Privacy policy

General

(“Company”, “We”, “Us”, “Our”, interchangeably) (Contact details: [email protected]).

Before using and/or visiting any section of the website please read this Privacy Notice carefully in its entirety.

Information We Collect

Your personal data is protected under data protection law. However, “personal data” does not include “anonymous data”, meaning those data which are considered de-identified since each and every direct or indirect identifiers linking such data to individual subject’s identities have been removed.

Whenever We process personal data, We always follow the GDPR principles:

lawfulness, fairness and transparency;
purpose limitation;
data minimization;
accuracy;
storage limitation;
integrity and confidentiality;
accountability;

Your Personal Data

In this paragraph, We will explain the following:

WHAT kind of Personal Data We collect, use, store and transfer;
HOW We collect Your Personal Data;
WHY/for what purposes We collect Personal Data.
WHAT LEGAL BASES for processing we rely on.

In order for data processing to be legal, data controllers must identify a legal basis for each processing activity. We could rely on the following legal bases:

consent – when We rely on Your consent to process Your Personal Data, We only process Your Personal Data in such a manner and for as long as We have Your consent to do so. You can withdraw Your consent at any point in time. However, this will not affect any processing of Personal Data that We carried out with Your consent before Your consent was withdrawn.
performance of contract – we rely on this legal basis when the processing of Your Personal Data is necessary for the performance of Our contractual obligations
legitimate interest – we rely on this legal basis when Your Personal Data is processed in the interest of conducting and managing Our business to ultimately provide You the best service and experience We possibly could. We do not rely on this legal basis if Your interests or fundamental rights and freedoms as a data subject override our interests to process Your Personal Data;
legal requirement – we rely on this legal basis when the processing of Your Personal Data is necessary for compliance with a legal obligation to which We are subject.

We Collect

Name and surname, e-mail address, phone number, date of birth, country, crypto account number, Data relating to Your communications with Us via email correspondence or web chat (or through other means of communication), Technical data – including Your internet protocol (IP) address, your login data (last login date), browser type and version, time zone setting and location etc., Usage data – data relating to Your use of Our Website.

We shall not collect any Personal Data about You without Your knowledge. We may, however, automatically collect certain Personal Data about You where You would have provided such data through the use of Our services and through Your interactions with Us.

Sharing of Your Personal Data

We may need to share Your Personal Data with other entities within Our Group of companies or/and with Our business partners. However, We will never sell or rent Your Personal Data to third parties. These companies include Our parent companies, their parent companies and all the subsidiaries of these respective companies, as well as other companies with whom We carry out business and hold necessary agreements. Data processing of Your Personal Data may be undertaken by the Company or by another entity in Our group of companies, which may use a third party to fulfill such data processing needs.

The third parties with whom We might share Your Personal Data process limited Personal Data on Our behalf, in order to support the Website, especially in relation to hosting and operating the websites, marketing, analytic, improving the websites, and sending email newsletters. We shall ensure that the transfer of the Personal Data to such recipients is compliant with applicable Data Protection Legislation, and that the same obligations are imposed on the processor under the respective Service Agreement.

We always ensure that any third party having access to Your Personal Data is bound to respect the security of Your Personal Data, and to process it in a lawful manner at all times and in compliance with Our Privacy Notice and strict codes of conduct. We do not allow any third-party service providers to use Your Personal Data for their own purposes. Processing by such third parties (also known as “Data Processors”) is solely carried out for specific purposes and in accordance with Our instructions as Data Controller and on Our behalf, and such third parties may only use Your Personal Data to the extent to which we ourselves are entitled. Furthermore, in all cases, We strive to ensure that We do not share more data than it is necessary to be shared for the service providers to carry out the processing activities in accordance with Our instructions.

These third parties include:

Governmental or regulatory authorities – We may, where We are required to do so by law, regulation, or other legal subpoena or warrant, or if We believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party, provide Your Personal Data to law enforcement agencies, governmental or regulatory organizations, courts or other public authorities. We attempt to notify all Our customers about legal demands for their Personal Data, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when We believe that the requests are disproportionate, vague or lack proper authority, but We do not promise to challenge every demand;
Customer service provider and communication software – We use a third-party software to help Us communicate with You. This software enables Us to send You emails and chat with You on web chat whenever You have queries. Furthermore, We use a third-party customer service provider to provide support to Our customers in relation to Our service;
Our Websites may also include social media features (e.g. “share” or “like” buttons). Such features are provided by third-party social media platforms. Where Your Personal Data is collected this way, its processing is governed by the privacy notice of the respective social media platform.

In addition to the above, We may also release Your Personal Data if We acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that Our customers’ personal data will be included within the sale or transfer.

Please note, our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy notices and data processing disclosures.

Transfer of Personal Data

We and/or Our service providers might require transferring Your Personal Data from one country to another in the European Union (EU), or in the European Free Trade Association (EFTA) regions, or outside the European Economic Area (EEA). Therefore, by browsing the Website and communicating electronically with Us, You acknowledge and agree to Our (or Our suppliers or subcontractors) processing of Your data in these countries. Whenever Your personal data is transferred outside the EEA, We always ensure that Your Personal Data is protected in the same way as it stays in the EEA. To ensure the protection of Your Personal Data, We will implement at least one of the following safeguards:

Adequacy decision(s) – We ensure that Your Personal Data is transferred to countries that provide an adequate level of data protection in accordance with the European Commission’s decision(s).
Standard Contractual Clauses – When a data processor or data controller is not based in a country benefiting from an adequacy decision, We may use special contracts, known as standard contractual clauses, which are model contracts approved by the European Commission.

