or EU who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Please also see our Terms of Use which set out the terms and conditions which apply to your use of this Website or any of our services.
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