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Why is this relevant?

Browsing a website from your actual location rather than through a VPN (Virtual Private Network) is important for several reasons, primarily revolving around the accuracy of information, compliance with legal requirements, and ensuring appropriate access.

Accurate Content and Services:

Websites often provide content and services tailored to specific geographic regions. This could include localized news, pricing, availability of products/services, or language-specific content. Accessing a website through a VPN may misrepresent your location, leading to inaccurate or irrelevant content being displayed. For example, you might see prices in a currency that doesn't match your actual location, or services that are not available in your region may appear accessible.

Legal and Regulatory Compliance:

Many websites and online services are subject to legal and regulatory requirements specific to certain regions. For instance, data privacy laws such as GDPR in Europe or CCPA in California impose restrictions on how personal data is collected, stored, and processed based on the user's location. Accessing a website through a VPN might mask your actual location, potentially leading to non-compliance with these regulations if you're interacting with content or services not meant for your actual geographic area.

Security Concerns:

VPNs are often used to enhance online security and privacy by encrypting internet traffic and masking IP addresses. However, some websites might restrict or block access from VPN IP addresses due to concerns over abuse or malicious activities. Attempting to access such websites through a VPN could result in denied access or additional security challenges.

Quality of Service:

Some websites or online services might adjust their performance or service levels based on the user's geographical location. This could affect factors like server response times, network latency, or overall service quality. Using a VPN might inadvertently route your traffic through servers that are not optimized for the best performance, impacting your user experience.

Ethical Considerations:

From an ethical standpoint, accessing content or services through a VPN to misrepresent your location might violate terms of service agreements or undermine the principles of fair use and access intended by content providers.

Privacy Statement

Welcome to the Privacy Statement section of our website. This policy sets out:

be informed of what we do with your personal information;

request a copy of personal information we hold about you;

require us to correct any inaccuracy or error in any personal information we hold about you;

request erasure of your personal information (note, however, that we may not always be able to comply with your requestof erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);

object to or restrict the processing by us of your personal information (including for marketing purposes);

request to receive some of your personal information in a structured, commonly used, and machine readable format,and request that we transfer such information to another party;

In this policy, “Blue City Capital Technologies”, "our", “we” or "us" refers to Blue City Capital Technologies, Inc, Ste 14395, #8, The Green, Dover, DE, USA, 19901 (Company Number 3215522). The term “Platform” means our website at bluecitycapital.com

In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, that relates to an identifiable individual.

Which types of information do we collect?

We collect the following types of information about you:

account and profile information that you provide when you register for an account or sign up for our products or services,for example We will collect the following information: your name (first and surname), your job title and position,the name of your employer and the address of your employer. We may also collect additional information from any professionalsocial media feeds you may have, such as LinkedIn. (collectively, 'Account Data');

information you provide through support channels, for example when you report a problem to us or interact with our support team,including any contact information, documentation, or screenshots (collectively, 'Support Data');

communication, marketing, and other preferences that you set when you set up your account or profile (collectively, 'Preference Data');

information about your device or connection, for example Your internet protocol (IP) address, log-in data, browser type and version,time-zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access ourproducts or services and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details)(collectively, 'Technical Data');

Information about your use of or visit to our Platform, for example Your clickstream to, through, and from our Platform,products you viewed, used, or searched for, page response times, download errors, & length of visits to certain pages,page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page (collectively, 'Usage Data').

Data Retention Periods.

The period of time with which we hold onto your data is dependant on the reason as to why you made contact with us in the first place, or whether you have an ongoing connection with our businesses.

The following data retention periods are designed to be compliant with the currect data protection legislations:

Enquiries: 6 months

Employee data: 6 years after termination

Client onboarding data: 6 years after termination

Employee or contractor applicant: 6 months

Data locations.

Our business partners and service providers based in:

The United Kingdom

The United States of America

We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.

We use Freshdesk, inc as our customer service management tool. Freshdesk, inc will have their own Data Protection Policies which contains some useful information around how they handle your data should you make contact with us via their platform.

How do we use the information that we collect?

