Last Updated: September, 2019
We collect Personal Information about You and the device You use when You use our Services on the Site or otherwise interact with the Company.
"Personal Information" means information that we directly associate with a specific person or entity, which may include without limitations, name, addresses, telephone numbers, email address, payment information, unique device ID (the "UDID"), device location, IP address, Site usage date, etc.
How Personal Information About You is Collected
We collect information about You in three primary ways:
- Information You Provide. We collect information that You provide to us when You register for or use the Site, or otherwise communicate with us. Without limitations, provision of information by You may include the following: information provided when You contact us or register to participate in our affiliated products, KYC information, the Company may collect personal contact information, billing information and any information shared with payment processors, all as may be necessary for the provision of the Company services or the interaction executed by You.
- Upon the establishment or modification of an account with the Company, We may collect user identification information, passwords, security question responses or other elements related account security, or any other means of identification, which You will use for future sign on.
- Upon interaction with our Customer Service representatives or anyone acting on behalf of the Company, or once You enter information on the Site, submit survey responses, we may also collect Personal Information and other data. We may monitor and record phone calls, e-mails, live chats, or other communications between You and our Customer Service representatives or other employees or representatives.
Information We Collect Automatically
We automatically collect a variety of Personal Information associated with Your use of the Site or the Services. Each time You visit the Site Personal Information is automatically gathered, which in general, does not identify You personally and may include without limitations: UDID, IP address, Country, City (if available), Connection Speed, Publisher Name, Collection Date, Day of Week, Time of Day (hour), Language settings in addition to any information provided directly by You, all of which allows the Company to evaluate Your use of the Site for the purpose of improving the Site and the Services.
Depending upon the device used, You may be able to set Your browser to reject cookies or delete cookies, but that may result in the loss of some functionality on the Site.
The Use of Web Beacons
The Company may use web beacons (or "pixels"), which are small graphic images on a web page or an HTML, for the purpose of monitoring interaction with the Site or e-mails.
Site Use Activity
Through Your access to the Site, we automatically collect certain Personal Information about Your use of the Site, such as Your IP address, browser type, date and time, the web pages You visited before visiting the Site, Your activities and downloads on the Site, and additional analytical information associated with the Site.
Information from Other Sources
The Company may collect information about You from other sources. For example, the Company may receive certain credit information from third-party sources before initiating any service to You. Company may also purchase or obtain Personal Information (for example, e-mail lists, postal mail lists, demographic and marketing data) from third parties.
Members sending Digital Assets to the Site through the use of cryptographic hashes and keys take full responsibility for the risks involved. By using the Services you will automatically accept liability of any loss, damages or implications incurred through the use of this Site and the Company will not be held liable for any loss of Your Digital Assets.
If You do not agree you can request the return of Your Digital Assets through the use of a withdrawal once logged in.
No cryptographic private keys are held on the Site servers. Digital assets sent to cryptographic public keys displayed on the Site are immediately forwarded to offline vaults.
The Company’s Use of the Personal Information Collected About You
The Company may use the Personal Information collected about You for a variety of business purposes, including the following:
- For providing customer services to You;
- For identifying and suggesting products or services that might interest You;
- For verifying Your identity and maintaining a record of Your transactions and interactions with us;
- For processing any transaction as applicable;
- For making internal business decisions about current and future service offerings;
- For creating, modifying, improving, enhancing, removing or fixing our Services and their performance;
- For providing You customized user experiences, including personalized services offerings;
- For protecting our rights, interests, safety and property and that of our customers, service providers and other third parties and affiliates;
- The Company may use third-party vendors, subcontractors, network advertisers and other businesses to deliver various services to You on the Company’s behalf. These providers may be supplied with or have access to Your information, including Your non-personally identifiable information (such as Your IP address and Your UDID) for the purposes of performing the functions for which the Company has engaged them. Provided that such providers have access to your personally identifiable information, they are bound by a confidentiality obligation; and
Use for Marketing
The Company may use information the Company collects to contact You with regards to our and/or third-party services, products and offers, which the Company believes might serve Your interests. In doing so, the Company may contact You by telephone, postal mail, e-mail, or other methods.
In addition, the Company uses Your UDID and information about third parties websites which You have visited through the Services to report on the number of users who click through the websites or who accessed third parties websites as a result of certain ads.
