Privacy Policy

Effective Date: February 25, 2019

This Privacy Policy explains how IGWT Block LLC (“IGWT Block”, “we” or “us”) collects, uses and discloses information about you when you use our website, https://www.tessab.com, and online services (collectively, the “Services”), when you interact with us as described below.

We may change this Privacy Policy from time to time in our sole discretion. If we make changes, we will notify you by revising the date at the top of this Privacy Policy, and the updated Privacy Policy will be posted via a hyperlink at the bottom of our website homepage. In some cases, we may provide you with additional notice (such as by adding a statement relating to Privacy Policy changes to our website homepage or by sending an email notification). We encourage you to review this Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you.

It is your obligation to periodically visit our Website to review any changes that may be made to this Privacy Policy. Your continued use of our Website and Services constitutes your agreement to be bound by our Privacy Policy and any changes to the Privacy Policy. If you do not agree with this Privacy Policy, you are not authorized to use our Website and your sole recourse is to not use our Website or the Services.

Collection of Information

Information You Provide to Us Directly

We collect information you provide directly to us. For example, we collect information when you interact with us as an investor, prospective investor, or former investor, when you create an account to access certain features of the Services, when you access or use any collaboration tools or participate in any interactive features of the Services, when you send us an email, fill out a form, respond to a survey, comment on a blog, register for an event, interact with us on social media, enter a promotional drawing, if any, or otherwise communicate with us. The types of information we may collect include the following:

  • Contact information and personal details, such as your name, residential, business and postal addresses, telephone number, email address, and family details such as name of your spouse, partner or children;
  • Profile information, such as the username and password you establish with the Services;
  • Demographic details, such as date of birth, country of citizenship and/or country of residence, marital status;
  • Information about your net worth and/or income, such as your stated net worth; stated current, historical, and expected future income; source(s) of income; and supporting documentation that you choose to submit (e.g., tax forms, tax returns, pay stubs, financial account statements, and information about your financial assets and liabilities);
  • Government-issued identification (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), a copy of your government-issued identification card and related government issued photographs;
  • Information about your investment experience and preferences, such as investment objectives, investment experience, liquidity needs, and risk tolerance;
  • Financial Account and payment Information, such as your bank accounts you may use to source your investment funds, other related payment information and the cryptocurrency wallet addresses you may use to receive your IGWT Block LLCs and revenue payout tokens, if any;
  • Information about your relationship to a company, such as your current occupation, job title and whether you are a beneficial owner or authorized signatory of the legal entity using the Service;
  • Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications;
  • Social media information such as username or handle, preferences; and
  • Other information you choose to provide.

Information About Your Use of the Services

When you access or use the Services, we may automatically collect information about you, such as the following:

  • Device Information: We collect information about the devices you use to access our website and Services, including the hardware model, operating system and version, unique device identifiers, network and mobile network information, and cryptocurrency wallet public keys.
  • Log Information: We collect log information about your use of the Services, including your browser type and language, app version, access times, pages viewed, Internet Protocol (“IP”) address, approximate geographic location, and the webpage, IP address, or online service you visited before navigating to the Services.
  • Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons (or pixel tags). Cookies are small data files stored on your hard drive or in device memory that help us to do things such as improve the Services and your experience, see which areas and features of the Services are popular, and count site visits. Web beacons are generally non-visible, electronic images or codes that may be used on the Services or in our emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine if an email has been opened and acted upon. For more information, please refer to our Cookie Policy.

Information We Collect from our Vendors

We may receive information about you from our vendors. For example, we use vendors to verify the identity and accredited investor status of users of our Services and perform KYC and AML checks. These vendors may provide us with information such as:

  • Whether you or your company are on government lists of restricted persons (e.g., the OFAC list or other watch lists or sanctions lists);
  • Whether there are adverse media reports regarding you or your company;
  • Whether you or your company qualifies as a “politically exposed person” (e.g., a government official or representative of an international organization) under applicable law;
  • Whether the Personal Information that you provided to us matches information contained in databases they consult; or
  • Whether you are an accredited investor per applicable law.

The information we collect from vendors may include sensitive information (e.g., criminal conviction for fraud) to the extent permitted under applicable law.

Information We Collect from Third Party Vendors and Social Media Networks

We may interact with third party companies that share your personal information with us. For example, if you establish a cryptocurrency wallet through a third party provider to make an investment through the Services, the provider of the wallet will share the address of that wallet with us. We may also maintain pages for IGWT Block LLC and our series investment offerings on a variety of third-party platforms, such as Facebook, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.