We only use your personal information where the law allows us to. We use your personal information only where:

We need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products orservices, to provide customer support and personalised features, and to protect the safety and security of our platform;

It satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests,for example for research and development, and in order to protect our legal rights and interests

You've given us consent to do so for a specific purpose, for example we may send you direct marketing materials orpublish your information as part of our testimonials or customer stories to promote our products or services with your permission;

We need to comply with a legal or regulatory obligation.

If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us (please refer to paragraph 8 for contact information), but please note this will not affect any use of your information that has already taken place.

We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.

We have set out our legal basis for processing your information in the Legal Basis Table at the end of this policy.

How do we share the information that we collect?

We share information with third parties that help us operate, provide, support, improve, and market our products and services, for example third-party service providers who provide Names of directors, addresses and potentially financial information.

Third-party service providers have access to your personal information only for the purpose of performing their services and in compliance with applicable laws and regulations. We require these third-party service providers to maintain confidentiality and security of all personal information that they process on our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of your personal information.

We take reasonable steps to confirm that all third-party service providers that we engage process personal information in the manner that provides at least the same level of protection as is provided under this policy. Where any third-party provider is unable to satisfy our requirements, we will require them to notify us immediately and we will take reasonable steps to prevent or stop non-compliant processing.

We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

If you use any third-party software in connection with our products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.

Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.

We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.

If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.

Please be aware that occasionally we may be required to share your information with our banking partners in order to fultil their fraud prevention and money laundering policies and security checks. This is also a part of our agreement with our banking partners.

How do we store & secure the information that we collect?

We have adopted the following measures to protect the security and integrity of your personal information:

information is encrypted using TLS/SSL technology;

access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and

our information collection, storage, and processing practices are reviewed regularly.

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

While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, we will delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it from further use. We periodically review the basis and appropriateness of our data retention policy.

You & your rights.

You have the right to:

be informed of what we do with your personal information;

request a copy of personal information we hold about you;

require us to correct any inaccuracy or error in any personal information we hold about you;

request erasure of your personal information (note, however, that we may not always be able to comply with your requestof erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);

object to or restrict the processing by us of your personal information (including for marketing purposes);

request to receive some of your personal information in a structured, commonly used, and machine readable format,and request that we transfer such information to another party;

You may opt out of receiving marketing materials from us You can unsubscribe from marketing distribution lists by clicking the unsubscribe link at the bottom of the email. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.

As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

Any request under paragraph 5.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests

If you are based in the United Kingdom, you can view your rights under GDPR legislation by visiting Information Commissioner's Office

Changes to this privacy policy.

We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.

Our policy towards children and minors.

Our products and services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 18.

Contact our Privacy & Data Protection Department

Please contact our Data Protection Officor Darryl Krakowski at darryl.krakowski@bluecitycapital.com or submit a written request to:

Request a DSAR

Attn: Data Protection Officor

Darryl Krakowski c/o

Blue City Capital Technologies, Inc

#1920, McKinney Avenue, Dallas, TX, USA, 75201

Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed. If you reside in the United Kingdom, you may file a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Reporting errors on our website

There will be occasions when errors occour in the loading of ours, of our subsidiaries, websites. When a user experienced an error, a support ticket is automatically generated and send to our internal development team. No personally identifiable data is included in the support request.

Third-party Services

We use third-party services to help us operate, provide, support, improve, and market our products and services. These third-party service providers have access to your personal information only for the purpose of performing their services and in compliance with applicable laws and regulations. We require these third-party service providers to maintain confidentiality and security of all personal information that they process on our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of your personal information.

We take reasonable steps to confirm that all third-party service providers that we engage process personal information in the manner that provides at least the same level of protection as is provided under this policy. Where any third-party provider is unable to satisfy our requirements, we will require them to notify us immediately and we will take reasonable steps to prevent or stop non-compliant processing.

We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

If you use any third-party software in connection with our products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.

Stripe, Inc

Processing of payments (including regular payments)

354 Oyster Point Blvd South San Francisco, CA, 94080-1912 United States

Freshdesk, Inc

Customer Services and Client Communications

79 Hatton Garden, London, United Kingdom, EC1N 8JS

Google Analytics (Google LLC)

Browser Tracking, analysing browner behaviour

1600 Amphitheater Parkway, Mountain View, California 94043, USA

IPinfo Inc

Browser Tracking, analysing browner behaviour, delivering your browsing location

5616 49th Ave SW, Seattle, WA 98136

How we process your data when you apply to us or our subsidiaries.

