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:
-
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
-
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.
-
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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