Last Revised: May 4, 2020
- Important information and who we are
- What information do we collect?
- How do we use the information we collect?
- How do we share your Personal Data?
- Transfers outside of the EEA if you are based in Europe
- How can you update your information?
- How long do we keep your information?
- What security precautions do we take?
- Your legal rights
- Children's privacy
- Contacting Us
1. Important information and who we are
European Supervisory Authority
If you are based in Europe, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (the UK supervisory authority for data protection issues (www.ico.org.uk)) or the supervisory authority of the country in which you are based. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
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.
Some information is collected automatically by our servers:
- 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.
Some information is collected from third parties:
We may obtain Personal Data about you from other sources, including through third party services such as sanctions screening services and other organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to close your Account but we will notify you if this is the case at the time.
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).
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- 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.
Data collected automatically will be used to administer or improve our Services and for other lawful purposes.
- 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.
We may create aggregated or de-identified records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use and aggregated and other de-identified information for any purpose and disclose to third parties in our sole discretion.
Where European Union data protection laws apply, such as the General Data Protection Regulation, we will process your personal data for the purposes described above and for marketing (described below) where we have a lawful basis to do so, as set out at the start of this section 3. For example, for processing necessary to provide you with the Services, the lawful basis will generally be that it is necessary for the purposes of performing our contract with you. For marketing (described below), we may send you marketing based on it being in our ‘legitimate interests’ to do so (where you are a corporate customer) or based on consent where you are acting in an individual capacity. Other processing we do, such as that for product development and improvement, may not be ‘necessary’ to provide the Services but may still be necessary for our ‘legitimate interests’ of running a business and offering the Services.
We provide you with choices regarding certain Personal Data that we use, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Personal Data to determine what may be of interest to you in accordance with applicable law. This is how we decide which products, Services, and offers may be relevant for you.
In accordance with applicable law, we may obtain your express consent (opt-in) before we share your Personal Data with any company outside our group for that company's own marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
4. How do we share your Personal Data?
- 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.
The Site may contain links to other third party websites which are regulated by their own privacy policies. We are not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Site.
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.
We may also use Google Analytics, and other service providers to collect information regarding visit, or behavior and visitor demographics on our Services. For more information about Google Analytics: www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.
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 EU.
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:
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".
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.
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:
Request to transfer
If you ask us, we will provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawal of consent
This applies where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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.
12. Contacting Us