Privacy Policy for MEDRE Token

Last updated: May 22, 2025

This Privacy Policy describes how MEDRE Token, currently operated by Danny Schuller ICT (a sole proprietorship based in The Netherlands, soon to be incorporated as a B.V. into a holding company where the token will also reside), collects, uses, and discloses information when you use our website.

We are committed to protecting your privacy. This policy explains what information we collect, why we collect it, and how we handle it.

1. Who We Are

MEDRE Token is currently operated by Danny Schuller ICT, a sole proprietorship based in The Netherlands. Please note that this is a temporary operational setup. We are in the process of establishing a new, dedicated legal entity (a B.V.) which will become part of a larger holding company structure. The MEDRE token itself will also officially reside within this new corporate structure.

Contact for Privacy Questions: [email protected]

2. Information We Collect

We collect limited personal data from our website visitors. The types of information we collect include:

Information You Provide Voluntarily (Contact Form & Presale Onboarding Form):
- General Contact Form: When you use our general contact form, we collect your Name and Email Address to respond to your inquiries.
- Presale Onboarding Form: When you use our dedicated form for presale onboarding, we collect additional information necessary to assess your eligibility and acknowledge risks associated with potential investment. This may include:
  - Full Name
  - Indication of Private Individual or Business Entity
  - Confirmation of being 18 years of age or older
  - Country of Residence
  - Information on how you heard about the project
  - Your acknowledgment and agreement to specific investment risks (as indicated by your ability to submit the form).
  - Other fields may be added to these forms in the future.
Automatically Collected Information (Usage Data via Google Analytics): Like many websites, we use Google Analytics to understand how our website is used. This service collects anonymous data about your visit. Please note that Google Analytics will only load and collect data if you provide your consent via our cookie consent banner. If you decline analytics cookies, this data will not be collected. The data collected may include:
- Usage Data: Information on how you interact with our website, such as the pages you visit, the time spent on those pages, and the features you use.
- Technical Data: Your IP address (anonymized where possible by Google Analytics), browser type, operating system, and device information.
- Location Data: Approximate location information derived from your IP address.

We do NOT collect financial details (like credit card or bank account numbers), sensitive demographic information (e.g., gender, race), or user-generated content from our website visitors through general Browse or these forms. We do not perform direct financial transactions via our website at this stage.

3. How We Collect Information

Directly from You: Information in our contact forms (general and presale onboarding) is provided directly by you when you fill out and submit the respective form.
Automatically (with consent): Usage data and technical data are collected automatically through the use of cookies and similar tracking technologies by Google Analytics, but only after you have explicitly given your consent via our cookie consent banner.

4. How We Use Your Information

We use the information we collect for the following purposes and based on the following legal bases:

To Respond to Your General Inquiries: If you use our general contact form, we use your name and email address to respond to your questions or requests. This processing is based on our legitimate interest to communicate with individuals who express interest in our project.
To Assess Eligibility for Presale Participation & Acknowledge Risks:
- We use the data collected via the presale onboarding form to determine your eligibility to participate in potential future presale events. This includes confirming your age and country of residence for compliance purposes.
- Your ability to submit the form after acknowledging risks indicates your understanding and agreement to those risks.
- This processing is based on our legitimate interest to manage our presale process and ensure we are engaging with appropriate potential participants. It may also be considered a pre-contractual step as it directly precedes potential token purchase agreements. Your act of submitting the form following risk acknowledgment serves as a form of explicit consent to this screening process and risk acceptance.
To Understand and Improve Our Website (with consent): The anonymous data collected through Google Analytics helps us understand how our website is being used, identify areas for improvement, and enhance the user experience. This processing is based on your explicit consent, which you can withdraw at any time.

5. How We Share Your Information

We do not sell, trade, or otherwise transfer your Personal Identifiable Information (PII) collected via the contact forms to outside parties, except as described below:

Google Analytics: We share automatically collected usage data with Google Analytics, a third-party analytics service. Google Analytics processes this data on our behalf to provide us with reports on website activity. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.
Legal & Compliance Purposes: We may share presale onboarding data with legal counsel or advisors as necessary to ensure compliance with relevant regulations (e.g., securities laws) or in response to lawful requests by public authorities.

6. Data Retention

General Contact Form Data: We retain general contact form submissions for a period necessary to adequately respond to your inquiry and for a reasonable period thereafter for record-keeping purposes, typically no longer than one (1) year, unless ongoing communication or a business relationship is established.
Presale Onboarding Data: Data collected for presale onboarding will be retained for a period necessary to assess eligibility, manage potential presale participation, and comply with any relevant legal or regulatory obligations related to investment offerings. This period may extend beyond one year, depending on the nature of future interactions and regulatory requirements. Specifically, data for individuals who do not proceed with a presale or are not accepted into the pre-seed/seed onboarding will be deleted within one (1) year, following a single follow-up email to inform them about potential eligibility for subsequent investment rounds. For those who do participate in a presale, data will be retained for longer periods as required by applicable laws and regulations.
Google Analytics Data: Google Analytics data is retained according to our configuration within Google Analytics, which aims to minimize retention periods where possible, and Google’s general data retention policies.

7. Data Security

We are committed to ensuring the security of your information. We implement reasonable technical and organizational measures to protect your data, including:

Encryption: Our email environment uses encryption to protect communications.
Secure Servers: Our website and email systems are hosted on secure servers with appropriate security measures.
Access Controls: Access to personal data is restricted to authorized personnel who need to access it for legitimate business purposes.

While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

8. Children's Privacy

Our website is not intended for individuals under the age of 18. We do not knowingly collect Personal Identifiable Information from anyone under 18. If we become aware that we have collected PII from an individual under 18, we will take steps to remove that information from our servers.

9. Your Rights Under GDPR (for EU/EEA Users)

As an EU/EEA resident, you have certain rights concerning your personal data:

Right to Access: You have the right to request copies of your personal data we hold.
Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
Right to Erasure (Right to be Forgotten): You have the right to request that we erase your personal data, under certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Right to Withdraw Consent: Where we rely on your consent for processing (e.g., for Google Analytics), you have the right to withdraw that consent at any time.

Since we primarily collect data through a contact form and anonymized website tracking (only with consent), and do not maintain user accounts, you currently do not have direct access to update or delete your information through our website. However, if you have submitted information via our contact form or wish to exercise your rights regarding data collected through Google Analytics, please contact us at the email address provided below.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us

If you have any questions about this Privacy Policy, or if you wish to exercise your data protection rights, please contact us at:

Email: [email protected]