Privacy Policy

1. Overview

This document constitutes the STOmaker Data Privacy policies. STOmaker is committed to protecting your right to privacy as a user of our online documents. It is our policy to respect the privacy of private communication.

The information you provide to us will be held for STOmaker on servers based in the US. Our hosting provider for the STOmaker webapp platform, AWS has its servers also in the US. As explained below, we will not transfer your information, or authorise its transfer, outside these two locations.

According to the STOmaker Data Privacy policies, we collect information about our users in order to help us continually improve the products and facilities we offer and so that we can enter into commercial arrangements, including the sale of advertising space. STOmaker will always adhere to common Data Protection Legislation which, from 25 May 2018, includes EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

Other than as stated below, we do not hold or use any information that you provide, or which we collect, outside the European Economic Area (“EEA”) or US, nor do we transfer it to, or share it with, others within or outside the EEA/US (except when we believe in good faith that the law requires it).

This Privacy Policy only relates to the STOmaker sites and does not extend to your use of the Internet outside of the STOmaker site.

2. Your information, privacy, and data protection

You understand and agree that STOmaker collects, uses, stores and otherwise processes your personal information and utilisation data and may share such data with third party service providers for the purposes of improving or providing the services subject to The STOmaker‘s privacy statement. Data to be processed may include your name, email address, LinkedIn profile, social media profiles and other information, which may include but is not limited to your job title, place of work, telephone number, and/or postal address. All personal data will be treated as confidential and in compliance with pertaining Data Protection Legislation and other applicable legislation.

You agree that STOmaker may access, preserve and disclose your personal information and/or content if required to do so by law or to:

1. comply with a legal process;

2. respond to claims that any content violates the rights of third parties or

3. protect the rights, property or personal safety of STOmaker, users, and the public.

You agree to comply with our terms and this privacy statement.

3. About Us – Imprint

STOmaker is brand held under a private limited UK entity represented by::

Digital Den Holdings Ltd.
c/o Jurgen Wittkopp
19, Maple Way, Melbourn, Hertfordshire
SG8 6BD
United Kingdom

Email: contact@stomaker.com
Web: https://www.stomaker.com

Dispute Resolution

For users in Europe we are obliged to advertise a dispute resolution facility under EU law. The EU Commission provides a platform to handle disputes online through:

https://ec.europa.eu/consumers/odr

We are not required to partake in person in any actual dispute resolutions.

4. Data We Collect

According to the STOmaker Data Privacy policies we will collect personal data as provided to us during the registration or purchase process, which you agree to supply us as accurate.

We do not monitor your use of the Internet, but we may use cookie technology to monitor your use of STOmaker. This information is not stored alongside your personal data and will only be used on an anonymous, aggregated basis. We may process your personal data in combination with the documents and forms downloaded, and materials and courses accessed in order to maintain and improve the facilities we offer and to send you alerts and emails about important updates to such content, new materials and courses.

5. Data Usage

We use your personal data for the following purposes:

Providing and managing your account and/or subscription(s).
Supplying you with information, documents, forms, and other content either through the STOmaker site or by email. You can control your email preferences from within the profile link at the bottom of emails and can opt out of our services when you register (or at any time thereafter). Please note that some emails are an integral part of the STOmaker service you sign up for when registering with STOmaker and cannot be opted out of and that by registering, you are consenting to us using your personal data to send such emails. We will never send you any spam and always aim to ensure that our emails will be genuinely useful to our recipients.
Communicating with you. This may include responding to emails or calls from you.
Building up a profile of your interests and preferences based on your download history.
Our processing of your personal data is in our legitimate interests and is necessary to provide the STOmaker service to you and to continually improve it and the content available through it.

Our use of your personal data is limited to that which is reasonably required in order to provide our service to you and to make improvements to that service which benefit both us and you. We do not use your personal data for any reasons not stated in this privacy policy and never use it in an excessive manner that is disproportionate to our aims of providing and improving our service or in a way that is contrary to your interests.

In addition, when you purchase a subscription from us, your personal data is necessary for the formation of the contract between you and STOmaker and the completion of your purchase.

6. Cookies We Use

STOmaker restricts its use of cookies and related technologies for the following purposes:

This tool is used when you visit our site via one of our paid ads on the Bing search engine. We use tracking and analytics to better understand how you use our site in order to improve our service. Tracking and analytics are not used for any direct marketing purposes.

This is a tool that we use for tracking and analytics on our site. We use tracking and analytics to better understand how you use our site in order to improve our service. Tracking and analytics are not used for any direct marketing purposes.

