PRIVACY NOTICE

We (also referred to as “we,” “us,” or “our”) take steps to protect your privacy. In this privacy notice (“Notice”), we describe the types of personal information we may collect from you in connection with your use of our websites, including wallet, our online cryptocurrency trading platform, marketplace, mobile application, social media pages, or other online properties (collectively, the “Website”), or when you use any of the products, services, content, features, technologies, or functions we offer (collectively, the “Services”).

This Notice is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Website and Services. Please note that our Service offerings may vary by region.

Importantly, if you have access to and can visit our Website and receive our Services, this does not necessarily mean that we respect and are bound by your specific country’s data protection and privacy laws.

Please read this Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, please do not use our Website and Services. By accessing or using our Website and Services, you acknowledge and agree to the terms of this Notice.

This Notice may be published in different languages. In case of any discrepancy, this English language version shall prevail.

Personal information we collect

The term “Personal Data” describes information that can be associated with a specific person and can identify that person. We collect Personal Data in connection with your use of the Website and our Services, or otherwise in the context of our relationship with you. The types of Personal Data that we may obtain from you may include:

Biographical Data, including:

  • Full name;
  • Email address;
  • Phone number;
  • Country;
  • Full address;
  • Date of birth.

Account Details, including:

  • Username;
  • User Profile Information in the “Bio” section;
  • Profile picture;
  • Joined date;
  • Default currency;
  • Time zone;
  • Default language.

Account Activity, including:

  • Trade chat messages (which may contain financial information if you provide it to sellers);
  • Trade chat attachments;
  • Trade activity;
  • Messenger chat messages and attachments;
  • Transaction history;
  • Partner program ID;
  • Partner program link;
  • Partner program transactions;
  • Offers created;
  • Offer terms;
  • Trade instructions;
  • Account notifications;
  • Account status.

Data relating to your Digital asset wallet, including:

  • Wallet balance;
  • Transactions received;
  • Transactions sent;
  • Deposit address.

Data Collected in connection with “Know Your Customer” (KYC) process, including:

  • Government-issued ID;
  • Photographs, if you elect to provide them to us.

Device and Website Usage Data, including:

  • IP addresses;
  • Cookie ID and/or other device identifiers;
  • Information relating to your access to the Website, such as device characteristics, date & time;
  • Language preferences;
  • Information on actions taken while using the Website.

Mobile application usage data, including:

  • Session data: IP address, version of the operating system, brand and model of the device, unique identifiers of the device, browser used, information about the time the application was accessed, name and parameters of the network connection;
  • Information about applications installed on the user’s device (metadata from applications): application name, application identifier and version, device identifier and checksum. Detecting malicious apps and protecting users from fraud are the main reasons for collecting information about installed apps;
  • Information on actions taken while using the mobile application;
  • Crash and application errors diagnostics data.

How we use your data

The business purposes for which we collect, use, retain, and share your Personal Data may include:

To provide Services through operating the Website, including:

  • Register, create, and maintain your account;
  • Authenticate your identity and/or your access to an account;
  • Initiate, facilitate, process, and/or execute transactions;
  • Facilitate using our messenger;
  • Communicate with you regarding your account or any Services you use;
  • Perform KYC, or other similar reviews;
  • Evaluate applications; or
  • Compare information for accuracy and verification purposes.
  • To manage risk and protect you, other persons, and the Website and Services;
  • To provide a personalized experience and implement your preferences;
  • To better understand customers and how they use and interact with the Website and Services;
  • To market to you;
  • To provide personalized Services, offers, and promotions on our Website;
  • To provide you with location-specific options, functionalities, and offers;
  • To comply with our policies, obligations, and legal processes;
  • To resolve disputes, collect fees, or troubleshoot problems;
  • To provide customer service to you or otherwise communicate with you;
  • To manage our business.

We may also process Personal Data for other purposes when required by law.

Sources from which we collect personal data

We collect Personal Data from several sources, including:

  • Directly from you: We collect Personal Data directly from you when you use our Website or Services, communicate with us, or interact directly with us;
  • From service providers and/or data processors who assist us in providing the Website or the Services: We may engage service providers to assist us in facilitating the Website or the Services to you, at our direction and on our behalf. These service providers may collect information about you and provide it to us;
  • From other users on our Website or from affiliates integrated with our Website or Services: Other users may provide us with information about you in connection with transactions or chats. Affiliates may also provide information to us about you related to your interactions or transactions with such affiliates;
  • From third-parties who may help us verify identity, prevent fraud, and protect the security of transactions;
  • From third-parties who may help us analyze Personal Data, improve the Website or the Services or your experience on it, market products or services, or provide promotions and offers to you;
  • From social media platforms, if you interact with us through social media.

How we share Personal Data

We may choose how we share your personal information.

We may share your Personal Data within our group, with affiliates or related companies, for purposes consistent with this Notice.