Use for Advertising
Upon the use of the Site, You may be exposed to advertisements. The Company may assist advertisers to better reach our users by providing certain customer information, including geographic information, language preferences or demographic information obtained from other companies. The information provided as aforementioned, may then be used by advertisers to determine which ads may be more relevant to You. However, the Company does not share Personal Information outside of our corporate related entities for advertising purposes without Your consent.
Links to Other Content and Third Party Websites
Use for any Fraud Prevention
We may use Personal Information for investigations or for prevention of fraud, AML, CTF, for Consumer Protection or network abuse and to protect our users.
When We Share Information Collected About You
Except as detailed herein this Policy, the Company does not sell, license or otherwise provide Your Personal Information to unaffiliated third parties, which are outside our corporate family without Your consent. The Company may, however, disclose Your information to unaffiliated third-parties with Your Consent obtained in either writing, online, through "click-through" agreements and downloads, upon acceptance by You of the terms of disclosures for certain Services, in writing (including without limitations by chat or email) or orally, when You interact with our customer service representatives.
Access to Third-Parties
Should You be required to choose a username or password while using the Site or the Company’s products, You should refrain from sharing Your login information with any third party. If You provide any of Your login information to third parties, such third parties will gain access to all Your Personal Information upon accessing Your Account with Your login information. Furthermore, sharing Your login information with third parties is forbidden under AML restrictions, CTF, Fraud and identity theft provisions.
For Legal Process & Protection
The Company may disclose Personal Information, and other information about You, or Your communications, where disclosure of such information is reasonably necessary: (i) In order to satisfy any applicable law, regulation, legal process or enforceable governmental request, including AML, CTF, Anti-Fraud and Consumer Protection requirements; or (ii) In order to enforce or apply agreements, or initiate, render, bill, and collect for services and products (including to collection agencies in order to obtain payment for our products and services); (iii) In order to protect our rights or interests, property or safety or that of others; or (iv) In order to assist with claims, disputes, or litigation – in court or elsewhere; or (v) In order to facilitate or verify the appropriate calculation of taxes, fees, or other obligations or in an emergency situation.
How We Store and Protect Personal Information
The Company uses a variety of physical, electronic, and procedural safeguards to protect Personal Information from unauthorized access, use, or disclosure while it is under our control. Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. As a result, although the Company utilizes security measures, the Company may not guarantee You against the loss, misuse, or alteration of Personal Information under our control, and You provide Personal Information to us at Your own risk. You should always take care with how You handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, social networks or other internet channels.
Retention and Disposal. The Company retains information for as long as we have a business or tax need or as required under the applicable laws, regulations and/or government orders from time to time. Following termination of the Account, the Company endeavors to erase and discard of Your data subject to the limitations and requirements under the applicable laws and regulations.
Transfer to other countries
For the purpose of providing You with the Services, the Company transfers Your information to different countries outside Your country where the Company has facilities. By using the Site, You consent to the transfer of Your information outside of Your country.
You have the right to access Your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to the Company at firstname.lastname@example.org or where possible, you can do these actions in Your account profile page Yourself.
Upon your written request, the Company will inform You of the Personal Information relating to You that the Company holds and the use and general disclosure of Your Personal Information. The Company will also give You a copy of the Personal Information the Company has retained. There may be a minimal charge for providing you additional copies of Your Personal Information to cover administrative costs.
You may also request the deletion or destruction of both the Account and Personal Information by sending an email to us at email@example.com . The Company will action your request immediately, except, where this is not consistent with its legal and regulatory obligations.
You may also ask us to transfer your Personal Information to another controller of your choice.
To ensure the confidentiality, integrity and availability of Your information to Yourself, the Company may request You to confirm Your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of Your rights.
If You refuse to prove your identity, the Company may decline to take actions in respect of Your data, save restricting processing, until the Company can ensure that such actions are the true wish of the data subject.
In the carrying out of the Services the Company may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, the Company carries out an analysis of Your identification, transactional and behavioural patterns.
The Company may not able to provide you with some or all the Services if you do not wish this automated processing to be carried out. If You feel that this processing might be detrimental to You, we can provide You with further information about this automated processing by contacting us on firstname.lastname@example.org
Email address: email@example.com