Privacy Policy

Account information

To register a User Account and use it, we may ask you to provide:

• Your full name;

• your e-mail address and create a password;

• Your_telephone_number

• your complete home address (country, state/province, postal code, city, street, number);

• your gender ;

• date of birth and place of birth;

• identity card or passport number (issuing country, number, expiry date etc.);

• images, and documents allowing your identification;

• proof of personal address, such as but not limited to (electricity bill, bank statement, government mail), your photo or video as a selfie;

• and all the information required by our AML/CFT policy (such as the AML/CFT questionnaire, estimated amount of your projected activity, the purpose of your purchase, the origin of your Assets used to purchase on the Platform, your employment, your position, your field of activity, the identity of your employer, URL of your employer’s website, if applicable, a copy of your signature, the beneficial owner of your purchase etc.);

• your transaction history, orders, device and browser information, login data, IP address, geolocation data, date, time and duration of use of the Platform, links you visited, links you were directed to on the Website; and

• as well as any information you voluntarily provide to us.

We use and/or store your e-mail address:

(a) to verify your identity when you log in to your Account;

(b) to contact you regarding your account or the operation of the Website (technical support emails), send emails with our newsletters, announcements, and other offers (marketing emails); and

(c) to comply with our legal obligations.

We store passwords protected against unauthorised access using a password hash function. We encourage you to create a strong password and avoid sharing it with others for the security of your Account and Assets.

Purpose of collection

We use and share the information we collect on the Website for the purposes described in this Privacy Policy. In addition to the purposes listed above, we may use the information we collect for the following purposes :

• create your User account and provide the Services;

• identify and authenticate you in order to access certain features of the Website;

• identify and authenticate you in order to comply with our obligations to combat money laundering and the financing of terrorism;

• conduct research and analysis to improve your experience and the Services provided to meet your needs and interests;

• maintain the Services and respond to your requests;

• investigate and resolve any difficulties, queries, disputes, and litigation relating to the use of the Platform;

• to detect and prevent illegal, fraudulent, and all types of activities that may endanger or adversely affect the integrity of the Services; and

• investigate any actual, alleged or suspected breach and ensure compliance with our policies and Terms of Use and as may be required by applicable laws and regulations, state or administrative authorities or judicial institutions.

In addition, we use the information we collect:

(a) to give you control over the active account session (data information on connected devices, order history, etc.); and

(b) to conduct our marketing research.

In addition, usage data is collected anonymously and in aggregate, where possible.
Please note that some information, such as transaction history, will be stored to comply with legal requirements.

Your communications with Us

If you need technical support, have a data request or any other request, you can contact us and leave your message. In this case, we will inevitably receive personal data about you. We will use this data to provide you with any assistance you may require, to repair a possible malfunction of one of our Services, to analyse the effectiveness of the Website, and for the purposes of the processing described above.

Social networks
We have official social network pages such as Facebook, Twitter, Instagram, Telegram. When you interact with our social network pages, such as subscribing to the pages, leaving comments or preferences (e.g., ‘liking’ our posts), we may analyze this data to measure our effectiveness and perform analysis of our marketing on social networks.

Cookies
A cookie is a small text file that is downloaded to your device (such as a computer or smartphone) when you access the Website. It allows us to recognize your device and store certain information about your preferences or past actions.
For more information on our use of cookies, please refer to our Cookies Policy.

Provision of our services
We process your e-mail address, Wallet information, usage data, and certain types of cookies to provide you with the Services. Without this information, we will not be able to provide you with the Services available on the Platform.

International transfer of information
As we operate internationally, it will be necessary, where appropriate, to transfer information to countries outside your country of residence. In which event, we endeavour to take steps to provide a similar level of protection.

Legitimate interests
For marketing purposes, we process your website activity statistics and usage data. This data helps us to understand our target groups and to conduct marketing research.
We may also send you occasional emails with updates to the Platform or new products/services, and other marketing emails for informational purposes.
You can also deactivate e-mail subscriptions by clicking on the appropriate button in our e-mails.

Legal compliance
As noted above, we are required to store certain types of information in order to comply with laws (for example, AML/CFT obligations). We will ensure that this information is treated strictly in accordance with applicable laws and we will not use this information for any other purpose (except as set out in this notice).

Age
We do not intend to collect or process personal data from children (under 18 years of age). Only natural persons, who are already 18 years old, can open a user account, and provide us with information.
If we believe that someone under the age of 18 has provided or attempted to provide us with their personal information and has opened an account, we will permanently delete the information from our database and close that account.

