Privacy Policy

Privacy policy

Brokoli OÜ (hereinafter – “Brokoli”) values the privacy of visitors to Brokoli’s websites. To ensure transparency, this Privacy Policy describes Brokoli’s information handling practices when you access content Brokoli owns or operates on the websites located at, or any other websites, pages, features, or content Brokoli owns or operates (collectively, the “Website(s)”). Acknowledge yourself with this Privacy Policy carefully. If you have any questions about this Privacy Policy, please contact Brokoli at [e-mail].

Acceptance of Privacy Policy 

By accessing and using the Website, you signify acceptance of the terms of this Privacy Policy. Where Brokoli requires your consent to process your personal information, Brokoli will ask for your consent to the collection, use, and disclosure of your personal information as described further below. If you do not agree with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Website.

Changes to Privacy Policy

Brokoli reserves the right to modify this Privacy Policy at any time, and when required by law, Brokoli will notify you of changes to this Privacy Policy. If Brokoli makes any material changes, Brokoli will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective.

Information about Brokoli Ltd.

Brokoli OÜ is a private limited company incorporated in Estonia with company number 16245034 and whose registered office is Papiniidu tn 5 Pärnu, Pärnu Pärnumaa 80042. Brokoli will be conducting an SHO via Strong Holder offering (hereinafter – “SHO”) and then developing Brokoli project as described on the Website, DAO maker website:  and Greenpaper.

Personal information collected

Brokoli collects personal information to contact you and to allow you to participate in Brokoli’s SHO. When Brokoli requires certain personal information from users it is because Brokoli is required by law to collect this information or it is relevant for specified purposes. Any information you provide to Brokoli that is not required is voluntary. You are free to choose whether to provide Brokoli with the types of personal information requested, but Brokoli may not be able to serve you as effectively or offer you all of Brokoli’s services when you do choose not to share certain information with Brokoli. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you. For example, Brokoli collects personal information which is required for Brokoli‘s KYC/AML services provider to verify your identity. Brokoli also collects personal information when you use or request information about Brokoli SHO, subscribe to marketing communications, request support, complete surveys, etc. Brokoli may also collect personal information from your offline, for example when you contact Brokoli’s customer support.  Brokoli collects the following types of information: Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email. Formal Identification Information: Tax ID number, passport number, national identity card details, photograph identification cards. Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification. Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses. Usage Data: Survey responses, the information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data, and other data collected via cookies and similar technologies.

How your personal information is used

Brokoli’s primary purpose in collecting personal information is to provide you with the most accurate information about Brokoli’s SHO and to make sure that any funds gathered during SHO are legal and can be used to develop a great product for you. In general, Brokoli uses personal information to create, develop, operate, deliver, and improve Brokoli’s Website, content, and advertising, and for the prevention of anti-fraud. Brokoli may use this information in the following ways based on Brokoli’s contract with you: To maintain legal and regulatory compliance: yo legally use the funds gathered during SHO Brokoli is subject to laws and regulations requiring Brokoli to collect and use your personal identification information, formal identification information, transaction information, online identifiers, and/or usage data in certain ways. For example, Brokoli must identify and verify customers sending funds to Brokoli’s SHO in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, Brokoli uses third parties to verify your identity by comparing the personal information you provided against third-party databases and public records.  To provide you services: Brokoli processes your personal information in order to provide services to you. For example, when you want to buy Brokoli tokens, Brokoli requires certain information such as your identification, contact information, and payment information. Brokoli cannot provide you with services without such information. To provide Service communications: Brokoli sends administrative information to you to keep you updated about Brokoli’s SHO, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect you. To provide customer service: Brokoli processes your personal information when you contact Brokoli to resolve any questions, disputes, or troubleshoot problems. Brokoli may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, Brokoli cannot respond to your requests. To ensure quality control: Brokoli processes your personal information for quality control and staff training to make sure Brokoli continues to provide you with accurate information. If Brokoli does not process personal information for quality control purposes, you may experience issues on the Website. Brokoli basis for such processing is based on the necessity of performing Brokoli’s contractual obligations with you. To ensure network and information security: Brokoli processes your personal information in order to enhance security, monitor, and verify identity, combat spam or other malware or security risks, and comply with applicable security laws and regulations. Without processing your personal information, Brokoli may not be able to ensure the security of Brokoli’s Website and satisfy Brokoli’s legal obligations. For research and development purposes: Brokoli processes your personal information to better understand the way you use and interact with the Website. In addition, Brokoli uses such information to customize, measure, and improve the content and layout of the Website. Without such processing, Brokoli cannot ensure your continued enjoyment of the Website. Brokoli processes this personal information to satisfy Brokoli’s legitimate interests as described above. To engage in marketing activities: Based on your communication preferences, Brokoli may send you marketing communications to inform you about Brokoli’s events or Brokoli’s partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. Brokoli uses information about your usage of the Website and your contact information to provide marketing communications. You can opt out of Brokoli’s marketing communications at any time.  Brokoli will not use your personal information for purposes other than those purposes Brokoli has disclosed to you, without your permission. From time to time Brokoli may request your permission to allow Brokoli to share your personal information with third parties. You may opt-out of having your personal information shared with third parties, or allowing Brokoli to use your personal information for any purpose that is incompatible with the purposes for which Brokoli originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or services may not be available to you.

