Coinshift Limited Privacy Policy
Last Revised: September 6, 2024
Coinshift Limited, a British Virgin Islands company (“Company”) is committed to protecting User’s privacy. Company has prepared this Privacy Policy (this “Policy”) to describe to User: (i) Company’s practices regarding the Personal Information (as defined below) that Company collects; (ii) why Company collects it; and (iii) how Company uses and discloses it. This Policy should be read in conjunction with Company’s Terms of Use (the “Terms”), into which this Policy is incorporated by reference. User is encouraged to read the Terms first, as certain terms used in this Policy are defined in the Terms.
01 ACCEPTANCE OF THE POLICY
User’s privacy matters to Company, so User should take the time to get to know Company’s policies and practices. This Policy describes the types of information that Company collects from User or that User may provide when User uses the Platform, and Company’s practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this Policy carefully. If User does not agree with Company’s policies and practices, then please do not use the Platform. By using the Platform, User agrees to the terms of this Policy.
Company reserves the right to change any of Company’s policies and practices at any time, but User can always find the latest version of this Policy here on this page. User’s continued use of the Platform after Company makes changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
02 PERSONAL INFORMATION COMPANY COLLECTS
As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.
Personal Information Company Collects from User. Company (or Company’s Affiliates) may collect and store the following categories of Personal Information directly from User:
Online identifier information, such as IP addresses, Account Information, Wallet addresses, and other data connected to User’s Wallets, Accounts, domain names, and similar identifying names or addresses (collectively, “Online Identifier Information”);
Device information, such as hardware, software, operating system, browser, device name, and language preferences (collectively, “Device Information”);
Usage data, such as system activity, internal and external information related to the Platform, clickstream information (collectively, “Usage Data”); and
Geolocation data, such as information about User’s device location (“Geolocation Data”).
Automatic collection of Personal Information may involve the use of Cookies, described in greater detail below. Company does not currently store Online Identifier Information, Device Information, Usage Data, or Geolocation Data on Company’s systems; however, please be aware that third-parties with which Company might interact might store such information.Personal Information That May Be Collected Automatically. Company (or Company’s Affiliates) may collect and store the following categories of Personal Information automatically through User’s use of the Platform:
Online Identifier Information;
Device Information;
Geolocation Data; and
Additional information, at Company’s discretion, to comply with legal obligations.
Personal Information Company Collects from Third Parties. Company (or Company’s Affiliates) may collect and/or verify the following categories of Personal Information about User from third parties:
Online Identifier Information; and
Additional information, at Company’s discretion, to comply with legal obligations.
Accuracy and Retention of Personal Information. Company takes reasonable and practicable steps to ensure that User’s Personal Information held by Company is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.
03 INTENDED FOR USERS 18+
Company does not knowingly collect data from or market to anyone under 18 years of age. Company does not knowingly solicit data from or market to anyone under 18 years of age. By using the Platform, User represents that User is at least 18 years old, or that User is the parent or guardian of such a minor and consents to such minor dependent’s use of the Platform. If Company learns that Personal Information, from Users less than 18 years of age has been collected, Company will discontinue User’s access to the Platform, to the extent that is possible, and take reasonable measures to promptly delete such data from Company’s records. If User becomes aware of any data Company may have collected from anyone under age 18, please contact Company at [_________].
04 HOW COMPANY USES USER’S PERSONAL INFORMATION
Company collects Personal Information about User in an attempt to provide User with the best experience possible, protect User from risks related to improper use and fraud, and to help Company maintain and improve the Platform. Company may use User’s Personal Information to:
Provide User with the Platform. Company uses User’s Personal Information to provide User with the Platform pursuant to the Terms.
Comply with Legal and Regulatory Requirements. Company processes User’s Personal Information as required by applicable laws and regulations.
Detect and Prevent Fraud. Company processes User’s Personal Information to detect and prevent fraud.
Protect the Security and Integrity of the Platform. Company uses User’s Personal Information to maintain the security of User’s Wallet, Account, and the Platform itself.
