Block360 Private Limited, an international software development company, together with
itsaffiliates andsubsidiaries (collectively “Block360” or “we”), has prepared this Privacy
Policy (“Policy”) tooutline its online data protection practices. This Policy explains why and
what informationaboutyou will be collected by Block360 when you visit its websites atwww.block360.io and relative subdomains(collectively
“Websites”), and when you contact Block360 by sending an email, filling in thecontact form or
otherwise, or when you apply for a job posted on our Website. It also describeshowthe
information about you will be used, how you, as a data subject, can control your personaldataand
Please read this Policy carefully before browsing this Website. We will process your data
onlyasdescribed in this Policy. Our Websites are not directed to children under the age of 16,
and wedonot knowingly collect personal data from children of this age group.
Website.Wemight update this Policy in the future, so please make sure to read it from time to
Should you have any questions or comments as for this Policy, please contact us at
2. WHAT DOES BLOCK360 HAVE TO DO WITH YOUR DATA?
In light of the EU General Data Protection Regulation (“GDPR”), Block360 is a controller and
aprocessor of the personal data submitted through this Website and collected in other ways.
Beingacontroller means that we are responsible for deciding how we hold and use personal
Block360 uses a third-party “Workable” for recruitment processing services. By submitting
anonline application for any vacancy placed on our Website you expressly submit your
personaldata,contact information, CV and any other information you choose, and agree that it
will becollectedand processed by both Block360 and Workable. In such case Block360 stays the
datacontroller and Workable becomes the processor
3. WHAT DATA ABOUT YOU DO WE COLLECT?
We only collect information about you that is necessary for us to allow you to use the
Websiteorcontact us, and only to the extent specifically provided in this Policy.
3.1 Information we
When you contact us via email or via the contact form, you provide us your name, phone
number,e-mail address, communication content and data associated with the communication.
Examples of personal data that you provide to us when applying for a vacancy are full
name,e-mail,phone number, location, any other information you choose to provide in your CV or
together withit.You might also choose to provide us with any other personal data, for example
the personal dataof acandidate for work whom you want to refer. From time to time, Block360 also
receives personalinformation about individuals from third parties around the world. This may
happen if youpublishyour CV on the Internet on some job boards, giving them the consent to use
and transmit yourdata,if someone recommended you for potential employment and in other similar
cases. We encourage youtoreview the privacy policies of any third-party websites before
providing your information tothem.
3.2 Information we
obtainfromyour use of our Websites
When you visit our Websites we may collect the following information about you:
information about your device(s), in particular, hardware model, version of
information about your visits to and use of this Website, including your IP
address,geographical location, browser type and version, referral source, page views and
cookies. For more information on the cookies being used on the Website and how you
canoptout, please visit the section 7 of this Policy.
4. WHY DO WE PROCESS YOUR PERSONAL DATA?
We will only process your personal data where we have a legal basis to do so. The legal
basiswilldepend on the reasons we have collected and need to use your personal data for. We may
processyourpersonal data because:
you have consented to us using your personal data
we need to comply with a legal obligation
it is in our legitimate business interests
More specifically, personal data submitted to us through this website and personal data
wecollectedfrom you or third parties or from public sources will be used for the purposes based
on thelegalgrounds as follows:
if you have contacted us via this website or otherwise, we may process your personal data to
beableto answer your questions, to organize the meeting, call, zoom or other communication.
Pleasenotethat this communication may be recorded and stored by Block360 representative in
4.2 Marketing and
publicrelations, based on your consent, art. 6 para. 1 a GDPR:
if you are a visitor of our website, we may, by way of cookies, process your data
tocarryout marketing research and to analyze the characteristics of this website
visitors, toassess the impact of our marketing communication and to adjust it to the
detectedtendencies, to plan our future marketing activities, to prepare analytics and
profilingforbusiness intelligence, to target our advertising.
if you are our subscriber, you receive or would like to receive our marketing
materials,wemay process the personal data you provided to us to spread promotional
materials, tomakeannouncements about additions and changes concerning our services, to
send you e-mailnotifications, to send you our email newsletters.
a) based on your consent, art. 6 para. 1 a GDPR:
if you are a potential employee, we may process your personal data to assist you with
ongoing orfuture employment or cooperation with Block360, to enable you to submit your resume,
apply forjobs online or express your interest in relocation.
b) based on Block360 legitimate interest, art. 6para.
