We are committed to securing your Personal Data and your privacy.
This Privacy Policy has been created to inform you about how We
manage, collect, stores and uses the information you provide in
connection with Our website (the
“Website”).
We will uphold the following principles:
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To be transparent in respect of the collection and
processing of Personal Data about you:
It is important to Us that you have at all times all the
information required for you to make educated decisions about
the processing of Personal Data about you. For this purpose,
We will make use of various techniques and measures aimed to
provide you with relevant information about the processing of
Personal Data about you, in the proper manner and timing.
In addition, if We find you are required to be provided with
specific information, We will provide it to you in the
appropriate time and place.
We are also happy to answer any questions you may have and to
provide you with any clarification you require, subject to
legal limitations. For this purpose, you can approach Us by
sending an email to the following address
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To process Personal Data about you solely for the
purposes outlined in the Policy:
The purposes for which We may process Personal Data about you
include, inter alia, to make Our Website available to you and
provide you with the services contained therein (the
“Services”), to enhance the user experience in Our Website, to
improve Our Services (including the Website), to protect Our
rights and interests, to perform business and administrative
activity that supports the provision of Our Services to Our
users, and/or to uphold any legal and/or regulatory
requirements.
In addition, We will process Personal Data about you in order
to understand your personal needs and preferences.
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To invest significant resources in order to respect your
rights in connection with Personal Data about you:
We apply significant resources to allow you to exercise your
rights as a data subject. Therefore, you may approach Us any
time you wish to review Personal Data about you, have Us amend
it, erase it, cease using it for specific purposes or in
general, or transfer it to you or to a third party. We will
fulfill your wishes in accordance with the law.
-
To secure Personal Data about you:
While We cannot promise absolute protection of the Personal
Data about you, We can promise that We use and will continue
to use a wide array of means and measures aimed at ensuring
the Personal Data about you is secured.
Our Complete Privacy Policy
1. The Scope?
This Policy describes what kind of Personal Data the Company
collects about natural persons, and how it collects it, uses it,
shares it with third parties, secures it, processes it, etc.
In this Policy, “Personal Data” refers to any information relating
to an identified or identifiable natural person. An identifiable
natural person is one who can be identified, directly or in
combination with additional information that We have or that We
have access to.
In this Policy, the “processing” of Personal Data refers to any
operation or set of operations performed on Personal Data,
including the collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure, or
destruction of Personal Data.
Our Services are intended for general audience and are not
directed at children under the age of 18. We do not knowingly
collect or solicit information from anyone under the age of 18 or
knowingly allow such persons to access our Services. If We learn
that information about a child was collected, We will take
reasonable steps to delete such information as soon as possible.
2. When Do We Collect Personal Data About You?
We collect Personal Data about you whenever you use Our Services,
use Our service channels, use the Website and/or contact Us. In
some instances, you will actively provide Us with the Personal
Data, and in other instances, We will collect the Personal Data
about you by examining and analyzing your use of Our Services
and/or Our service channels.
3. No Obligation To Provide Personal Data To The Company And
Its Implications
You are not obligated to provide Us with any Personal Data about
you. However, in some instances, not providing such Personal Data
will prevent Us from providing you with the Services, will prevent
your use of the Website, and/or will cause the malfunctioning of
Our Services and the Website.
4. What Personal Data About You Do We Collect?
Personal Data We collect upon each browsing onto the
Website:
this information includes online activity log, traffic information
(including, without limitation, IP address, time of access, date
of access, web and mobile page(s) visited, language used, software
crash reports and type of browser used, information regarding the
device you used. Some of this information may not identify you
personally, and therefore not constitute Personal Data.
Personal Data We receive from you: any Personal Data you
provide to Us of your own free will when contacting Us.
Personal Data You specifically provide to Us for submission to
third-parties:
this information includes your name and email address.
5. The Purposes Of The Processing Of Personal Data And Their
Legal Basis
The Company processes your Personal Data for one or more of the
purposes outlined in this section and according to the appropriate
legal basis.
The Company will not process Personal Data about you unless there
is a legal basis for such processing. The legal bases according to
which the Company may process Personal Data about you are as
follows:
-
You have given consent to the processing of your Personal
Data for one or more specific purposes.
This refers to cases where you specifically provide your details
to Us through the Website, so that We submit them to third
parties.
