Online Privacy Policy


“Suponic” is the trading name for MRV Technologies Company Limited (the “Company").

This Company Privacy Policy (the “Privacy Policy”) applies to your access and use of the Company’s website (the “Site”) and any iOS and Android app (both, the “App”). The Site and any Apps are collectively referred to as the “Company Technology”. The Company Technology is provided by / owned by MRV Technologies Company Limited, (referred to as “Suponic” “we,” or “us”).

The Definitions that apply in our Terms and Conditions apply to this Privacy Policy.

Remember that your use of the Site is at all times subject to the Company’s Terms and Conditions of Use, which incorporates this Privacy Policy. This Privacy Policy along with our Terms of use sets out the basis on which we collect any personal data from you or that you provide to us, which will be processed by us.

BY PURCHASING TOKENS OR COINS OR ANY DERIVATIVE PRODUCT, USING OR OTHERWISE ACCESSING THE WEBSITE, CREATING OR REGISTERING AN ACCOUNT, DOWNLOADING CONTENT OR OTHER INFORMATION, YOU SHALL BE DEEMED TO ACKNOWLEDGE THAT YOU DO SO WITH FULL CONSENT AND FULL KNOWLEDGE OF THIS POLICY AND. YOUR PARTICIPATION WILL BE DEEMED TO BE YOUR UNEQUIVOCALLY AND EXPRESS AGREEMENT TO BE BOUND BY THE TERMS.

We may modify this Privacy Policy at any time by posting the revised Privacy Policy on the Site. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. Any modifications will be effective immediately upon such posting. YOUR USE OF OR ACCESS TO THE SITE AFTER SUCH MODIFICATIONS ARE POSTED WILL SIGNIFY YOUR ACCEPTANCE OF THE MODIFICATIONS AND YOUR AGREEMENT TO BE BOUND BY THEM. Notwithstanding the foregoing, any modifications to this Privacy Policy shall not apply to any dispute between us arising prior to the date on which we post the revised Terms that contain such modifications.

We believe your business is no one else's. Your privacy is important to you and to us. So we will protect the information you share with us. To protect your privacy, the Company follows different principles in accordance with world-wide practices for customer privacy and data protection and strictly adheres to General Data Protection Regulation ("GDPR"). The GDPR will come into force on the 25th May 2018, replacing the existing data protection framework under the EU Data Protection Directive. As a regulation, it will not generally require transposition into Irish law and therefore has direct effect.

The Company respects the privacy of visitors to our site. Please read this Online Privacy Policy carefully so that you understand our privacy practices relating to information we gather through this Web site.

Our customers can be confident that in using this Site your personal details and financial information are kept private and are not misused.

I. Your Information

a) What is personal information

For the purposes of this Privacy Policy, Personal Information is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities ("Personal Information").


b) Personal information you give us

We collect and with your consent may transmit personal information that you provide to us through the Company Technology (“Your Information”). Your Information may include, but not be limited to, your name, physical address, telephone number, e-mail address, date of birth, health information, and credit card information.


c) Consent

If you choose not to register an account as defined in the Terms and Conditions of use or provide personal information, you will not be able to proceed to participate in the ICO or use the Platform or Technology or Website.

If you decide to register, you will be able to select the kinds of information you want to receive from us in addition to the emails to be sent to you regarding your purchase of the Tokens, Coins or derivative products, usage of your Account and can therefore choose by subscribing to various services, like our electronic newsletters. If you do not want us to communicate with you about other offers regarding other Company products, programs, events, or services by e-mail, postal mail, or telephone, you may select the option stating that you do not wish to receive marketing messages from the Company.

The Company occasionally allows other companies to offer our registered customers information about their products and services, using postal mail only. If you do not want to receive these offers, you may select the option stating that you do not wish to receive marketing materials from third parties.


d) Information we collect though the site

Whenever you interact with the Site, we automatically receive and record information from your browser, which may include: the device you use to access or use the Site, your IP address, the type of browser or application you are using to access the Site, and the identity of the Site page or feature you are requesting. We may use IP addresses to analyze trends, administer the Site, and gather broad demographic data for aggregate use.

Our websites use cookies to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our sites. By continuing to browse the sites, you are agreeing to our use of cookies.

We may use “cookies” or other tracking technologies to track how you use the Site. We also use JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site. Our advertising partners may also transmit cookies to your browser, application, or mobile device when you click on ads that appear on the Site. Clicking on a link to a third party website from our Site may also allow that third party website to also transmit cookies to you.

We may also use “web beacons” (i.e. “web bugs” or “single–pixel” or “clear” GIFs) on the Site. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-commerce payment processing services. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies. These cookies are used to recognise you when you return to our websites. They enable us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed.

You may adjust your web browser software if you do not wish to receive cookies or web beacons, but this may prevent you from taking advantage of some of the Site’s features. The company does not recognize “do not track” signals from your web browser.