Collection and use of information collected automatically 

Brokoli receives and stores certain types of information automatically, such as whenever you interact with the Website. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software, and your Internet Protocol (IP) address/MAC address/device identifier. For example, Brokoli automatically receives and records information on Brokoli’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity, and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. Brokoli may also collect information about how your device has interacted with the Website, including pages accessed and links clicked. Brokoli may use identifiers to recognize you when you arrive at the Website via an external link, such as a link appearing on a third-party Website.

Information sharing with third parties

Brokoli allows your personal information to be accessed only by those who really need to in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. Brokoli will never sell or rent your personal information. Brokoli will only share your information in the following circumstances: Brokoli shares your information with third-party identity verification services in order to prevent fraud. This allows Brokoli to confirm your identity by comparing the information you provide Brokoli to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with the provision of identity verification and fraud prevention services. Brokoli may share your information with service providers under contract who help with parts of Brokoli’s SHO such as marketing and technology services. Brokoli’s contracts require these service providers to only use your information in connection with the services they perform for Brokoli and prohibit them from selling your information to anyone else. Brokoli shares your information with financial institutions with which Brokoli partners to process payments you have authorized. Brokoli may share your information with law enforcement, officials, or other third parties when Brokoli is compelled to do so by a subpoena, court order, or similar legal procedure, or when Brokoli believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate any violations. Please note that any third parties you interact with may have their privacy policies, and Brokoli is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, who may include such things as contact details or location data, is governed by their privacy practices. Brokoli encourages you to learn about the privacy practices of those third parties.

How Brokoli protects and stores personal information 

Brokoli understands how important your privacy is, which is why Brokoli maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to Brokoli. However, Brokoli cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your personal information. When registering with the Website, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify Brokoli if you become aware of any unauthorized access to or use of your account. Furthermore, Brokoli cannot ensure or warrant the security or confidentiality of the information you transmit to Brokoli or receive from Brokoli by Internet or wireless connection, including email, phone, or SMS, since Brokoli has no way of protecting that information once it leaves and until it reaches Brokoli. If you have reason to believe that your data is no longer secure, please contact Brokoli at the email address, mailing address, or telephone number listed at the end of this Privacy Policy.  

Retention of personal information

Brokoli will only retain your personal information for as long as necessary to fulfill the purposes for which Brokoli collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about Brokoli’s typical retention periods for different aspects of your personal information are described below. Contact Information such as your name, email address, and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter Brokoli will add your details to Brokoli’s suppression list indefinitely. Content that you post on the Website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes. Recording of Brokoli’s telephone calls with you may be kept for a period of up to six years. Information collected via technical means such as cookies, webpage counters, and other analytics tools is kept for a period of up to one year from the expiry of the cookie.

Children’s personal information 

Brokoli does not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Brokoli will require the user to close his or her account and will not allow the user to continue to participate in SHO. Brokoli will also take steps to delete the information as soon as possible. Please notify Brokoli if you know of any individuals under the age of 18 participating in Brokoli’s SHO so Brokoli can take action to prevent access to SHO.

  Individual Rights

When Brokoli receives an individual rights request via email Brokoli may take steps to verify your identity before complying with the request to protect your privacy and security: Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of data processing based on consent before your withdrawal. Right of access to and rectification of your personal information. You have a right to request that Brokoli provide you a copy of your personal information held by Brokoli. This information will be provided without undue delay subject to some fee associated with the gathering of the information (as permitted by law) unless such provision adversely affects the rights and freedoms of others. You may also request Brokoli to rectify or update any of your personal information held by Brokoli that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated. Right to erasure. You have the right to request the erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for Brokoli’s processing. The above is subject to limitations by relevant data protection laws. Right to data portability. If Brokoli processes your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have Brokoli transfer your personal information directly to another “controller”, where technically feasible, unless the exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information. Right to restriction of or processing. You have the right to restrict or object to Brokoli processing your personal information where one of the following applies: You contest the accuracy of your personal information that Brokoli processed. In such instances, Brokoli will restrict processing during the period necessary for Brokoli to verify the accuracy of your personal information. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead. Brokoli no longer needs your personal information for the purposes of the processing, but it is required by you to establish exercise or defense of legal claims. You have objected to processing, pending the verification of whether the legitimate grounds of Brokoli processing override your rights. Right to lodge a complaint. If you believe that Brokoli has infringed your rights, Brokoli encourages you to contact Brokoli first at [e-mail] so that Brokoli can try to resolve the issue or dispute informally. You can also complain about Brokoli’s processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.  Your rights to personal information are not absolute. Access may be denied when: Denial of access is required or authorized by law; Granting access would have a negative impact on other’s privacy; To protect Brokoli’s rights and properties; and Where the request is frivolous or vexatious.


The Website may use a browser feature called a “cookie” to collect information anonymously and track user patterns on the Website. A cookie is a small text file containing a unique identification number that identifies a customer’s browser, but not the customer personally, each time that customer visits a website using cookies. Cookies tell Brokoli which pages of the Website are visited and how many people visited each one. This helps enhance visitors’ online experience. Cookies also serve to identify your computer so that your preferences can be saved for future visits, and Brokoli may work with third parties that use these cookies to help Brokoli. You have the right to decide whether to accept cookies. You can exercise your preferences in relation to cookies served on the Website. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Website.

How to contact Brokoli

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us at [e-mail], or by writing to Brokoli at Papiniidu tn 5 Pärnu, Pärnu Pärnumaa 80042, Estonia. You can also complain about Brokoli’s processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.