Data retention

We will only retain Your Personal Data for as long as it is necessary to fulfill the purpose for which it was collected.

We will retain Your Personal Data on record for as long as required by law, and Your Personal Data shall only be used should it be required by competent authorities in cases of inquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.

In order to determine the appropriate retention period for Your Personal Data, We take into account various factors, such as:

the nature and sensitivity of Your Personal Data;
the potential risk of unauthorized use or disclosure of Your Personal Data;
the purpose We collected and processed Your Personal Data for; and
any applicable laws and/or legal requirements imposed on Us.

Security of Your personal data

We always strive to ensure that Your Personal Data is secure, both in Our hands and in the hands of any third party We may share Your Personal Data with. To ensure that Your Personal Data is not accidentally lost, used, altered, disclosed or accessed in an unauthorized manner, We adopt a number of technical, contractual and organizational measures.

Only selected employees of the Company and of Our Group shall have access to Your Personal Data, and only for the purpose of executing their duties and providing You with assistance. Such employees have signed confidentiality agreements to respect the confidential nature of Your Personal Data pursuant to applicable data protection and privacy laws.

Contacting Us

You may always contact Us in regard to this Privacy Notice should You wish to exercise any of Your rights pursuant to data protection law.More precisely, in accordance with data protection law, You have the right to:

request the erasure of Your Personal Data – You may exercise this right when We no longer have a legitimate reason to continue processing it or retaining it. However, as explained above, this right is not absolute: if We have a legal obligation to retain Your Personal Data, or if We need to retain Your Personal Data in order to defend Ourselves in a legal dispute, We will not be able to satisfy Your request;
update or rectify any information that You have provided Us – if You wish to exercise this right, You shall provide any evidence We may reasonably require executing the requested changes. Please note that it is illegal to provide Us with false information about You, and it is Your responsibility to ensure that We are always updated with Your correct Personal Data;
object to the processing of Your Personal Data where We rely on Our legitimate interests (or those of a third party) to process Your Personal Data, and You feel that Our processing of Your Personal Data in such a manner impacts Your fundamental rights and freedoms – However, in some cases, We may be able to demonstrate that We have a compelling legitimate ground to process Your Personal Data, which may override Your rights and freedoms;
request the restriction of the processing of Your Personal Data – You may ask Us to temporarily suspend the processing of Your Personal Data in case:

1. You want Us to establish the accuracy of Your Personal Data;

2. Our use of Your Personal Data is unlawful, but You do not wish for Us to delete it;

3. You need Us to retain Your Personal Data even when We no longer need it in order for You to establish, exercise, or defend legal claims;

4. You have objected to the use of Your Personal Data, but We need to verify whether We have overriding legitimate grounds to use it

Request the transfer of Your Personal Data (“data portability”) – You may request Us to transfer Your Personal Data to a third party. Please note that this right only applies to Personal Data acquired through automated means which You initially provided consent for Us to use, or where We used the data to perform Our obligations under a contract with You;
Withdraw Your consent at any time – where We rely on Your consent to process Your Personal Data, You may withdraw it at any time. Please note that withdrawing Your consent will not affect the lawfulness of the processing carried out by Us up until the time You withdraw Your consent. Withdrawing Your consent means that, going forward, You no longer wish for Us to process Your data in such a manner. This means that You may no longer consent for Us to provide You with certain services, such as marketing communications (if You want to withdraw Your marketing consent).

In order to exercise Your rights as explained above, We may need You to provide specific proof and documentation to help Us verify Your identity. This is a security measure to ensure that We are certain that the person to whom We disclose Your Personal Data is really You.

In addition, as per Article 77 of the GDPR, You have the right to lodge a complaint related to the processing of Your Personal Data to a supervisory authority, in particular in the Member State of Your habitual residence, place of work or place of an alleged infringement.

Cookie Policy

When You visit the Website, Our system automatically collects information about Your visit, such as Your browser, IP address, and the referring website. This collection may be done in conjunction with Our platform providers and partners. We may receive from them general demographic or usage data of Our Website visitors. We do not use automatically collected information to identify You personally without receiving additional consent. To collect the information in question, We use cookies and similar tracking tools.

Cookies are small text files that are stored on Your computer or equipment when You visit Our web pages. Some of the cookies are essential for the Website to operate; others improve Your Website experience and help Us deliver a better service. Below are the types of cookies We use and their purposes:

REQUIRED COOKIES: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.
FUNCTIONAL COOKIES: allow Us to analyze Your Website usage and Your selections on the Website (e.g. Your session key, language, or region), so We can save these settings and offer You a more personalized experience.
ADVERTISING COOKIES: allow Us to gauge how effective Our content marketing is. These cookies are provided by Our partners to track Website visits. We do not share Your Personal Data (such as name or email) to affiliated partners except for site visit data collected directly by such Advertising Cookies. However, Your site visit data may be linked with other Personal Data collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.

In addition to the above, We use a number of third-party service providers who also set cookies on this Website, in order to deliver the services that they are providing to Us. Such services include, but are not limited to, helping Us to improve Your experience by tracking Your activity on the Website, measuring the effectiveness of the Website and the effectiveness of Our marketing campaigns.

Most online browsers automatically accept cookies. If You prefer, it is possible to block some or all cookies, or to delete cookies that have already been set by modifying Your browser settings. However, We recommend that You do not block or delete Your cookies as this may restrict Your use of Our Website.