1 f GDPR:
in specific cases, and only upon the client’s request, we may show your CV to
apotentialclient for business engagement or to current client to confirm the high level
of skillsofour members of staff providing the services. Also, to fulfill its
complianceobligations,our client may need to check your biography more closely before
providing you with theaccess to its protected data and facilities. Therefore, we may ask
you to provide morespecific information, such as tax number, work permission,
citizenship, criminalbackgroundand other additional and specific background checks
required by particular clients toprovide you with an access to clients’ systems and
relations,basedon Block360 legitimate interest, art. 6 para. 1 f GDPR:
if you are a representative of our current or potential client, vendor or business partner,
wemayprocess your personal data to organize the approval, processing and signing of contracts,
acts,invoices and other contractual documentation; to promote our new products, works and
services;toconfirm the high level of our works and services; to invite you to the meetings and
events ororganize them; to comply with economic sanctions and export control list screening,
industrystandards, regulators’ requirements and other requirements related to anti-corruption,
fraudprevention and anti-money laundering.
4.5 Corporate and
investorrelations, based on Block360 compliance obligations, art. 6 para. 1 c GDPR:
if you are a current or potential director or top manager of Block360, we may
processyour personal data to organize your participation in corporate meetings,
events,businesstrips, to pay your remuneration, to cover related expenses, to maintain
our corporaterecords, to make obligatory public disclosures and reports, to execute
auditor’srequests,to present the company and its management during the sale process and
to perform otherlegalobligations. We also may share this information within Block360,
provide some of thisdata to banks, notary, payroll agencies and legal advisors with the
purpose of openingof acorporate bank account or other accounts;
if you are a current or potential affiliate of Block360, we may process your
personaldata to organize your participation in corporate meetings and events, to provide
youwiththe meetings’ materials and our reports, to support you in execution of your
rights, tomakeobligatory public disclosures and reports, to execute auditor’s requests
and to performother legal obligations, including anti-money laundering requirements and
4.6 Security, based
onBlock360 legitimate interest, art. 6 para. 1 f GDPR:
if you are a visitor of this website, we may process your personal data to keep
thiswebsitesecure, prevent fraud, protect rights and interests of Block360 and third
parties,protect Intellectual Property rights;
if you are a visitor of our office, we may process your personal data to
monitorphysicalaccess and to ensure security in our office, as well as to prevent,
detect andinvestigateany crime, misconduct, incident or accident.
5. HOW CAN WE USE YOUR PERSONAL DATA?
We may process your data by way of collecting, recording, organizing, storing,
using,structuring,adapting or altering, retrieving, consulting, aligning or combining, erasing
Also, as Block360 is an international group of companies, we may disclose your data
bytransmission, dissemination or otherwise making available. To the extent permitted by
applicabledata protection laws, your personal data may be transferred between various locations
ofBlock360 and thus processed in European Economic Area and outside of it, depending on
thepurpose of processing. Such transfer and processing are possible only as reasonably
necessaryforthe purposes set out in this Policy and within the scope of legitimate interest of
We may disclose your personal data to some of our clients for business engagement or to
confirmthehigh level of skills of our team members to auditors, agencies, supervisory
authorities or tootherexternal service providers on “need to know basis” to perform our
We may also disclose your personal data:
to the extent that we are required to do so by law;
in connection with any ongoing or prospective legal proceedings;
in order to establish, exercise or defend our legal rights, including
providinginformationto others for the purposes of fraud prevention and reducing credit
6. HOW CAN YOU CONTROL YOUR DATA?
You, as a Data Subject, have the right to:
Requestinformation about whether we hold personal
information about you, and, if so,what that information is and why we are holding or
Requestaccessto your personal information. This
enables you to receive a copy of the personalinformationwe hold about you and to check
that we are lawfully processing it.
Requestcorrection of the personal information
that we hold about you. This enablesyouto have any incomplete or inaccurate information
we hold about you corrected.
Requesterasureof your personal information. This
enables you to ask us to delete or remove personalinformation where there is no good
reason for us continuing to process it. You also havetheright to ask us to delete or
remove your personal information where you have exercisedyourright to object to
processing (see below).
toprocessing of your personal information where we are relying on a
legitimateinterest (or those of a third party) and there is something about your
particularsituationwhich makes you want to object to processing on this ground. You also
have the right toobject where we are processing your personal information for direct
automateddecision-making, including profiling, that is not to be subject of
anyautomateddecision-making by us using your personal information or profiling of you.
therestriction of processing of your personal information. This enables you
toaskus to suspend the processing of personal information about you, for example if you
wantusto establish its accuracy or the reason for processing it.
