Personal data or personal information means any information about you that enables you to be identified personally.

Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers that can be linked with such information in order to identify you. It does not include data where the identity has been removed (anonymous data).

Depending on the use you make of our site or services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, and date of birth.

Contact Data includes current address, email address and telephone number.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, visitor login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices visitor uses to access our site.

Profile Data includes visitor username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how visitor interacts with and use the site, products and services.

Marketing and Communications Data includes visitor preferences in receiving marketing from us and our third parties and their communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law and will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature of our site. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

This site is owned and operated by BN Labs Ltd, a company registered in England and Wales with company number 14211627, whose registered office is at 101 New Cavendish Street, 1st Floor South, London, United Kingdom, W1W 6XH (“BN Labs”, “we”, “us”, or “our”). We are the controller and are responsible for this site.

We are responsible for your personal data, except where we process your personal data because you use our services as a result of your relationship with a client who we supply our services to (for example, if you use our services as a result of your being our client's employee or client).

Where we process your personal data because you use our services as a result of your relationship with a client who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our client as a data processor.

Where we are processing your personal data on behalf of our client, the privacy policy that you should be referring to would be our client's privacy policy. Our client's privacy policy should inform you as to how your personal data will be processed.

We are bound by applicable data protection laws in respect of the handling and collection of your personal data.

If you have any questions about this privacy policy or our privacy practices, including any request to exercise your legal rights, please contact us by any of the following means:

Email address: compliance@irys.xyz

Postal address: 101 New Cavendish Street, 1st Floor South, London, United Kingdom, W1W 6XH

We use different methods to collect data from and about you including through:

Direct interactions with us. You may give us your personal data by: filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our cookie policy https://irys.xyz/cookies for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, including but not limited to the following:

• Technical Data is collected from analytics providers such as Google which is based outside the UK

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services

• Identity and Contact Data is collected from data brokers or aggregators

• Identity and Contact Data is collected from publicly available sources such as social media accounts, Companies House and the Electoral Register based inside the UK

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience.

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may send you marketing communications by email, text message, telephone, or email. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our business offerings may be relevant to you.

We will get in your express opt-in consent before we share personal data with any third party for marketing purposes.

Opting out of marketing:

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links within any marketing communication sent to you or by contacting us by email.

Where you opt out of receiving these marketing messages, you will still receive service-related communications that are essential for administrative or customer service purposes.

If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.

Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.

We do not make any automated decisions.

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

External third parties such as:

• Professional advisors including lawyers, bankers, auditors, and insurers

• HM Revenues & Customs, regulators, and other authorities

• Service providers and subcontractors/sub-processors such as Google Analytics

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 policy.

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.

Your personal data are processed mainly within the UK.

Whenever our relations with partners, our subcontractors or third parties (such as those who provide us with support services) involve cross-border exchanges of your personal data outside the UK, we ensure a similar degree of protection is afforded to your personal data by ensuring that 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 by the UK.

If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK (as applicable).

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

In any event, you agree to your personal data being processed under these conditions, outside the UK.

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.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data (see your legal rights below).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Otherwise, we securely erase or anonymise your personal data where we no longer require your information for the purposes collected.

Under UK data protection laws, you have a number of rights (subject to certain conditions) when it comes to your personal data. Your legal rights include:

Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data 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.

Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.

Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.

Withdraw consent at any time where we are relying on consent to process your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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.

Our site may include links to third party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you. Third-party sites are not under our control, and we are not responsible for its content. When you leave our site, we encourage you to read the privacy policy of every website you visit.

We keep this Privacy Policy under regular review and may update it from time to time. We reserve the right to make amendments to our Privacy Policy at any time. Historic versions can be obtained by contacting us.

Any changes we may make to this Privacy Policy will be posted on our website and, where appropriate, notified to you.

Unless otherwise provided in this Privacy Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.