7. Keeping Personal Data

The personal data that you provide when registering with STOmaker is retained until you ask us to delete it. If you wish to delete your registration, you can do so using the ‘Unsubscribe’ option in the bottom of our email communication to you.. Download histories are retained indefinitely, however when your record is deleted, this information cannot be used to identify you. All personally identifying information is deleted immediately on your request.

8. Storing and Transferring Personal Data?

We only store your personal data in the EU and US. This means that it will be fully protected under the GDPR.

As explained, as covered in the STOmaker Data Privacy policies, certain personal data might be made accessible to our third-party IT contractor, based outside of the European Economic Area from time to time. Additional steps have therefore been taken to ensure that your personal data will be treated just as securely and safely as it would be in the UK and under the GDPR, as embodied in a data processing agreement between us and our contractor based on model contractual clauses provided by the European Commission, which impose suitable data protection standards on a contractual basis.

9. Sharing Personal Data

We share your personal data with selected third parties exclusively to provide services to you, only with the following parties for the following purposes:

Access to the STOmaker materials, courses etc. through teachable.com, our hosting provider for learning material.
To the extent necessary for the purpose of providing our service, the personal data which you give us during the registration process, and data relating to the documents and forms downloaded by you, may be transferred to third parties within the EEA who we engage from time to time to provide us with any services or facilities which we use for the purpose of administering our business and providing our products and services to customers.

We may also transfer any of that data to our third-party IT contractor outside the EEA which provides us with IT services facilitating our provision of products and services via our website and email communications to those who register as customers with us. Any such transfer will be subject to terms agreed with our IT contractor which comply with those prescribed for such a purpose by the European Commission, thereby ensuring that your personal data will be protected to standards equivalent to those specified by the GDPR.

10. Your Rights As A Data Subject

Individual data subjects have the following rights under the GDPR which we will always work to uphold:

The right to be informed about our collection and use of your personal data (as described in this policy).
The right to access your personal data by means of a subject access request (see below).
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. You can do this either by contacting us or by clicking on the “Change Profile” link contained in our email communication to you.
The right to erasure (also known as the right to be forgotten). You can exercise this right either by contacting us. Please note that if you delete your record, it will be deleted immediately and if you have an active subscription, that subscription will be cancelled. Refunds are not available.
The right to restrict or object to our processing of your personal data for particular purposes. Email preferences can be changed using the ‘Change Profile’ link in the bottom of our email communications to you.
The right to data portability. This means that you can ask us for a copy of your personal data to re-use with another service or business. Please note, however, that this right applies only if you have provided personal data to us directly, we are using it with your consent or for performance with a contract, and your data is processed using automated means.
Rights relating to automated decision-making and profiling. We do not, however, use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us.

Further information about your rights can be obtained from the Information Commissioner’s Office. You also have the right to lodge a complaint with the Information Commissioner’s Office if you feel that your rights have been breached.

11. Access Personal Data

All personal data provided by you during registration, along with details of your download history, can be requested by contacting us.

If you wish to make a data subject access request, please do so in writing, sent to the email or postal address shown below, clearly marking your correspondence with subject “STOmaker Data Privacy” and explain your access request.

We do not normally charge for subject access requests unless they are ‘manifestly unfounded or excessive’ (e.g. repetitive). We will respond to your subject access request within one month of receiving it. In the unlikely event that your request is particularly complex, a further two months may be required but we will keep you informed if this is the case.

12. How To Contact Us

To contact STOmaker about anything to do with your personal data and data protection, including to make a subject access request, please use the following details and we will respond as soon as possible:

Email: contact@stomaker.com

13. Changes To This Policy

We may change our privacy policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be notified to you the first time you login to STOmaker after the changes have been made.

Version: May 2023

STOmaker is a support (and educational) platform for vetting, designing and launching registered financial instruments, security token offerings (real estate assets, equity, debt, funds, etc.) that live in a digital format on various blockchains. We do not assume the roles of investment bankers, financial advisers or managers of financial vehicles, nor do we engage with clients as a funding platform, underwriter of securities or broker-dealer. Support rendered through this website and the tools we provide shall not be construed as financial advice to any person or entity. STOmaker’s mission is to simplify the process of preparing, issuing digitalized securities based on distributed ledger technology, thereby helping to minimise cost and time it takes to raise funds and migrate from the traditional world of finance into the digital age.
You will need to enlist the services of a registered professional should you require regulated financial services such as negotiations for transactions, the purchase of securities, custody of digital assets and services of similar nature.
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