Personal Data protection Policy
(“GDPR Policy”) – V0.1
Last Update: May, 03 2022
INNOVATIVE CLOUD TECH, a simplified stock company, with a capital of 215 055€, whose registered office is 14 rue du Printemps 75017 Paris – France, registered at the Paris Companies Register under the number B 899 756 340, publisher of the website accessible at the URL address: https://pokmi.com/ (the “Site”) and hereafter called “POKMI”.
Within the framework of the implementation of the Services proposed by POKMI, the latter will be required to process personal data (hereafter “Personal Data”), as a consequence it undertakes to respect the privacy of its contacts (users, content creators, partners… hereafter referred to as “Contact(s)”) and to treat Personal Data confidentially. This Personal Data is collected in accordance with the provisions of the European Regulation 2016/679 on the protection of personal data (GDPR) and the French law n°78-17 of January 6, 1978 relating to data processing, files and freedoms. The terms defined in article 4 of the GDPR apply to this GDPR Policy and are themselves mentioned with capital letter. POKMI is qualified as the “Data Controller”.
As a reminder, Personal Data is any information relating to “a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (identified or identifiable natural person).
1. Purpose
Here, we explain to you what the privacy policy is for. If you browse the site, it means that you accept it!
2. Processed Personal Data
Which data are processed?
The Personal Data processed in the context of the Services offered by POKMI are:
For participants in the Pokens offer (White list, pre-ICO, ICO):
Name, first name, email address, crypto wallet (public key), information required for prevention of money laundering and terrorist financing’s check
For users:
Last name, first name, pseudo, email address, crypto wallet (public key)
For Content Creators:
Name, first name, email address, contents that may contain personality attributes, crypto wallet (public key), information required for age control, identity check information (KYC – Know Your Customer)
The collection of Personal Data is limited to the strict minimum. Consequently, only relevant, adequate and limited information is collected in relation to the purposes for which it is processed.
3. Purposes of the processes
Why is your data processed ?
For participants in the Pokens offer (White list, pre-ICO, ICO):
– Account management, relationship follow-up – Allocation, management of Pokens and accounting, – preventing money laundering and terrorism financing and fighting against corruption; – Organisation, registration, sending of articles, information and invitations to events – Prospecting and animation.
For users:
– Account management, relationship monitoring – Allocation, management of Pokens and accounting, – Organisation, registration, sending of articles, information and invitations to events – Prospecting and animation.
For Content Creators:
– Account management, relationship monitoring – Allocation, management of Pokens and accounting, – Organisation, registration, sending of articles, information and invitations to events – Prospecting and animation
4. Legal basis of the Processing
Here we explain why we have the authority to process your personal data.
5. Recipients of Personal Data
Qui aura accès à vos données personnelles ?
The Personal Data will be processed exclusively on the territory of (i) France, (ii) and/or any other member state of the European Union, (iii) and/or any other signatory state of the agreement on the European Economic Area or Switzerland (iv) and/or any other state ensuring an adequate level of protection (hereafter referred to as the “Territory”.) Apart from the cases mentioned above, any transfer of Personal Data to a third country requires the prior agreement of the Contact and is subject to the respect of the laws on the protection of personal data in force./su_tooltip]
POKMI’s service providers who may receive your Personal Data are:
| Name of the service provider | Address | Concerned Personal Data | Purpose for sharing |
| Synapse | Synaps SAS, 4 rue de la République 69001 Lyon, France | Name, first name, email address | Identity check (KYC): prevent money laundering and the financing of terrorism |
| Get ID | Maakri 19/1, 30th floor, 10145 Tallinn, Estonia | Email, ID document, Name, Date of Birth, Address | KYC check for creators |
| Send-In-Blue | Synaps SAS, 4 rue de la République 69001 Lyon, France | Name, first name, email address | Used for marketing campaigns |
| Typeform | Typeform S.L., Bac de Roda, 163 Barcelona 08018, Spain | Name, first name, email address | Used by sales team to get inbound requests |
| AWS | Amazon Web Services EMEA SARL, 5 rue Plaetis L-2338 Luxembourg | Name, first name, email address, address, phone number | Used as Server host |
| MongoDB | Mongodb Limited, Building Two, Number One Ballsbridge, Dublin 4, Ballsbridge,Dublin, Ireland | Name, first name, email address, address, phone number | Used as Database host |
The service providers indicated above are located in the Territories and are therefore subject to the obligations of the GDPR.
POKMI may also share the Personal Data collected:
– with the companies it controls or those controlling it in the sense of articles L233-1 and following of the French Commercial Code,
– in the event of a sale, demerger, partial contribution of assets, or any other form of restructuring that it may undergo,
– in order to meet its legal and regulatory obligations.
6. Data security
7. Cookies
The recipe for your cookies: what they are, how and why they are collected and how to object to them.
a) Opposition of the Contact to the use of cookies by the Site
The Contact is informed that he/she may oppose the recording of these “cookies” files by configuring his/her browser software.
For information, the Contact can find at the following addresses the steps to follow in order to configure his browser software to oppose the recording of “cookies” files:
● for Internet ExplorerTM : Link
● for SafariTM : Link ;
● for ChromeTM: Link
● for FirefoxTM: Link ;
● for OperaTM : Link
b) Description of the cookies used by the Site
The editor of the Site draws the attention of the Contact to the fact that the following cookies are used during his navigation:
Google Analytics – traffic and visit analysis
8. Data retention
Concerning the Personal Data processed outside the Blockchain, the retention periods are as follows:
● For accounting purposes: 10 years from the end of the accounting period;
● For the purposes of preventing money laundering and the financing of terrorism, and the fight against corruption: 5 years after the end of the relationship with POKMI;
● For the needs of identification and management of the Users and Content Creators: for the duration of the contractual relations increased by 2 years;
● For the needs of recruitment within POKMI: for the duration necessary to process the application and 3 years after the last contact.
9. Rights of Contacts
Under the conditions defined by the French law n°78-17 of January 6, 1978 relating to data processing, files and freedoms and the RGPD, the Contacts – natural persons – have a right of access to the Personal Data concerning them, of rectification, of limitation, of portability, of deletion.
The Contacts – natural persons – also have the right to define general and specific directives defining the way in which they intend the above-mentioned rights to be exercised after their death by e-mail to the following address: dpo@thepokencompany.com or by post to the following address INNOVATIVE CLOUD TECH SAS, Data Privacy, 14 rue Charles V 74004 Paris France, accompanied by a copy of a signed identity document.
In the event of a dispute or infringement of one of the rights listed above, the Contact is entitled to refer the matter to the French Data Privacy Authority (CNIL – Commission Nationale de l’Informatique et des Libertés, https://www.cnil.fr).
10. Applicable law and place of jurisdiction
This RGPD Policy is subject to French law. In the event of a dispute and in the event that an amicable agreement cannot be reached, the competent courts will be those within the jurisdiction of the Paris Court of Appeal, notwithstanding multiple defenders or the introduction of third parties.