Except for essential cookies, all cookies will expire after two years.

Be sure to review the privacy notice of any third party website you visit because this Privacy Policy does not cover the use of cookies or web beacons by any third parties. You may also request to opt-out of an advertiser’s use of cookies by visiting the National Advertising Initiative or the Digital Advertising Alliance. You may request to opt-out of Google’s use of cookies by visiting www.google.com/ads/preferences. All applicable terms on these websites will apply to your request to opt-out in addition to this Privacy Policy.

II. Why We Collect Personal Information

The Company collects Personal Information to enable us to manage, maintain, and develop our operations, including for example:
to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number); to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation;
to protect us against error, fraud, theft and damage to our goods and property;
to enable us to comply with applicable law or regulatory process (for example, we may collect Personal Information to satisfy the obligations imposed on us by our various regulators including AML/KYC regulations);
for the purposes stated in this Privacy Policy;
and any other reasonable purpose to which you consent.


III. How We Use And Disclore Your Information


Non-Personal Information

With your consent we may use and share non-personal, de-identified information (i.e. information that cannot be used to identify you) for any lawful business purpose without any obligation or accounting to you. We may use your personal information to generate non-personal information. When we do so, we will take reasonable measures to ensure that the non-personal information is no longer personally identifiable and cannot later be used to identify you. We may also disclose non-personal, aggregate, anonymous data in a de-identified format to investors and potential partners based on information collected from users.



Personal Information

With your consent we may use and disclose Your Information collected through the Company Technology (i) to perform the services described on the Site and in the Apps; and (ii) to contact you regarding our services. We may combine and enhance Your Information with information we receive from third parties as long as we use the combined information as described in this Privacy Policy. We may also use information collected through the Company Technology for research regarding the effectiveness of the Company Technology, Company products and our business planning, marketing, advertising, and sales efforts. We may disclose Your Information to perform our services as permitted by law and our contracts with our customers.

We may employ other companies and people to perform tasks on our behalf and we may need to share Your Information with them to provide services to you. Unless we tell you differently, they do not have any right to use Your Information beyond what is necessary to assist us

We may also disclose Your Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. We may disclose Your Information in order to protect the rights, property, or safety of a user or any other person. We may disclose Your Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.



Mobile Device Information

When you access the App on your mobile device (“Mobile Device”), you will be given the option to consent to the collection of Your Information. If you provide your consent we will obtain information from your Mobile Device about the type of Mobile Device you are using. With your consent we may use this information to notify you of features and products that may be available on your Mobile Device. Certain features may require our collection of the phone number of your Mobile Device. We may link that phone number to the Mobile Device identification information, but will not use that number for telemarketing. In addition, some mobile network providers (“Mobile Provider”) in the U.S. are required to use technology that tracks the physical location of Mobile Devices that use their service. Most Mobile Devices provide users with the ability to disable location services. These controls are usually located in the Mobile Device's settings menu. If you have questions about how to disable your Mobile Device's location services, we recommend you contact your Mobile Provider or your Mobile Device manufacturer.



Smart Contract Supplier

With your consent you authorize us to use the Company Technology, including the use of a third party Smart Contract Supplier. Your consent confirms your agreement to indemnify and keep indemnified the Company, its directors and employees against any loss or damage howsoever arising out of the supply and use of information by the third party Smart Contract Supplier.



IV. Protection Of Your Information

Protecting your Company Technology login credentials (i.e. your username and password) from unauthorized access is your responsibility. You may not share your login credentials with any third party. We recommend you log out after accessing your account, change your password on a periodic basis, and limit access to your computer or device and its browser. While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Company Technology, we cannot guarantee that these efforts will always be successful. We do not represent, warrant, or guarantee that our safeguards will protect the total privacy of Your Information disclosed on the Company Technology. Your Information may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to or from us. We cannot and do not ensure, represent, warrant, or guarantee the security of any information you transmit through the Company Technology.

The Company has taken strong measures to protect the security of your personal information and to ensure that your choices for its intended use are honored. We take strong precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

Our aim is to guarantee your interactions with the website are 100% safe and secure. When you interact or access your personal account information, you're utilizing a secure server software SSL, which encrypts your personal information before it's sent over the Internet. SSL is one of the safest encryption technologies available.

The Company strictly protects the security of your personal information and honors your choices for its intended use. We carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

Your personal information is never shared outside the Company without your permission, except under conditions explained above. Inside the company, data is stored in password-controlled servers with limited access.

Your information may be stored and processed in Ireland or any other country where the Company, its subsidiaries, affiliates or agents are located or the data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (”EEA”). It will be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any web-based payment transactions will be encrypted using SSL technology.

