Privacy policy

Latest update: December 2022

This Privacy Policy explains what personal data we gather about you and how we process your personal data onthe basis of your use of our Website or through your use of our services, which services include campaigns, surveys and competitions which we launch from time to time. Any queries relating to this Privacy Policy and any other aspects of your data privacy can be addressed to us at

When we refer to «we» or «us» this refers to EasyDevelopment Inc., a company registered in US with company registration number 13 477 915, and with the registered address at 8 the Green, Suite # 10 258; Dover, DE, 19 901, United States which operates under the brand name «Rate Club». EasyDevelopment Inc. is the data controller, being the company that's responsible for your privacy pursuant to this Privacy Policy.

When we refer to «our Website» or «this Website» or «our Site» in this Privacy Policy we mean the specific webpage of Pantheon —

In this Privacy Policy, your information is called «personal data» or «personal information». We also collectively refer to handling, collecting, protecting and storing your personal information as «processing» such personal information.

a. What personal data do we process?

Our Site is designed in such a manner that it makes it possible for users to visit and use our Website without disclosing or revealing any personal information about themselves. However, you may choose to provide us with personal information when you contact us via the ‘Contact Us' page on our Website. Should this occur, we oblige ourselves to process any such personal data that you may provide in full accordance with all applicable data policy laws, and in such a manner that is necessary for us to be able to respond and administer any request that you may make.

You may also decide to provide us with your personal information when signing up or participating in surveys, campaigns, competitions or other activities organized by us. The personal information so collected normally includes your full name as well as your contact details which shall all be processed strictly in accordance with this Privacy Policy and in such a manner to ensure the proper conduct of the survey, campaign, competition or other activity concerned.

From time to time, we may further process your personal data to provide you with information about developments taking place in our business industries, and which we feel may be of interest to you. However, this will be subject to you giving us prior consent for such personal data processing. Please inform us by sending an email to if you do not wish to receive such information from us.

Furthermore, we are entitled to request from you, at any point in time, information and/or other documentation that we, in our sole discretion, deem fit and necessary in order to comply with any applicable law or regulation in connection with the holding and using of Rate Coin (RC).

We also gather other information when you access our Website. To find out more about how we use cookies, please see our Cookie Notice available here.

b. Providing personal data to third parties

We do not pass on your personal data, collected from you as a visitor to our Website, to any third party unless you provide us with your consent to do so. Such disclosure to third parties would be required to provide to you our services, such as running campaigns and competitions which may be conducted with the assistance of third parties. Your refusal to provide such third parties with your personal information may disqualify you from participating in the campaigns or competition concerned. Furthermore, your personal information will be shared with third parties, without the need of obtaining your consent, in the instances indicated below.

You will be aware however that personal data sent via the internet may be transmitted across international borders, even where the sender and the receiver of such information are located in the same country. Consequently, data relating to you may be transmitted via a country having a lower level of data protection than that existing in your country of residence.

Without prejudice to anything contained in this Privacy Policy, we reserve the right to disclose personal data relating to you to any third party, if such disclosures are necessary inter alia for the following purposes:

  • For the purpose of preventing, detecting or suppressing fraud or any other criminal activity;
  • Where it is a matter of national or public security;
  • In the interest of national budgetary, monetary or taxation matters that can arise;
  • To protect and defend our rights and property or that of users of our Website;
  • To protect against abuse, misuse or unauthorized use of our Website;
  • To protect the personal safety or property of users of our Website (e.g. if you provide false or deceptive information about yourself or attempt to pose as someone else, we shall disclose any information we may have about you in our possession so as to assist any type of investigation into your actions);
  • For any purpose that may be necessary for the performance of any agreement you may have entered into with us;
  • As may be allowed or required by or under any law.

c. Retention of personal data

No personal data that we process will be kept longer than necessary for the purposes for which it is collected. In particular, we shall retain your personal information for the longer of the following periods: (i) the end of the relevant campaign, competition, survey or other activity being the purpose for which you have provided your personal data; (ii) any retention period that is required by law (including but not limited to any prevention of money laundering and funding of terrorism legislation that may be applicable); or (iii) the end of the period in which litigation or investigations might arise in respect of your use of our services.

d. Compliance

This Privacy Policy and all other personal data processing we may undertake is in strict accordance with Data Protection Act 2018 and EU Regulation 2016/679 (General Data Protection Regulation). We will also endeavor to employ all reasonable measures to safeguard the confidentiality and security of all personal data that may be processed by us at any time. Such measures include the following:

  • Administrative and technical controls to restrict access to personal data on a ‘need to know' basis;
  • Physical security measures, such as staff security passes to access our premises;
  • Technological security measures, including firewalls, encryption and anti-virus software.
  • Where data is processed by a third-party as outlined in this Privacy Notice, we ensure that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that any processing by them satisfies the legal requirements in terms of applicable data protection laws, including the protection of your rights. Moreover, we also ensure that processing by third parties is governed by an agreement between us and third party which includes the necessary contractual clauses to ensure protection of your personal data.

Although we use appropriate security measures once we have received your personal data, we remind you that by its very nature the internet may not always be a secure medium and data sent via the internet can potentially be subject to unauthorised acts by third parties. We cannot guarantee the privacy or confidentiality of any information passing over our Website, nor shall we accept any responsibility or liability whatsoever for the security of your personal data while in transit through the internet.

e. Third party websites

Our Website may from time to time contain links to both local and international third party websites after obtaining permission from them. Any such links are not an endorsement by us of any information in such website or products and/or services offered through the same. We shall not accept any responsibility whatsoever for the content, use, availability, privacy practices or the content of any such websites. Please note that upon entering such other websites, you become subject to the privacy policy of such other sites.

No third party is permitted to link any other website to our website without obtaining our prior consent in writing.

f. Changes to this Privacy Policy

We reserve the right to unilaterally modify this Privacy Policy at any time, particularly if statutory obligations so mandate or the interest of our users' security so requires. To let you know when we make changes to this Privacy Policy, we will amend the revision date at the bottom of this page. The modified Privacy Policy will apply from such revision date. We will not officially notify you about such changes, and it is therefore in your own interest to check this Privacy Policy page from time to time so as to familiarize yourself with any changes.

g. What are your rights?

Provided you fall within the legal definition of a ‘data subject' under the Data Protection Act 2018, you have the right to find out what information the government and other organisations store about you. These include the right to:

  • be informed about how your data is being used;
  • access personal data;
  • have incorrect data updated;
  • have data erased;
  • stop or restrict the processing of your data;
  • data portability (allowing you to get and reuse your data for different services);
  • object to how your data is processed in certain circumstances.

Any request to exercise any of your above rights must be made in writing to us at the following mailing address and must be signed by yourself as the data subject to whom the particular personal data relates to.

We shall provide you with access to your personal data, including a copy thereof, at no charge. However, if your requests in exercising your above rights be manifestly unfounded or excessive, in particular repetitive in nature, we reserve the right to charge you an administrative charge (determined at our sole discretion) of which you shall be informed beforehand.