Third-party access to your information

AML/CFT, technical support and e-mail notifications
To comply with anti-money laundering and anti-terrorist financing (‘AML/CFT’) laws, we are required to collect, retain, and analyse documents that identify you, contact information, transaction history, verification data, including from third party sources (e.g., consumer reporting agencies, public databases, business registries and sanctions lists), and other types of information required by law.
We can conduct all the necessary investigations directly or through a third party (“AML/CFT and KYC Provider”). In the event that the AML/CFT and KYC checks are conducted by an AML/CFT and KYC Provider, you must agree to their terms and conditions. Failure to submit to the necessary investigations either conducted by us or an AML/CFT and KYC Provider will result in your Account being temporarily or permanently suspended and/or deleted.
The AML/CFT Provider might share with us data about you anonymised or not or not. We will keep the information collected confidential and will not use the data in your AML/CFT profile for any other purpose than the conduct of AML/CFT checks. For more information on KYC, please refer to our AML/ CFT and KYC Policy

We also use third party services to :
– Provide you with technical support when using the Platform;
– Manage our relationships with users (using customer relationship management software);
– Analyse usage flows and products using analysis tools;
– Create personalised and targeted advertisements;
– Conducting the AML/CFT procedure; and
– Send our notifications, newsletters, announcements and product/service offers by e-mail.

Analysis services.To analyse our effectiveness and conduct marketing research, we use the services of analytics providers. When using analytics services, we may share anonymous, aggregated details about the use of the Platform, including, but not limited to, usage flow data, location data, length of visit, and other communication data. This information does not identify a specific individual and is therefore considered non-personally identifiable information.Non-personally identifiable information may be collected and processed, along with other services, by Google Analytics in an anonymous and aggregated manner to improve the usability of the Platform and for marketing purposes.Google Analytics is a web analytics service that tracks and reports traffic on the Platform. Google Analytics uses the data collected to track and monitor the use of our Platform. This data may also be shared with other Google services.

Other Disclosures
In addition to the disclosures for the purposes identified above, we may share information about you:
– if we are required to do so by law, in connection with legal proceedings or to establish, exercise or defend our rights. For example, we may be required to save and store the history of transactions made on the Website to comply with our legal obligations under financial regulations. If requested by a court, governmental authority, and/or administrative authority, we will be required to share the data with them; and
– in the event that we sell, license or otherwise transfer our Company, the Business Rights, the Website, or its separate applications or features to third parties.
Except as provided in this Privacy Policy, we will not sell, share or rent your information to third parties.

Retention of your information
We will retain your information for as long as you use the Website and keep your account open. We will not retain your information if you delete your account or if you do not use the account for more than 5 years.
Please note that in order to comply with our legal obligations, we will need to retain AML/CFT information for 5 years after the relationship with you has ended (e.g. after the account has been closed or inactive for more than 2 years).

Your rights

Our Users reside in different countries. We felt it was important that all our Users have the same rights with regard to their personal data.

• Object to the processing of your information. If we are processing your information for our legitimate interests, for example for technical support e-mails, direct marketing or marketing research purposes, you may object. We will consider your request and, if there is no legal reason to refuse (e.g. public interest), stop processing for such purposes;

In this case, we will not process the information for any purpose other than storage or legal compliance until the restrictive circumstances cease to exist.

Ask us to delete / destroy / otherwise remove your information. If we are not obliged to retain the data for legal purposes, we will delete your data

Please note that deleting your information may affect your experience on the Website or lead to the termination of the relationship between you and us if the data was strictly necessary for the provision of the Services.

If you believe that our collection and processing of your personal data violates your rights, you can take your case to your national data protection authority.

Information security. The servers have technical measures in place to store the data securely and protected against unauthorised access. Please note that data shared with third party service providers may be stored on the servers of those providers. To maintain processing, we may transfer information to foreign countries, for example for technical maintenance purposes. In this case, we will ensure that the necessary safeguards to process the information are in accordance with our privacy policy. For more information about our server you may contact us directly. We take necessary and sufficient measures, including hashing and encrypting certain information , to protect your information from unauthorised or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties. Immediate access to some of the data is only allowed to our authorized employees involved in the maintenance of the Platform. These employees maintain strict confidentiality and prevent unauthorized access to personal information by third parties.

Changes to the Privacy Policy
We may update this Privacy Policy by posting a new version on the Website. We recommend that you check this page regularly to ensure that you agree to any changes. We will endeavour to provide you with an announcement of any significant changes.

Third party services
The Platform may contain links to third party services. While we choose our partners carefully and diligently, we cannot be responsible for the content, terms and conditions or privacy policies of third-party services.