You also have a significant role in protecting your information. No one can see or edit your personal information without knowing your user name and password, so do not share these with others. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The Company has made all reasonable efforts to ensure all data controllers and processors who have access to your data are compliant the GDPR

V. Retention Of Your Information; Modification


Correcting, Updating, Accessing, or Removing Personal Information

You can correct, update, or remove Your Information if it changes or if you no longer want to receive information from the Company beyond information related to our services. This can be done by emailing a request to us at privacy@suponic.com.

You may also request access to Your Information collected by us by sending a request to us at privacy@suponic.com.

We may not be able to completely remove Your Information from our systems in certain circumstances. All of Your Information that we keep will continue to be subject to the terms of the Privacy Policy to which you have previously agreed.

The Company retention policy is GDPR compliant and all data which we are no longer authorised to keep will be destroyed.

VI. Disclosure Of Your Information


You consent to and agree that we have the right to share your personal information with:

Selected third parties including: Analytics and search engine providers that assist us in the improvement and optimization of our site; E-commerce providers such as payment solution providers to assist us in the processing of your online purchases, donations and other payments. We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions for events and other agreements; or to protect the rights, property, or safety of the Company or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

VII. Third-Party Privacy Policies


The Company Technology may include or provide links to other websites on the Internet that we do not control. We are not responsible for the actions of third parties. We encourage you to consult that website's privacy policy before providing Your Information to it and whenever interacting with any website.



VIII. Disclosure Of Customer Information Throught Busines Transfers


We may buy, merge, or partner with other companies or businesses and in so doing, acquire or transfer information. Your Information collected through the website may be among the transferred business assets. In the event that a portion or substantially all of our assets are sold or transferred to a third party, Your Information would likely be a transferred business asset, and you hereby agree to such a transfer.



IX. Users From Outside Of Ireland


The Company Technology is hosted in the Republic of Ireland and is governed by the laws of the Republic of Ireland. If you are using the Company Technology from outside Ireland, please be aware that your information may be transferred to, stored, and processed in Ireland where our servers are located and our central database is operated. The data protection and other laws of Ireland and other countries might not be as comprehensive as those in your country. By using the Company Technology, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

Our Web server automatically collects your IP address when you request pages from our server. Your IP address is a number that is used by computers connected to the Internet to identify your computer so that data (such as the Web pages you request) can be sent to you. We also collect information on the operating system you are running on your computer and the Web browser software you are using to access our site so we can optimize our site for the most popular operating systems and Web browsers.



X. No Children


The Company Technology is not for use by those under the age of 18. If you use the Company Technology, you hereby represent and warrant that you are at least 18 years of age. In compliance with the Children's Online Privacy Protection Act, any information we receive from users we believe to be under the age of 18 will be purged from our database.

The Company does not market to children under the age of 18. Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. If you are under 18, please wait until you are 18 and come back.



XI. Notice To Parents


Parents or guardians: we want to help you guard your children's privacy. We encourage you to talk to your children about safe and responsible use of their Personal Information while using the Internet.

The Company’s site does not publish content that is targeted to children. However, if you are concerned about your children providing the Company any personal information without your consent, please contact us on the email address below and we will endeavor to remove any such information as soon as is practicable.



XII. Enforcement


If for some reason you believe the Company has not adhered to these principles, please notify us by e-mail at privacy@suponic.com, and we will do our best to determine and correct the problem promptly. Be certain the words Privacy Policy are in the Subject line. If your privacy concerns are not addressed to your satisfaction by The Company you may contact the office the government body responsible for personal information in your jurisdiction for further guidance.



XIII. Governing Law


The Privacy Policy shall be construed in accordance with the laws of the Republic of Ireland.

INTERNATIONAL LAW IS VERY COMPLEX, AND WE DO NOT PROPOSE TO KNOW THE SPECIFIC LAWS THAT MAY APPLY TO YOU WHERE YOU LIVE. WE OPERATE UNDER STRICT COMPLIANCE WITH THE LAWS OF THE REPUBLIC OF IRELAND AND URGE YOU TO ACCESS OUR SITE ONLY IF YOU FEEL THAT YOU ARE IN COMPLIANCE WITH THE LAWS OF YOUR HOME COUNTRY.



XIV. Notice


Any notice to be given under this Privacy Policy shall be sufficient if it is in writing or by email and is sent by certified or registered mail to the Company at its registered address as the same appears on the books and records of the Company or to the Company at its principal office, attention of the CEO, or otherwise as directed by Company, from time to time.



XV. Survival


The provisions of this Privacy Policy shall survive the termination of relationship, however caused.



XVI. Privacy and Confidentiality Obligations of Purchaser


You as purchasers must keep confidential and not disclose to third parties other than tax or other advisors under similar conditions of confidentiality any and all information regarding the Company and the Company Technology provided to you.



XVII. Contact Us


Should you need to contact us with questions regarding this policy please e-mail privacy@suponic.com