Last Revised: January 8, 2023
- 1. Important information and who we are
- 2. What information do we collect?
- 3. How do we use the information we collect?
- 4. How do we share your Personal Data?
- 5. Transfers outside of the EEA if you are based in Europe
- 6. How can you update your information?
- 7. How long do we keep your information?
- 9. What security precautions do we take?
- 10. Your legal rights
- 11. Children's privacy
- 12. Contacting Us
2. What information do we collect? We collect Personal Data and Anonymous Data, as described below. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, tax ID, identity information, photographs, company name, and password when you use our Site.
- We may also collect other Personal Data provided by third party identity verification, market surveillance providers, and sanctions screening services, service providers, regulators or via social networking websites.
- If you fill out a survey or tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
- Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- We also collect other types of Personal Data that you provide to us voluntarily when seeking support and other Services, such as email, chat name and logs, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
- We may collect referral URLs, your location, and blockchain analytics information related to blockchain addresses you provide. Some of the Personal Data used by the blockchain and crypto exchange services is public information and can be seen by others, including, your public address and the type and amount of digital assets transferred. Additionally, certain technologies, such as blockchain, are immutable meaning that information, including Personal Data, cannot be deleted from the ledger. If you have concerns about this use of your Personal Data, do not use the Services.
- Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
- We retain information on your behalf, such as transactional data including records for trades, deposits, and withdraws for you and the counterparty to the transaction and other session data linked to your Account.
3. How do we use the information we collect? We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- Where we need to comply with a legal or regulatory obligation.
- You have provided your consent (or explicit consent where we process facial recognition and biometric data).
- facilitate the creation of and secure your Account on our network;
- identify you and perform identity verification through a service provider;
- provide improved administration of our Site and Services;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
- identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
- notify you about important changes to our Terms; and
- respond to your inquiries related to employment opportunities or other requests.
- We use IP address to make our Site and Services more useful to you, and to perform identity verification.
- We use third parties to verify your identity by determining whether a selfie you take matches the photo in your form of identification. The vendor’s facial recognition technology collects information from your photos that may include facial recognition or biometric data, and it shares this information with us. We use that information to verify your ID. We will store your biometric data for as long as is necessary to perform the Services and comply with applicable law.
- We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
- It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of us, our users, or the public.
- We may share Personal Data with our affiliated companies.
- We may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such data and other information with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks.
- We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to us. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
- We may provide Personal Data to business partners with whom we jointly offer products or services as allowed by law. In such cases, our business partner’s name will appear with ours.
5. Transfers outside of the EEA if you are based in Europe We share your Personal Data within our affiliated group of companies, which are based in various locations globally. If you are based in Europe, this will involve transferring your data outside the European Economic Area (EEA) In addition, many of our external third parties are also based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by putting in place appropriate safeguards, as required by applicable law. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
6. How can you update your information? You can update your information by contacting support and making a request. We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account, open a ticket in our support center. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
7. How long do we keep your information? We retain Personal Data for as long we need it for the purposes set out in this Policy. This period will vary depending on the nature of the information and your interactions with our Site and our Services. If you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
9. What security precautions do we take? We take the protection of your Personal Data seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your Personal Data. Our servers and business operations are entirely located in the United States. Please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure.
10. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below: Request access This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". Request correction This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you need to add or change any information, you can log into your Account and make the change in your settings. If it doesnt look like you can make the change on your own, please reach out to us via the Support Center and we'll take care of it. Request deletion This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law. Please note: your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request. Object to processing You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
- 1. if you want us to establish the data's accuracy;
- 2. where our use of the data is unlawful but you do not want us to delete it;
- 3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- 4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
11. Children's privacy Unfortunately, if you're under 18, you can't use our Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we'll delete it immediately.