1.Types of Data We Collect & Data Categories
“Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing such as;
- Transaction Security Information
- Customer Transaction Information
- Professional Experience
- Legal Action Information
- Audio and Visual Recordings
“Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.
a.Information You Provide Us
- When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address, first and last name, user name, and other information you provide. We also collect your crypto asset wallet address, which may become associated with Personal Data when you use our Service.
- Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser, or mobile device.
- If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.
- We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.
b.Information Collected via Technology.
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third-party service provider) may collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
- Log Files. As is true of most websites and applications, we may gather certain information automatically and store it in log files. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We may use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
- Pixel Tag. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
- How We Respond to Do Not Track Signals. Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
c.Information Collected from Third-Party Companies
We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. For example, third-party wallet providers provide us with your wallet address and certain other information you choose to share with those wallets’ providers. We may add this to the data we have already collected from or about you through our Service.
d.Public Information Observed from Blockchains
We may collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of cryptocurrencies, which may then be associated with other data you have provided to us.
2.Use of Your Personal Data
a.We may process your Personal Data to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your Personal Data to:
- facilitate the creation of and secure your account;
- identify you as a user in our system;
- improve the administration of our Service and quality of experience when you interact with our Service, including, but not limited to, by analyzing how you and other users find and interact with the Service;
- provide customer support and respond to your requests and inquiries;
- investigate and address conduct that may violate our User Agreement;
- detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;
- send you a welcome email to verify ownership of the email address provided when your account was created;
- send you administrative notifications, such as security, support, and maintenance advisories;
- send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services;
- respond to your inquiries related to employment opportunities or other requests;
- comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
- act in any other way we may describe when you provide the Personal Data.
b.We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
- Disclosure of Your Personal Data
- Third Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities by facilitating KYC procedures; provide technical and customer support; and/or to provide other support to us and to the Service.
- Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.
5.Your Choices Regarding Information.
You have several choices regarding the use of information on our Services:
- Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service or third parties’ goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the Notifications preferences in your Settings page. Despite these preferences, we may send you occasional transactional service-related informational communications.
- If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.
6.Legal bases for the processing of your Personal Data
The Company may use Personal Data based on following legal bases:
- To enable the Company to enter into an agreement with you, after which The Company will execute this agreement, such as but not limited to the agreement for the delivery of The Company products and/or services;
- To enable The Company to meet its statutory obligations;
- We are always looking for ways to make our Services smarter, faster, more secure, integrated and useful to you. It is in our legitimate business interests to continue to maintain and improve Services. The processing is necessary for the purposes of the legitimate interests pursued by The Company, including the interest to perform its business activities, except where such interests are overridden by the interests of fundamental rights and freedoms of the data subjects that require protection of Personal Data. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.
- Lastly, we may also use the personal data you provide to us for marketing purposes, and in particular to offer you personalized offers.
* When we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
*Where we are using your information because we have a legitimate interest to do so, you have the right to object.
7.Retention of Your Personal Data
8.Security of Your Personal Data
The security of Your Personal Data is important to Us. We take necessary and proper measures to protect your Personal Data, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.
9.Transferring Data to Abroad
Within the scope of conducting our business activities, information and communication technology applications and software (“IT Systems”) (“Yandex e-mail software, G-Cloud Systems”) will be used. The infrastructure and databases of these services may be located abroad.
Due to the fact that the infrastructure of the IT Systems and databases that are used for conducting communication activities and keeping your data safe may be located abroad, your personal data will be transferred abroad “with your explicit consent”.
BITCI GLOBAL includes suitable technical, organizational and contractual safeguards (including Standard Confidentiality Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules of the relevant country.
a.Your Rights under the CCPA. The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, You have the right to request that we disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Personal Data. Once we receive and confirm Your request, we will disclose to You:
- The categories of Personal Data we collected about You
- The categories of sources for the Personal Data we collected about You
- Our business or commercial purpose for collecting or selling that Personal Data
- The categories of third parties with whom we share that Personal Data
- The specific pieces of Personal Data We collected about You
- If we sold Your Personal Data or disclosed Your Personal Data for a business purpose, we will disclose to You:
- The categories of Personal Data categories sold
- The categories of Personal Data categories disclosed
- The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your Personal Data. To submit an opt-out request please contact Us.
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct Our Service Providers to delete) Your Personal Data from our records, unless an exception applies. we may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
- Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
b.Your Rights Under the GDPR
- Objection: Depending on the situation, you have the right to consent or object to the processing of your Personal Data and the conditions under which this processing takes place.
- Access: You have the right to request from us, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal Data regarding you is being processed, ii) information on the purposes for which Personal Data is processed, iii) the categories of Personal Data concerned, and iv) the recipients or categories of recipients to whom the Personal Data is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal Data being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal Data relating to you.
- Rectification, erasure, blocking or deletion: You, where appropriate, have the right to rectification, erasure, blocking or deletion of your Personal Data that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate.
- Notification: You have the right to a notification to third parties to whom your Personal Data has been disclosed, when you have been granted any rectification, erasure, blocking or deletion as stated above, unless such notification proves to be impossible or requires a disproportionate effort from us.
- Withdraw consent: where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
- Complaint with relevant authority: You have the right to file a complaint with the relevant data protection authorities.
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact Us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require Your parent's consent before we collect and use that information