Privacy Policy

This privacy policy applies to you if are a natural person and your personal data has been provided to PureDome in connection with your use of PureDome Business services (being business cybersecurity through the use of VPN, including but not limited to remote access, dedicated IPs, site to site tunnels, and data access control (the Services) or PureDome otherwise uses your personal data. This privacy policy sets out the basis on which personal data about you will be processed by PureDome. Please take the time to read and understand this privacy policy.

PureDome is a data controller in respect of your personal data for the purposes of the Virgin Islands Data Protection Act, 2021 (the Act). PureDome is responsible for ensuring that it uses your personal data in compliance with the Act.

The information collected by PureDome is limited to that which is necessary for the provision of the Services, including your name, email address, payment information and admin IP. Except for the specific data listed in this privacy policy, our system is designed so that no other personal data (whether sensitive or otherwise) is logged about you.

Source Of Personal Data

PureDome collects personal information about its customers predominantly through the following sources:

(a) Subscription forms/contracts and other information provided by the customer to PureDome in writing, electronically or by any other means;

(b) Transactions in connection with the provision of the Services; or

Specifically, information collected by PureDome will typically be collected through a subscription form, contact form, download form, by email, through ‘chat bot’ on our website, or through other documents provided by the customer.

Reason For Personal Data Collection

Generally speaking, your personal data is collected to ensure the provision of PureDome services to you in a successful manner, for account creation and maintenance, for marketing purposes, creating client relationships, for legalities, and for providing regular support, feature updates and service upgrades. More detail is provided below under ‘Use of your personal data’.

Uses Of Your Personal Data

Your personal data may be stored and processed by PureDome for the following purposes:

(a) General business administration. Communicating with you, service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.

(b) Performance of contractual obligations. PureDome will process your data in connection with our obligations under any agreement entered into with you for the provision of the Services.

(c) Provision of the Services. PureDome will process information connected to your use of the Services including, but not limited to, subscription information, account registration and login information, basic device information, application diagnostics, connection timestamps and IP addresses.

(d) Marketing. Your contact details such as email address may be used to provide you with marketing information such as special offers. You will have the option not to receive these emails.

(e) Performance of transactions. Where you have provided payment information under our agreement with you in connection with the provision of the Services, PureDome will collect and process such personal information as necessary to complete a transaction and perform our obligations under our agreement with you.

(f) Website support and security. As is standard our website collects access logs from users. This information is essential for security purposes and to enable us to better diagnose problems and maintain our website. Additionally, information collected via cookies such as your IP address, device type, location (country) enable us to improve user experience.

(g) Communicating with users and customer support.

(h) Advertising.

(i) Compliance with legal and regulatory obligations.

PureDome is entitled to process your personal data in these ways for the following reasons:

(a) You have given your express consent.

(b) You may enter into an agreement with PureDome for the provision of the Services and some processing will be necessary for the performance of that contract, or will be done at your request prior to entering into that contract.

(c) Processing may be necessary to discharge a relevant legal or regulatory obligation to which you are the subject (other than an obligation imposed by a contract).

(d) Processing may be necessary to protect your vital interests.

(e) Processing may be necessary for the administration of justice.

(f) Processing may be necessary for the exercise of any functions conferred on a person by or under any law.

(g) The personal data will, in all cases:

(i) be processed for a lawful purpose directly related to the provision of the Services;

(ii) be necessary for, or directly related to, the purpose referred to at limb (i) above; and

(iii) be adequate but not excessive in relation to the purpose referred to at limb (i) above.

(h) In respect of any processing of sensitive personal data falling within special categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be subject to additional safeguards.

Personal Data That PureDome Might Use

PureDome might process the following personal data about you:

(a) Information provided to PureDome by you which might include your name and address, contact details, date of birth, gender, nationality and credit card details (or other financial information).

(b) Information that PureDome collects or generates which might include information relating to your, emails (and related data), call recordings and website usage data and messages submitted through our website. This might include user IP, user name, connection time and duration, URLs visit and other corresponding details.

Disclosure Of Your Personal Data To Third Parties

We do not sell or provide your personal information to third parties. However, where permitted by applicable laws and for the purposes listed in this Policy we share, to the extent necessary, the information with: (i) our business partners that provide IT, servers, marketing, customer support, data storage, website customization, website analytics, accounting, legal, agency, and other services to us; (ii) affiliated companies within our corporate structure (iii) third-party tools to store the contacts, mailing lists, send communications to you or confirm your sign up to news subscriptions or waitlists and (iv) notaries, bailiffs, auditors, courts, law enforcement institutions, tax, regulatory and other public authorities only in cases where we are required, by way of a statutory provision or a binding legal order, to provide the information to such authorities.

We implement reasonable safeguards to protect collected information from unauthorised and illegal disclosure. We also require any other partners and involved third parties to implement and apply the same information protection strategies. Where the third parties listed process your personal data on our behalf we shall ensure that such third parties have appropriate data protection measures in place.

Transfers Of Your Personal Data Outside The British Virgin Islands

Your personal data may be transferred to and stored by persons outside the British Virgin Islands, and in particular may be transferred to and stored by us in the United States and by our affiliated companies and third party vendors that are based in other countries.

Where personal data is transferred outside the British Virgin Islands, PureDome will ensure that there is proof of adequate data protection safeguards. You can obtain more details of the protection given to your personal data when it is transferred outside the British Virgin Islands, including a copy of any standard data protection clauses entered into with recipients of your personal data, by contacting PureDome using the details set out under “Contact Us” below.

Retention Of Personal Data

How long PureDome holds your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which PureDome is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which PureDome has to keep your personal data). Rest assured, collected information is only retained as long as it is necessary to fulfil the collection purpose and comply with legal requirements.

Can You Refuse To Share Your Personal Data With Us?

In general, we receive your personal data where you provide this on a voluntary basis, and there will typically be no detrimental effect for you if you wish not to provide this or otherwise withhold your consent for it to be processed. However, there are certain cases where we will unfortunately be unable to act without receiving such data, for example where we need to carry out legally required compliance screening or require such data to process your instructions or orders, or otherwise to provide you with our Services.

Where it is not possible for us to provide you with what you request without the relevant personal data, we will let you know accordingly.

Your Rights

You have a number of legal rights in relation to the personal data that PureDome holds about you. These rights include the following:

(a) The right to obtain information regarding the processing of your personal data and request access to the personal data that PureDome holds about you.

(b) The right to request that PureDome rectifies your personal data if it is incomplete, incorrect, misleading, or excessive.

(d) The right to lodge a complaint with the BVI Information Commissioner if you think that any of your rights have been infringed by PureDome.

You can exercise your rights by contacting PureDome using the details set out under “Contact Us” below. You can also find out more information about your rights under applicable British Virgin Islands data protection law by contacting the Office of the Information Commissioner. Please note that, as of December 2022, an Information Commissioner has not yet been appointed.

Contact Us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to support@puredome.com

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