-
Processing is necessary for the purposes of the legitimate
interests pursued by the Company or by a third party.
By way of example, for the purpose of improving Our Services, or
for the exercise or defense of legal claims.
-
Processing is necessary for compliance with a legal
obligation to which the Company is subject.
At any time, you may approach Us by sending a notice
to
the email address, in order to receive information concerning
the review performed by Us. This is so you can conclude that We
may process the Personal Data about you on account of such
processing being necessary for the purposes of the legitimate
interests pursued by the Company or by a third party.
The following list outlines the purposes for which We may process
Personal Data about you and the legal basis for any such
processing:
6. Transfer Of Personal Data To Third Parties
The Company may also share Personal Data about you with third
parties that provide Us services, such as storage and hosting
providers, IP address information, analysis of user experience and
research, analytical, technical, and diagnostic services.
In addition, you may specifically request that We submit certain
Personal Data about you to third-party Bitcoin trading platforms.
In such cases, We will share the Personal Data that you will
provide to Us for such purpose, to such third parties, and their
use of your Personal Data will be subject to their own privacy
policies.
The Company may also share Personal Data about you with its
related entities and business partners, which provide it with
resources that enable the Company to enrich and improve the level
of services and products it provides to its users.
The Company may share Personal Data about you with governmental,
local, official, and regulatory authorities, as well as if such
disclosure is required to protect Our and third parties’
interests, rights, and assets, including initiation, exercise, or
defense of legal claims.
In addition, We may disclose Personal Data about you to potential
purchasers or investors of, or lenders to, the Company and/or any
company within the group of companies of which the Company is a
part, or in the event of any similar transaction (including the
sale of assets of the Company and/or of any company within the
group of companies of which the Company is a part), and/or in
connection with any merger, reorganization, consolidation, or
bankruptcy of the Company and/or any company within the group of
companies of which the Company is a part.
7. Cookies and Third Party Services
We may use certain third party services, such as analytics
companies or companies delivering advertisements in our Website,
which may also use cookies or other technologies, and those
practices and providers are subject to their own policies.
Cookie (which is a small text file) is installed on the device via
which you visit or access the Website. The cookies shall allow Us
to collect information about you and your behavior, in order to
improve your user experience, to remember your preferences and
settings, and to customize and offer you products and services
that may interest you. Cookies may also be used to collect
statistics and perform analytics.
Some of the cookies We may use are session cookies, which are
downloaded temporarily to your device and last until you close
your web browser, while others are persistent cookies, which last
on your device after you cease browsing the Website and can be
used to help the Website remember you as a returning visitor when
you return to the Website.
Types of cookies:
Blocking and removal of cookies
You can change your browser settings to block and delete some or
all cookies. Please see below links to instructions on how to do
this in respect of some of the most popular web browsers:
- Firefox
- Internet Explorer
- Google Chrome
- Safari
Please note, however, that if you do so, some or all of the
Website’s features and functionalities might not perform as
intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK
SIGNALS.
8. Retention Of Personal Data About You
The Company shall retain Personal Data about you for as long as is
required to fulfill the purposes of the processing of the Personal
Data as outlined in this Policy, or for a longer period as
required according to the legislation, regulation, policies, and
orders that apply to Us.
In order to ensure that Personal Data about you is not retained
for longer than is required, We periodically review Personal Data
retained by Us to examine whether any Personal Data can be erased.
9. Transfers Of Personal Data To A Third Country Or An
International Organization
Personal Data about you may be transferred to a third country
(i.e. jurisdictions other than the one you reside in) or to
international organizations. In such circumstances, the Company
shall take appropriate safeguards to ensure the protection of
Personal Data about you and to provide that enforceable data
subject rights and effective legal remedies for data subjects are
available.
If you are an EEA (European Economic Area) resident, please note
that these safeguards and protection will be available if any of
the following are met:
-
The transfer is to a third country or an international
organization that the EU Commission has decided provides an
adequate level of protection to the Personal Data that is
transferred to it pursuant to Article 45(3) of Regulation (EU)
2016/679 of the European Parliament and of the Council of 27
April 2016 ("GDPR"), including any transfer in accordance with
the EU-US Privacy Shield Framework;
-
The transfer is according to a legally binding and enforceable
instrument between public authorities or bodies pursuant to
Article 46(2)(a) of the GDPR; or
-
The transfer is in accordance with standard data protection
clauses adopted by the EU Commission pursuant to Article
46(2)(c) of the GDPR.
