Privacy Notice

Last Updated: September 7, 2023

1. Why Do You Need this Privacy Notice?

We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with your access to and use of the Services.

In this Privacy Notice, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual. In this Privacy Notice we explain which types of personal data we hold on you, how we collect and process such data, how ong we keep it, and so on.

2. Where Can You Find the Definitions?

Unless otherwise provided in this Privacy Notice, capitalized terms used in this Privacy Notice have the meaning determined in the (the “Terms”). We encourage you to read the Terms carefully as they affect your obligations and legal rights.

3. Who Are We and How to Reach Us?

When we say “we”, “us”, or “our”, we mean CPEX DLT Inc., a BVI business company. With respect to personal data collected when you access and use the Services, we act as a data controller, meaning that we solely determine what data collected and the purposes and means of data processing.

We process your personal data in accordance with this Privacy Notice and we endeavor to comply with the applicable data protection legislation. 

If you have any questions regarding this Privacy Notice or the processing of your personal data, do not hesitate to contact us via the following contact details:

Name: CPEX DLT Inc.

Address: Intershore Chambers, PO Box 4342, Road Town, Tortola, VG1110,  British Virgin Islands.


4. What Personal Data Do We Collect?

The categories of personal data we collect depend on how you interact with us, use the Services, and the requirements of the applicable laws. We collect and process the following types of personal data as outlined below. Please note that we may also collect certain other information, which may be required under the applicable laws.

Category of Data



Other Comments

Account Data

email address


Mandatory data. Email address may be considered personal data.

full name

This includes your first name, last name and middle name, if any.

Mandatory data.





The data is optional and provided at your discretion.




Description of yourself

Certificate Data

Certificate details

This may include your name and Certificate number.

The data is generated automatically if you obtain a Certificate. Without other data, your Certificate number is not personal data as it does not allow anyone to identify you.

Testimonials Data

testimonials details 

This primarily includes your name, however may also include other data that you choose to provide.

This data is optional and provided at your discretion. Unless reasonably necessary, please do not provide additional data.

Payment Data

payment details

Depending on the chosen payment method, this may include:

  1. wallet address (public address on the respective blockchain associated with the relevant wallet);

  2. account details (account number, beneficiary name, etc.);

  3. card details (card number, name of the holder, security code (CVV), expiry date, etc.);

  4. billing information (full name, country of residence, city, ZIP code, street name, building and/or apartment number);

  5. transaction details (amount, time, currency/token, status, transaction ID, etc.).

Mandatory data, if you make a payment.

Please note that payment details may be processed by the respective payment processors and/or payment service providers that you choose or which are available at the payment stage. They are separate data controllers with respect to such data. We do not manage, control, or affiliate with such payment processors and/or payment service providers.

Please note that we do not have access to your full card details as they are processed by the respective payment processor and/or payment service provider.

Contact Data

full name

This includes your first name, last name and middle name, if any.

Optional data, provided only if you contact us.

contact details

This may include your email address, phone number, etc.

any other data requested by us or data that you choose to provide us with

Please do not provide personal data unless it is reasonably necessary or requested by us.

5. How Do We Use Personal Data?

Category of Data


Lawful Basis for Processing

Account Data

To create and register a User Account in order to access and use certain Services.

To perform a contract with you.

Certificate Data

To issue a Certificate of course completion and maintain a database of persons who passed our course and received a Certificate.

Our legitimate interest to maintain a database of persons who passed our course and received a Certificate.

Testimonials Data

To publish Users’ thoughts on the Services.

Our legitimate interest to demonstrate Users’ feedback.

Payment Data

To process payments arising when you use the Services. 

To perform a contract with you.

Our legal obligation to keep and retain the financial records to comply with the applicable laws.

Our legitimate interest to prevent and detect fraud and abuse, and protect the security of the Services.

Contact Data

To respond to your inquiry.

Our legitimate interest to respond to your inquiry.

6. How Long Do We Process Your Data?

As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:

(a) to meet our legal obligations under the applicable law;

(b) in relation to anticipated or pending legal proceedings; or 

(c) to protect our rights and legitimate interests or those of third parties.

Category of Data

Storage Period


Account Data

As long as you keep your User Account with the Platform.

We process your Account Data as long as it is necessary for the operation of your User Account.

Certificate Data

Until you request us to erase it.

We process such data as long as we maintain the Services to ensure that issued Certificates can be verified where necessary.

Testimonials Data

Until we remove your testimonial or you request us to erase it.

We don’t need to store your testimonials forever. So, if you think that we should remove it, just let us know.

