Privacy Policy
Origin Labs - Trading as: Tokenizd
Last updated: January 2025 | Version 1.1
Preamble
Origin Labs, a French company (SAS) operating under the trading name "Tokenizd", respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our platform.
This policy complies with the General Data Protection Regulation (GDPR) and applicable French laws regarding data protection.
Article 1 - Data Controller
Legal Entity: ORIGIN LABS
Trading Name: Tokenizd
Legal Form: SAS, société par actions simplifiée
SIREN: 988 746 624
SIRET (Head Office): 988 746 624 00010
VAT (TVA) No.: FR60 988 746 624
EORI: No valid EORI number
NAF/APE: 62.01Z — Programmation informatique
Registered Address: BUREAU 326, 78 AVENUE DES CHAMPS ELYSÉES, 75008 PARIS
Capital: 35 000,00 € (fixed)
Activity: Development of technological solutions for asset tokenization
Contact for data protection matters:
Email: tokenizd@originlabs.app
Data Protection Officer: tokenizd@originlabs.app
Article 2 - Data We Collect
2.1 Information You Provide
- • Account registration information (email, username)
- • Profile information and preferences
- • Communication data (support requests, feedback)
- • Asset information for tokenization
- • Identity verification data (if required by regulation)
2.2 Automatically Collected Information
- • Device information (IP address, browser type, operating system)
- • Usage data (pages visited, time spent, interactions)
- • Cookies and tracking technologies
- • Connection and activity logs
2.3 Blockchain Data
Important: Blockchain transactions are public and immutable. Wallet addresses and transaction history cannot be deleted from the blockchain. This data is not under Origin Labs' control.
Article 3 - Purposes of Data Processing
We use your personal data for the following purposes:
- • Provide and maintain our platform services
- • Process transactions and tokenization requests
- • Send important notifications and updates
- • Improve platform functionality and user experience
- • Comply with legal obligations and prevent fraud
- • Provide customer support
- • Perform anonymized statistical analysis
Legal Basis for Processing
- • Contract performance: provision of platform services
- • Legal obligation: regulatory compliance, fraud prevention
- • Legitimate interest: service improvement, platform security
- • Consent: marketing communications (with withdrawal option)
Article 4 - Data Sharing and Disclosure
We do not sell your personal data. We may share your information in the following situations:
- • With your consent or at your direction
- • To comply with legal obligations or court decisions
- • To protect our rights and prevent fraud
- • With service providers (under strict confidentiality agreements)
- • In case of merger, acquisition, or business transfer
- • With competent authorities if required by law
Service Providers
We work with third-party service providers for hosting, analytics, customer support, and other services. These providers have access to personal data only to the extent necessary to provide their services and are contractually bound to protect it.
Article 5 - Data Security
Technical Security Measures
- • End-to-end encryption for sensitive data
- • Multi-signature security protocols
- • Regular security audits and penetration testing
- • Compliance with security standards
- • Employee access controls and monitoring
- • Secure backup and recovery plans
Access Limitation: Access to personal data is strictly limited to employees and contractors who need it to provide our services. All access is logged and monitored.
Breach Notification: In case of a personal data breach presenting a risk to your rights and freedoms, we will inform you as soon as possible in accordance with regulations.
Article 6 - Cookies and Tracking Technologies
We use cookies and similar technologies for:
Essential Cookies
- • Platform functionality
- • Authentication and security
- • Language preferences
- • Cart and sessions
Analytics Cookies
- • Performance analysis
- • Usage statistics
- • Experience improvement
- • Anonymous aggregated data
Cookie Management: You can control and manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality.
Article 7 - Your Data Protection Rights
Under GDPR, you have the following rights regarding your personal data:
Access and Rectification Rights
- • Access your personal data
- • Correct inaccurate information
- • Obtain a copy of your data
- • Complete incomplete data
Erasure and Restriction Rights
- • Delete your account and data
- • Restrict processing of your data
- • Object to processing
- • Withdraw your consent
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
Exercising Your Rights
To exercise your rights, contact us at: tokenizd@originlabs.app
We will respond to your request within one month. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority.
Article 8 - Data Retention
We retain your personal data for as long as necessary to provide our services, comply with legal obligations, and resolve disputes.
Retention Periods
- • Active account data: During your use of the platform
- • Closed account data: 3 years after closure (legal obligations)
- • Support data: 3 years after issue resolution
- • Security logs: 1 year for fraud detection
- • Marketing data: Until consent withdrawal
Automatic Deletion: Upon expiration of retention periods, your data is automatically deleted from our systems, unless legal obligations require otherwise.
Article 9 - International Data Transfers
Your data may be transferred to and processed in countries other than France. We ensure appropriate safeguards are in place to protect your data during international transfers:
- • European Commission adequacy decisions
- • EU Standard Contractual Clauses
- • Binding Corporate Rules
- • Approved certifications and codes of conduct
For more information about the safeguards in place, contact us at tokenizd@originlabs.app.
Article 10 - Protection of Minors
Our platform is not intended for persons under 18 years of age. We do not knowingly collect personal information from minors.
If we learn that a minor has provided us with personal data, we will delete it immediately. If you believe a minor has provided us with personal data, please contact us immediately at tokenizd@originlabs.app.
Article 11 - Links to Third-Party Sites
Our platform may contain links to external websites. This Privacy Policy does not apply to third-party sites.
We recommend reviewing their privacy policies before providing personal information. We are not responsible for the privacy practices of third-party sites.
Article 12 - Updates to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated through:
- • Email notification to registered users
- • Announcement on the platform
- • Update of the last modified date
Continued use of the platform after changes constitutes acceptance of the updated policy.
Article 13 - Contact Us
For any questions about this Privacy Policy or to exercise your rights:
General Information
Email: tokenizd@originlabs.app
Support: tokenizd@originlabs.app
Data Protection Officer: tokenizd@originlabs.app
Supervisory Authority
For EU residents:
Contact your local data protection authority
For French residents:
Commission Nationale de l'Informatique et des Libertés (CNIL)
Website: www.cnil.fr
Document established by Origin Labs (trading as: Tokenizd)
Compliant with GDPR and applicable data protection laws