Privacy Policy

Effective 27 November, 2017

Welcome to the website of nTitle GmbH (“nTitle”). This Privacy Policy covers any of your Personal Information obtained by nTitle. The term “nTitle” refers to all these entities collectively. If we make any material changes, we will post the new policy here, with a new effective date.

By using nTitle websites, which include and other names under which we do business (collectively, “Site”), you consent to use of information that is collected or submitted as described in this Privacy Policy.

“Personal information” is data about an individual who can be identified from that data, or from that data and other information to which we have access. Personal Information is usually your name in combination with another identifier, such as date of birth, address.

We will collect Personal Information when you participate in the nTitle Token Sale (the “Token Sale”).

What Personal Information Do We Collect?

We may ask you for your name and postal address, email address, and telephone number information when you participate in the nTitle Token Sale and/or to create, complete or update your nTitle account.

We may seek Personal Information regarding your age to verify that you are not a minor in accordance with our policy against doing business with children, set forth below.

You are not required to provide the personal information we request, but if you decline, you may not participate in the Token Sale and we may not be able to respond to queries you may have.

How Do We Use Your Personal Information?

To transact business with you in connection with the Token Sale and related transactions (e.g. requests for information about our nTitle token or other products or services) and otherwise serve you as a customer;

To assess your interests, preferences and degree of satisfaction with the Token Sale and/or related products and services;

To keep you posted on new or updated nTitle token offerings or related products, services and/or upcoming events;

To improve the effectiveness of the Site, products, services, operations, mobile experience or marketing efforts;

To verify your identity and eligibility for the Token Sale and/or related products and services;

To conduct auditing, data analysis, and research to improve nTitle’s products, services, and customer communications;

To allow our employees to service your customer needs;

To prevent, deter and investigate violation of this Privacy Policy and our Terms and Conditions, or any fraud and other illegal activities; and

To send you important notices regarding your purchases and changes to our business policies.

With Whom Do We Share Your Personal Information?

We may provide your Personal Information to affiliated companies.

We may provide your Personal Information to business partners or others who process it on our behalf.

We share your Personal Information with third party services who facilitate the Token Sale, manage and enhance our systems or customer data, provide customer service, assess your interest in our products and services, and conduct customer research or satisfaction surveys. The companies have agreed to protect your information as a condition of receiving or processing it.

We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Service, this Privacy Policy or to otherwise protect our operations or users.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.

We may share your Personal Information with our dealers, suppliers and partners, who may provide you with SMS, email and other communications and offers for products and services, including offers based on your interests, personal and business characteristics, stated preferences and location.

How Do We Protect Your Personal Information?

We maintain a variety of security measures, including physical, electronic and procedural safeguards. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Access to Personal Information

You can ask us for the Personal Information we possess, so that you can determine if it is inaccurate or if you want it deleted, provided that we are not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to [email protected]

What Other Information Do We Collect?

We automatically gather information when you browse or view our Site. This log data may include your browser type (e.g., Chrome, Safari, Firefox or Internet Explorer), your domain, the Internet Protocol (IP) address assigned to your computer (or the unique device ID of your mobile device, or other unique identifier), the date and time of your visits, the pages on our site you visit and other information related to your visit.

We collect data that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose such non-personal information for any purpose.

If we combine non-personal information with your Personal Information, we will maintain the combined information as Personal Information for as long as it remains combined.

We may collect information such as language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a Token Sale participant is located so that we can better understand customer behavior and improve our products, services, and advertising.

We may collect aggregated information regarding participant activities on our Site, mobile application, and from our other products and services we may offer.

We may collect details of how visitors to the Site use our services.

How Do We Employ Cookies and Similar Technologies?

We use technologies such as “cookies” and web beacons so we can remember certain information about you, remember your preferences or recognize you when you return. They also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Site and protect our Site from fraud.

A cookie is a text file that stored on your computer. As text files, cookies cannot read information on your hard drive, run programs or deliver viruses to your computer. Cookies let our Site remember your preferences or recognize you when you return.

Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. Note that declining cookies may hinder our Site’s performance and may not allow you to access all of its features and services.

Web beacons, also known as clear GIFs, are often used in combination with cookies. These often transparent images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Site is used. They are not used to access Personal Information.

Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

As do many internet sites, we gather some information automatically, such Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

In some of our email messages, you will find a “click-through URL” linked to content on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.

We use Google Adwords and Google Analytics to gather data such as age, gender and interests to provide advertising targeted to suit your interests and preferences. For example, you may see certain online ads on our Site or other sites because we contract with Google and similar companies to target our ads based on information collected from you or by automated means, like cookies and web beacons. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at and edit or opt-out your Google Display Network ads’ preferences at

You may give consent for our Site to capture and record certain precise geo-location or global positioning data from your device in order to tailor information to your location. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Site.

You should be able to manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device’s privacy and security settings.

There are “do not track” or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Site will not operate any differently when a “do not track” signal is received.

Social Networking Sites

You may be able to post content to Social Networking Sites (such as Facebook, Instagram, Snapchat or Twitter) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Sites in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network Sites.

Third Party Links

Our Site may have links or be linked to other sites we do not own, control or maintain. We are not responsible for and make no representations or warranties about the privacy practices of those sites. We recommend that you check the privacy policies of other sites and contact the operator if you have concerns or questions. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third party sites.


The Site allows users to exchange money for NTL Tokens. No individual under the age of eighteen (18) may use the services, regardless of any consent from your parent or guardian to use the services. If you are under the age of majority where you live, you must obtain consent from your parent or guardian to use the services. Notwithstanding the foregoing, you may not use the services if you are under the age of majority where you live if you use PayPal in association with your account.

If you are under eighteen (18) years old, you are not allowed to use the Site. If we learn that we have collected personal information from anyone under the age of 13, we will endeavor to delete such information as soon as reasonably possible.

Privacy Rights of California Residents

If you are a California resident, you may have the right to request and receive certain information about a company’s disclosure of your personal information to third parties for their own direct marketing use, and your choices with respect to such disclosures.

California Civil Code Section 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected], or write us at:

nTitle GmbH
Joan Muyskenweg 22
2nd Floor, Unit 9
1098 CJ, Amsterdam
The Netherlands

Changes to our Privacy Statement

We may update this Privacy Statement from time to time, so please check the effective date at the top of this page as the date of last revision. Changes will become immediately effective upon posting on our Site unless otherwise noted. Your use of the Site following these changes indicates your consent to the practices described in the revised Privacy Statement.

Opting Out of Communications

You may opt-out of receiving marketing-related emails by clicking the "unsubscribe" link at the bottom of any email you receive from us or by changing the communication preferences on your online account or profile. If you no longer want to receive promotional text messages from us, please follow the cancellation instructions contained in the last text message. If you are having difficulty unsubscribing from our marketing communications using the above methods, please contact us at [email protected]

If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your orders, customer service inquiries, promotions participation and other matters.

If you agreed to receive future marketing communications directly from a third party through our Site, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s Privacy Policy.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information at [email protected]