Payment Data

As long as you keep your User Account and for seven (7) years after the completion of the respective payment. 

Please note that due to the nature of a blockchain, the wallet addresses and Payment Data associated therewith may be stored permanently on the applicable blockchain (not by us).

We set this retention period due to the retention period for Payment Data established under our policies and procedures and the law of our jurisdiction.

Contact Data

For one (1) year from the last date when you contacted us regarding the same matter.

We set this retention period due to the statutes of limitations established in the Terms.

7. How Do We Share Your Data?

General. We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, applicable legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary:

(a) to provide you with access to the Services and performance of our undertakings with you; 

(b) for compliance with the applicable laws and regulations; or 

(c) for our legitimate interest to maintain, improve and develop the Services. 

Please note that if we share any portion of your personal data with third persons, we will endeavor to secure such transfer using appropriate legal, organizational, and technical measures.

Recipients. Given the purposes outlined above, your personal information is shared with the following categories of recipients:

  1. Affiliates;

  2. email verification service providers;

  3. email delivery service providers;

  4. support and technical teams;

  5. hosting service providers; 

  6. payment processors and payment service providers;

  7. government authorities, upon their request or if necessary to comply with our legal obligations;

  8. another entity if we sell or otherwise transfer the Services or their part; and

  9. other third-party solutions, which may be from time to time integrated in relation to the Services.

Intricacies. Certain data will be publicly available:

  1. data that is stored on a blockchain, as described in Section “What Are the Features of Blockchain Data Processing?”;

  2. Certificate Data — any person knowing your Certificate ID can validate it within the Platform. Consider this feature before sharing your Certificate ID;

  3. Testimonials Data — this data is obviously publicly available, so other Users or potential Users may make a decision regarding the Services or their specific parts.

8. What Are the Features of Blockchain Data Processing?

Please note that the wallet addresses and Payment Data associated therewith may interact with public decentralized blockchain infrastructures and blockchain-based software, including smart-contracts, that work autonomously. The data entered in a public decentralized blockchain is distributed via the nodes that simultaneously store all records entered into the blockchain.

By design, blockchain records cannot be changed or deleted and are said to be “immutable”. Please be aware that any transaction within a blockchain is irreversible and information entered into a blockchain cannot be deleted or changed. Therefore, your ability to exercise certain data protection rights or abilities may be limited. 

In addition, due to the blockchain’s nature, the information that was entered in a blockchain will be publicly available and we may neither control such information nor manage access to it. Once you start carrying out transactions, certain data, which may be considered personal, will become publicly available on a blockchain. The ultimate decision whether to transact on a blockchain or carry out any transactions rests with you.

9. Are You Subject to Automated Decision-Making?

Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. We do not make any automated decisions based on your personal data. If we intend to process your personal data by any automated means, we will do our best to inform you about the same prior to such processing.

10. What About Interacting with Third-Party Links?

The Platform may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share certain data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Platform, we encourage you to read the privacy policy/notice/statement of every website or application you visit.

11. What Data Subject Rights Do You Have?

General. According to the applicable data protection legislation, you may have the rights outlined below. In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.

Blockchain Data Processing. Please note that when you interact with a blockchain, we may not be able to exercise certain rights that you may have pursuant to the applicable data protection legislation with respect to the wallet addresses and Payment Data associated therewith. For instance, we may not be able to ensure that such personal data is deleted, corrected, or restricted. You may learn more above in the “What Are the Features of Blockchain Data Processing?” section of this Privacy Notice.

Data Subject Rights. According to the applicable legislation, you may have the following rights:



Right to access your personal data 

This enables you to ask us whether we process your personal data. If we process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you, and check that we are lawfully processing it.

Right to rectification of the personal data

This enables you to have any incomplete or inaccurate data we hold about you completed or rectified, though we may need to verify the accuracy of the new data you provide to us.

Right to erasure of your personal data (commonly known as a “right to be forgotten”)

This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 

Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request

Right to object to processing of your personal data

This enables you to 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 as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict the processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data (commonly known as a “right to the data portability”)

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you

Right to withdraw consent

You may withdraw your consent at any time where we are relying on consent to process your personal data.

Right not to be subject to automated decision-making

If and to the extent applicable, you reserve the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you.

Right to file a complaint

You may file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable legislation. The relevant supervisory authority will particularly depend on where you are located. 

12. Do We Process Children’s Personal Data?

The Services are not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children.

If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.

13. Can We Modify and Update this Privacy Notice?

We keep our Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice to check for the updates. If we make substantial changes to the way we treat your personal information, we will display a notice on the Platform.