We may share your Personal Data with our service providers, financial institutions, data processors and vendors to assist us in providing you with the Services. These third-party service providers may provide you with certain Services, verify your identity, assist in processing transactions and/or making payments, send you advertisements for our products and Services, or provide customer support. These third parties may use your Personal Data only as directed or authorized by us and in a manner consistent with this Notice, and are prohibited from using or disclosing your Personal Data for any other purpose.

We may share your Personal Data for compliance and regulatory purposes, in order to protect our legitimate interests or in connection with a business transaction.

International transfers of Personal Data

Please note that we may transfer Personal Data we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

Cookies

A cookie is a small text file that a website saves on your computer or mobile device when you visit the website.

Our Website uses cookies and tracking technologies to operate, and to target advertising that may be of interest to you.

We use cookies to track how you use our Website by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to our Website.

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our Website may be limited. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

Personal Data retention

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, business or reporting requirements. We make efforts to delete or de-identify your Personal Data once it is no longer required for any of the business purposes described above. However not all your Personal Data may be able to be deleted or de-identified due to the nature of Blockchain transactions.

Data security

We have implemented safeguards designed to protect your Personal Data, including measures designed to prevent Personal Data against loss, misuse, and unauthorized access and disclosure. Still, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection. Transferring data through the Internet always carries some risk, even if we make efforts to protect data once we have received it. Hence, any transmission of Personal Data is always at your own risk. We recommend using a unique password for your account with us that is not utilized for other online accounts and to sign off when you finish using a shared computer.

We protect your Personal Data, among other things, by collecting it only to extent essential for providing our Services and ensuring their proper functioning. We do not request, store or process Personal Data that is not strictly required for the Services you have opted for.

Children under 18 years of age

Our Website is not intended for children under the age of 18. We do not knowingly collect data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. If we learn that we have collected information, including Personal Data, from an individual under 18 years of age without parental consent, we will delete that information immediately.

Modifications to the privacy notice

We reserve the right to update or change this Notice from time to time based upon evolving laws, regulations and industry standards. We will notify you of modifications to this Notice consistent with the significance of the updates or changes we make by posting a revised version of this Notice here, by email, or by means of a prominent notice on the Website. We recommend that you periodically check the Website for any changes. If you disagree with the changes to this Notice, you should discontinue your access and use of our Website and Services.

Contact us

If you would like to exercise any of the rights listed in this Notice, or if you would like to contact us about any questions you may have regarding your personal data, please contact our support and provide (i) enough information to identify you and (ii) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Data Controller

Personal Data controller is a person or organization that controls the collection, holding, processing or use of Personal Data, including a person or organization that instructs another person or organization to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

Legal Bases for Processing Personal Data

We may process Personal Data relating to you if you have given your consent to us. We may be allowed to process Personal Data until you object to such processing ("opt-out"). We may process Personal Data relating to you without having to rely on consent when Personal Data and its processing are necessary for: (i) the performance of an agreement with you and/or for any pre-contractual obligations; (ii) compliance with a legal obligation; (iii) the purposes of pursuing legitimate interests.

Data Protection Rights

Laws provide you with certain rights with respect to your Personal Data, including the following rights to:

  • request access to and amend your Personal Data;
  • request deletion of your certain Personal Data relating to you;
  • withdraw your consent you have provided to us to collect, use, or share your data. Please note that withdrawing consent does not affect the lawfulness of processing your Personal Data before your withdrawal.

You are generally entitled to access Personal Data that we hold about you. If you think that we have not respected your privacy, please contact us.

Do Not Track Disclosure

Our Website is not designed to respond to “Do Not Track” signals or requests.

Facts
What do we do with your personal information?
We may collect, process and share your personal information as set out in this Notice. Law requires us to tell you how we collect, share, and protect your personal information. Please read this Notice carefully to understand what we do.

Why?
Our primary purpose in collecting Personal Data is to provide our Services in a secure, efficient, and smooth way. We generally use Personal Data to deliver our Services, as well as for content and advertising, and for loss prevention and anti-fraud purposes.

What?

The types of personal information we collect and share depend on the product or Service you have with us. This information can include:

  • ID number or account balances;
  • Payment or transaction history.

When you are no longer our customer, we continue keeping and sharing your information as described in this Notice.


How?

We need to collect Personal Data to run our everyday business. In the section below, we list some reasons we can share customers' personal information and whether you can limit this sharing.


Reasons we can share your personal information
Do we share?
Can you limit this sharing?
For our everyday business purposes - such as to process your transactions, maintain your account(s), comply with our obligations
Yes
No
For our marketing purposes - to offer our products and Services
Yes
No
For joint marketing with other companies
Yes
No
For our affiliates' everyday business purposes - information about your transactions and experiences
Yes
No

What we do
How do we protect your personal information?
To protect your personal information from unauthorized access and use we employ security measures that comply with law. These measures include computer safeguards and secured files and buildings.
How do we collect your personal information?

We collect your personal information, for example, when you

  • open an account or provide account information;
  • give us contact information or make a transfer;
  • use your account to send or receive funds.

We also receive personal information from other companies.