Information We Collect from Other Sources

We may also obtain information from other sources such as public databases, publicly accessible government lists or media and internet searches and combine that with information we collect through the Services. For example, we may use information from LinkedIn to update information about you in our contact database or to verify your employment.

Use of Information
Internal Use of Information

We may use information about you for various purposes, including to:

  • Operate, maintain and improve our website and the features and functionality of the Services;
  • Manage identity verification of and perform KYC and AML checks on, and accredited investor status conformation of, our prospective investors;
  • Process the investments you may make with our IGWT Block LLC series issuers through the Services;
  • Communicate with you regarding your account with us and your investments in one or more of our IGWT Block LLC series investments;
  • Respond to your questions, comments and requests;
  • Provide information or services and send related information, including confirmations and receipts;
  • Communicate about products, services, offers, promotions, rewards and events offered by IGWT Block LLC or others we think will be of interest to you;
  • Monitor and analyze usage, trends and activities related to, and the effectiveness of, the Services;
  • Manage your online account(s) and send you technical notices, updates, security alerts, and support and administrative messages; and
  • Notify you about any changes to the Services.

We may process and store information about you in the United States and other countries, which may have less protective data protection laws than the region in which you are situated.

Sharing of Information

We may share information about you as follows or as otherwise described in this policy:

  • With vendors, consultants, professional advisors and other third-party service providers who are working on our behalf and either collect or need access to your information to carry out their work for us;
  • We work with Primary Capital, LLC (“Primary”), a broker-dealer registered with the U.S. Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority, or FINRA.  Our series IGWT Block LLC securities investments are offered through Primary and we are required to disclose investor personal information to primary to comply with applicable U.S. securities laws. Primary’s use of personal information is subject to Primary’s own privacy policies;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including, for example, subpoenas and lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our user agreements or policies, to protect the rights, property and safety of us or any third party, or to protect, deter or investigate against fraudulent, harmful, unauthorized unethical or illegal activity; and
  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Please note that information you post in your profile, blogs, listings, public or private groups, forums and any other interactive areas of the Services (if any) will be available to other users of those features and, in some cases, may be publicly available.

Links to Other Websites and Third-Party Content

We may provide links to or embed videos hosted by third-party websites, services, and applications that are not operated or controlled by IGWT Block LLC. This Privacy Policy does not apply to third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.

The Services may include an activity feed, social media buttons and widgets, such as the Facebook “Like” button or the “Share This” button. Your interactions with these features are governed by the privacy policy of the third-party service that provides the feature.

Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with our legal obligations and legitimate business interests or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as proper account maintenance, IGWT Block LLC investment record keeping, facilitating client relationship management, and responding to legal claims or regulatory requests.

Data Security

IGWT Block LLC is extremely aware of the need to protect your personal data against loss and unauthorized manipulation, access or modification. To protect your personal data, we employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website and the Services. These measures are designed to appropriately protect personal information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal information in our possession. We will continuously assess and change our internal procedures accordingly to meet data protection requirements; however, no security system is impenetrable and, although we intend to do our best to protect your personal data, we cannot guarantee the security of our systems or your personal information.  You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided by you through our website or Services.

Residents of the European Economic Area

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under applicable law regarding the processing of your personal data. The term “personal data” has the meaning given to it by the EU General Data Protection Regulation (“GDPR”). When we process your personal data as described in this Privacy Policy, we will only do so when we have a legitimate interest in processing your personal data (for example, our legitimate interest in providing the Services, responding to your inquiries and sending you marketing communications), when the processing is necessary for compliance with a legal obligation to which we are subject, or when we have your consent to process your personal data. When processing is based on consent, you have the right to revoke such consent at any time. You also have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Your Choices

Account Information

You may update, correct or delete your online account information (if any) at any time by logging into your account. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes.

Promotional Communications

You may opt out of receiving marketing or promotional emails from us by following the instructions in those emails. Please note that even if you opt out of receiving promotional emails, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Information Collected Via Cookies

You may determine not to accept cookies by following the following procedures which most web browsers support: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  By blocking or disabling cookies, your experience using our website may be negatively impacted, as some features and services on our website may not work properly once our cookie is disabled. Depending on your mobile device and operating system,

Contact Us

If you have any questions about this Privacy Policy, please contact us at: [email protected]

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