-
You may request that the Company provide you with details
concerning the safeguards employed by it to protect the Personal
Data about you that are transferred to a third country or an
international organization, by sending an email to the following
address
10. Protection Of Personal Data About You
We implement appropriate technical and organizational measures to
ensure an appropriate level of security to Personal Data, taking
into account the risks that are presented by processing, in
particular from accidental or unlawful destruction, loss,
alteration, unauthorized disclosure of, or access to Personal Data
transmitted, stored, or otherwise processed.
We may be required, due to legal or other obligations outside Our
control, to transfer Personal Data about you to third parties,
such as public authorities. In such circumstances, We have limited
control over the level of protection provided to the Personal Data
about you by such third parties.
Any transfer of Personal Data via the internet cannot be fully
secured. Therefore, the Company cannot ensure the protection of
Personal Data about you when transferred via the internet to Us.
11. Links To Websites of Third Parties
The Website may provide links to websites and/or applications of
third parties. The Company does not control such websites and
applications, nor the collection and/or processing of Personal
Data about you by such websites and applications, and We are not
responsible for such websites and applications, nor for their
privacy and data protection policies and activities. This Policy
does not apply to any actions taken via such websites and/or
applications.
Whenever you access such third parties' websites and/or
applications, We recommend that you carefully review their privacy
policies prior to using such websites and/or applications and
prior to disclosing any Personal Data about you.
12. Changes To This Policy
We may amend, from time to time, the terms of this Policy.
Whenever We amend this Policy, We will notify you of such
amendments by publishing the updated Policy on the Website. In
addition, when We make significant amendments to this Policy, We
will strive to inform you about such amendments via means of
communication We believe are reasonably appropriate to inform you
of such amendments and by publishing a notice about such
amendments on the Website. Unless stated otherwise, all amendments
will enter into force upon publication of the updated Policy on
our Website.
13. Your Rights In Respect Of The Personal Data About You
Generally, you have the right to request that We provide you with
confirm whether Personal Data about you is being collected by us,
to ask to review such data, to rectify the content if applicable
and to erase the Personal Data no longer required by Us. You may
also restrict you consent to certain processing of your Personal
Information.
If you are an EEA resident please read this section below:
You are entitled to the following rights in respect of the
Personal Data about you. To exercise such rights, you may send a
request to exercise your rights to the following email address
Right of access
You have the right to receive from the Company confirmation as to
whether or not Personal Data about you is being processed, and, if
that is the case, access to the Personal Data and the following
information: (1) the purposes of the processing; (2) the
categories of Personal Data concerned; (3) the recipients or
categories of recipients to whom the Personal Data have been or
will be disclosed, in particular recipients in third countries
outside the European Economic Area (EEA) or international
organizations; (4) if possible, the envisaged period for which the
Personal Data will be stored, or, if not possible, the criteria
used to determine that period; (5) the existence of the right to
request from the Company rectification or erasure of Personal Data
or restriction of processing of Personal Data about you or to
object to such processing; (6) the right to lodge a complaint with
a supervisory authority; (7) if the Personal Data is not collected
from you, any available information as to its source; (8) the
existence of profiling; and (9) if Personal Data is transferred to
a third country outside the EEA or to an international
organization, the appropriate safeguards relating to the transfer.
The Company shall provide a copy of the Personal Data undergoing
processing and may charge a reasonable fee for any further copies
requested by you. If you make the request by electronic means, and
unless otherwise requested by you, the information shall be
provided in a commonly used electronic form.
The right to obtain a copy of the Personal Data shall not
adversely affect the rights and freedoms of others. Therefore, if
the request harms the rights and freedoms of others, the Company
may not fulfill your request or do so in a limited manner.
Right to rectification
You have the right to obtain from the Company the rectification of
inaccurate Personal Data about you. Taking into account the
purposes of the processing, you have the right for incomplete
Personal Data about you to be completed, including by means of
providing a supplementary statement.