We your personal data to process your application for a position within our Company. If your application is successful through to telephone screening/interview, and you are not selected for a role, we may store your personal data for 12 months to enable our HR team to contact you should future roles be advertised. Where you apply, but are not selected for telephone screening/interview, we will delete your personal data once the position is filled. We do not use automated decisioning or profiling when selecting candidates.

There may be occasions where we may need to share your data with Government agencies for their purposes of crime detection and prevention. However, there may also be occasions where we will be required to share your information with our banking partners in order for them to continue to provide their contracted services to us. These are not Government agencies, however, as responsible regulated entities they also have a duty to ensure that appropriate due dilligence is carried out to ensure that the people we pay are who they tell us they are.

If you have been sourced from CodeControl GmBH, we will not collect any personal information about you, but will continue to collect data pertaining to your skills and your career history - if appropriate - in order for us to determine your suitability for the assignment we have placed to tender.

If you are based in the United Kingdom, you can view your rights under GDPR legislation by visiting Information Commissioner's Office

Personal data we collect

We collect personal data for a variety of reasons, including to meet our legal obligations, manage our operations, improve our business, establish, exercise or defend our legal claims and most importantly – to deliver our Services and Products to you. We’re dedicated to protecting all of our Tide members from the industry-wide threat of fraud, so we may use any data provided to us for the identification, investigation, reporting and prevention of fraud. Below is a list of types of personal data that we will collect and use when you apply for, or use, any of our Products or Services.

Date Type
Description
Purpose
Lawful Basis

Service enquiries, providing feedback, press queries or requests for assistance.

Full name

Email address

Phone number

Existing ticket numbers

Press credentials (if aplicable)

Your message

Managing business relationships

Providing our services to you

Sending you service-related communications

Sending you marketing communications (where you have consented to this)!

Fulfilling our contract with you

When it is our legal duty

When you consent to it

Communicate with our members

Keep our records up to date

Resolve issues and improve the service we provide to you

Optimise your user experience

When it is in your or someone else’s vital interest.

Client Onboarding.

The name(s) of all managers and/or officers

The name(s) of all directors

The date(s) of birth of all managers, officers and directors

Beneficial ownership information (BOI) data

Residential address(es) of all managers, officers and directors

Legal corporate name

Trading name(s)

Incorporation type

Service of process address

Trading address(es)

Incorporation state

Incorporation secretary of state

State corporate income tax rate(s)

State sales tax rate(s)

Employer identification number (EIN)

Typical business activities

Business website(s)

Complaince with applicable law

Prevention and detection of money laundering activities

Background checks of directors and officors

Compliance with anti-money laundering controls

Application for employment (who do not come under 1099 status).

Full legal name

Previously-known names (including maiden names)

Full residential address

Residential address history contact telephone/cellular number(s)

Employment history

Social security number (SSN)

Recent tax information

Records of prior criminal activity

Immigration status

Verifying who you are

Conducting background checks

Conducting employment history checks

Disabilities where we need to make reasonable adjustments for

Matching skills with job requirements

Ensuring that you are allowed to work in the country you are applying in

Ensure that you are not barred from working in such an industry

Ensuring that you have no criminal history - where applicable

Behavioural.

IP address(es)

Pages you have visited

Browser & device data

What pages you visited

How long you have visited each page

Assessing how users interact with our site

Collect feedback

Which pages are most frequently visited

Detect any issues which pay arise from our site

Commercial interest

Contractors.

Full name

Work history

Skills and abilities

Email address(es)

Knowing who you are

Assessing your skills and suitability for the contracted role

To enable us to communicate with you

Commercial interest

Feedback

We welcome any and all feedback in relation to any legal information we provide on our website.



We value your privacy and security. When you provide us with your contact details, you can feel confident we will handle your data with care. Our Privacy Statement outlines our commitment to collecting, storing, processing, and deleting your information responsibly. Please review it to learn more about how we respect your data. Rest assured we only use your contact information for the purposes you authorize.