Requesttransferof your personal information in an
electronic and structured form to you or to anotherparty. This enables you to take your
data from us in an electronically useable formatand tobe able to transfer your data to
another party in an electronically useable format.
Withdrawconsent.You have the right to withdraw
your consent to the collection,processingand transfer of your personal information for a
specific purpose at any time. Once wehavereceived notification that you have withdrawn
your consent, we will no longer processyourinformation for the purpose or purposes you
originally agreed to, unless we have anotherlegitimate basis for doing so in law. The
withdrawal of consent will not affect thelawfulness of processing based on consent prior
If you want to exercise any of these rights, please contact us at
firstname.lastname@example.org. The request response time isone
We may need to request specific information from you to help us confirm your identity and
ensureyour right to access the information or to exercise any of your other rights. This is
anothersecurity measure to ensure that personal information is not disclosed to any person who
has norightto receive it.
Please exercise your rights wisely and note that abuse of rights may entail your liability.
7. HOW IS YOUR DATA RETAINED?
We make sure to use appropriate technical and physical security measures to protect
yourpersonaldata which is transmitted, stored or otherwise processed by us, from accidental or
unlawfuldestruction, loss, alteration, unauthorized disclosure of, or access.
Your personal data is securely stored by Block360 on its servers, and on the servers of
thecloud-based database management services that Block360 engages, such as Workable.
We will not retain your data for longer than it is necessary to fulfil the purpose it is
beingprocessed for. To determine the appropriate retention period, we consider the amount,
nature andsensitivity of the personal data, the purposes for which we process it and whether we
canachievethose purposes through other means. We must also consider periods for which we might
need toretainpersonal data in order to meet our legal obligations or to deal with complaints,
queries and toprotect our legal rights in the event of a claim being made. When we no longer
need yourpersonaldata, we will securely delete or destroy it.
We will retain information and documents, including electronic documents, containing
to the extent that we are required to do so by law
if the information is relevant to any ongoing or prospective legal proceedings, and
in order to establish, exercise or defend our legal rights, including
providinginformationto others for the purposes of fraud prevention and reducing credit
8. WHAT ARE COOKIES AND HOW DO WE USE THEM?
When you visit the Block360 websites, Block360 may place cookies and similar analyticalcodes
(collectively, “Cookies”) on your device, browser or the webpage you are viewing, in
ordertopersonalize your experience, understand usage patterns and provide, improve, and secure
theBlock360 websites. Cookies are simple computer files made of text. Cookies do not
typicallycontain any information that personally identifies someone, but personal data that we
storeaboutyou may be linked to the information obtained from cookies.
Our websites use different types of Cookies for different reasons, as follows:
Functional cookies - these Cookies areessential
toenable you to move around the Block360 websites and use their features. These
Cookiesmake sure you can view the websites and use them in a proper way. They also give
youaccessto secured parts of the Block360 websites. Examples of functional cookies:
SID,PHPSESSID, wp-settings-X, wp-settings-time-X, etc.
Analytical cookies and other cookies -
theseCookies help us improve all our websites, collect anonymous information about
howvisitorsuse our websites, collect information about the most visited pages and tell
us whetherandhow many error messages were displayed. Examples of analytical cookies: 1_P
Third-party cookies - these Cookies help
thirdparties to help track and manage the effectiveness of, for example, their websites,
ads,number of visitors. More information about these Cookies may be available on
therelevantthird party’s website. Examples of third-party cookies: bcookie, sb, fr,
spin, wd, xs,etc.
Based on how long they are valid, the Cookies on the Block360 websites may be either
persistentcookies or session cookies: a persistent cookie will be stored by a web browser and
will remainvalid until its set expiry date, unless deleted by the user before the expiry date; a
sessioncookie, on the other hand, will expire at the end of the user session, when the web
browser isclosed. If you want to receive more information about the cookies we use, please
You can adjust your browser settings to delete some of our cookies or cookies set by
thirdparties.You may also adjust your browser settings to prevent websites from setting cookies
orthird-partycookies altogether. If you prevent us from setting specific cookies, you may find
that somefunctions are not available or that certain parts of the website will not load. Find
out how toadjust the settings for different browsers:
9. DO YOU HAVE ANY QUESTIONS?