Right to erasure
You have the right to obtain from the Company the erasure of
Personal Data about you if one of the following grounds applies:
(a) the Personal Data is no longer necessary in relation to the
purpose for which it was collected or otherwise processed; (b) you
withdraw your consent on which the processing is based and there
is no other legal ground for the processing; (c) you object at any
time, on grounds relating to your particular situation, to the
processing of Personal Data about you that is based on the
legitimate interests pursued by Us or by a third party, and there
are no overriding legitimate grounds for the processing; (d) you
object to the processing of Personal Data about you for direct
marketing purposes; (e) the Personal Data has been unlawfully
processed; or (f) the Personal Data about you has to be erased for
compliance with a legal obligation in European Union or Member
State law to which the Company is subject.
This right is not applicable to the extent that the processing is
necessary (a) for compliance with a legal obligation that requires
processing by European Union or Member State law to which the
Company is subject; or (b) for the establishment, exercise, or
defense of legal claims.
Right of restriction of processing
You have the right to obtain from the Company the restriction of
processing of Personal Data about you if one of the following
applies: (a) the accuracy of the Personal Data is contested by
you, for a period enabling the Company to verify the accuracy of
the Personal Data about you; (b) the processing is unlawful and
you oppose the erasure of the Personal Data about you and request
the restriction of its use instead; (c) the Company no longer
needs the Personal Data about you for the purposes of processing,
but the Personal Data is required by you for the establishment,
exercise, or defense of legal claims; (d) if the processing of
Personal Data about you is necessary for the purpose of the
legitimate interests pursued by the Company or by a third party,
unless We demonstrate compelling legitimate grounds for the
processing that override your interests, rights, and freedoms or
for the establishment, exercise, or defense of legal claims; or
(e) if the Personal Data about you is processed for direct
marketing purposes, including profiling, to the extent it is
related to such direct marketing.
If the processing of Personal Data about you has been restricted
following your request, such Personal Data shall, with the
exception of storage, only be processed with your consent or for
the establishment, exercise, or defense of legal claims or for the
protection of the rights of another natural or legal person or for
reasons of important public interest of the European Union or of a
Member State.
Right to data portability
You have the right to receive the Personal Data about you, which
you have provided to the Company, in a structured, commonly used,
and machine-readable format, as well as the right to transmit such
Personal Data to another controller, if (a) the processing is
based on your consent or on a contract to which you are a party,
and (b) the processing is carried out by automated means.
In exercising your right to data portability, you have the right
for the Personal Data about you to be transmitted directly from
the Company to another controller, where technically feasible. The
exercise of your right to data portability is without prejudice to
your and the Company’s rights under your right to erasure. In
addition, the right to data portability shall not adversely affect
the rights and freedoms of others.
Right to object
You have the right to object at any time, on grounds relating to
your particular situation, to the processing of Personal Data
about you that is based on the legitimate interests pursued by the
Company or by a third party, including profiling based on such
legitimate interests. In such case, We shall no longer process the
Personal Data about you, unless We demonstrate compelling
legitimate grounds for the processing that override your
interests, rights, and freedoms or for the establishment,
exercise, or defense of legal claims.
You have the right to object at any time to the processing of
Personal Data about you for direct marketing purposes, including
profiling, to the extent it is related to such direct marketing.
Right to withdraw consent
You may withdraw your consent provided to Us for the purpose of
processing Personal Data about you at any time, without affecting
the lawfulness of processing based on your consent before its
withdrawal.
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory
authority established by a Member State to protect the fundamental
rights and freedoms of natural persons in relation to the
processing of Personal Data within the European Union.
Your rights in respect of Personal Data about you as outlined in
this section 13 may be restricted by European Union or Member
State law to which the Company is subject.
We shall provide you with the information requested according to
your rights outlined in this section 13 without undue delay and in
any event within one month of receipt of the request. That period
may be extended by two further months where necessary, taking into
account the complexity and number of the requests. We shall inform
you of any such extension within one month of receipt of your
request, together with the reasons for the delay.
The information requested according to your rights outlined in
this section 13 shall be provided free of charge, unless stated
otherwise in this section 13. Where requests are manifestly
unfounded or excessive, in particular because of their repetitive
character, We may either (a) charge a reasonable fee, taking into
account the administrative costs of providing the information or
communication or taking the action requested; or (b) refuse to act
on the request.
The Company may require you to provide additional information
necessary to confirm your identity in order to fulfill your
request according to your rights outlined in this section 13, if
We have reasonable doubts concerning the identity of the natural
person making the request.
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