Other Business Purposes. Company may use User’s Personal Information for additional purposes if disclosed to User before Company collects User’s Personal Information or if Company obtains User’s consent.
05 HOW COMPANY SHARES USER’S PERSONAL INFORMATION
Company will never sell, share, rent, or trade User’s Personal Information with third parties for their commercial purposes. Further, Company will not share User’s Personal Information with third parties, except as described below:
Third-Party Service Providers. Company may share User’s Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, customer support, data analytics, information technology, advertising and marketing, network infrastructure, storage, and transaction monitoring. Company shares User’s Personal Information with these service providers only so that they can provide Company with their services, and Company prohibits its service providers from using or disclosing User’s Personal Information for any other purpose.
Law Enforcement. Company may be compelled to share User’s Personal Information with law enforcement, government officials, and/or regulators.
Corporate Transactions. Company may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
Professional Advisors. Company may share User’s Personal Information with Company’s professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with Company’s legal obligations.
Consent. Company may share User’s Personal Information with User’s consent.
If Company decides to modify the purpose for which User’s Personal Information is collected and used, Company will amend this Policy.
06 COOKIES
When User accesses the Website, Company may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on User’s computer or other devices used to visit the Website. Company uses Cookies to help Company recognize User as a customer, collect information about User’s use of the Platform to better customize the Platform and content for User, and collect information about User’s computer or other access devices to: (i) ensure that User’s Account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent activities; and (ii) assess and improve the Platform and advertising campaigns.
User can also learn more about Cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies on different types of browsers and mobile devices. Please note that if User rejects Cookies, User will not be able to use some or all of the Platform. If User does not consent to the placing of Cookies on User’s device, please do not visit, access, or use the Website.
07 INFORMATION SECURITY
No security is foolproof, and the internet is an insecure medium. Company cannot guarantee absolute security, but Company works hard to protect Company and User from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information Company collects and stores. Measures Company takes include encryption of Company website communications with SSL; periodic review of Company’s Personal Information collection, storage, and processing practices; and restricted access to User’s Personal Information on a need-to-know basis for Company’s employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
08 INFORMATION FOR PERSONS SUBJECT TO EU DATA PROTECTION LAW
Company recognizes that customers may be located in the European Union (“EU”), European Economic Area (“EEA”), the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”). Accordingly, Company recognizes and adheres to relevant EU data protection laws. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Lawful Bases for Processing. Company processes personal data subject to GDPR on one or more of the following legal bases:
Legal Obligations: to conduct anti-fraud and to fulfill Company’s retention and other legal obligations;
Contractual Obligations: to satisfy Company’s obligations to User under the Terms, including to provide User with the Platform and customer support services, and to optimize and enhance the Platform;
Legitimate Interest: to monitor the usage of the Platform, conduct automated and manual security checks of the Platform, to protect Company’s rights; and
Consent: to market Company and the Platform. User may withdraw User’s consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.
European Privacy Rights. European residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:
Rights to Access and Rectification: User may submit a request that Company disclose the personal data that Company processes about User and correct any inaccurate personal data.
Right to Erasure: User may submit a request that Company delete the personal data that Company has about User.
Right to Restriction of Processing: User has the right to restrict or object to Company’s processing of User’s personal data under certain circumstances.
Right to Data Portability: User has the right to receive the personal data User has provided to Company in an electronic format and to transmit that personal data to another data controller.
To submit a request to exercise these rights, please contact Company using the methods described at the end of this Policy. When handling requests to exercise European privacy rights, Company checks the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. This will require User to provide Company with User’s unique Wallet identification. While Company maintains a policy to respond to these requests free of charge, should User’s request be repetitive or unduly onerous, Company reserves the right to charge User a reasonable fee for compliance with User’s request.
09 COLLECTION AND TRANSFER OF DATA OUTSIDE THE EEA
The Platform operates with many of Company’s systems based in the [______]. As a result, Company may transfer personal data to Europe, the United States, or other third countries, under the following conditions:
Contractual Obligation. Where transfers are necessary to satisfy Company’s obligation to User under the Terms, including to provide User with the Platform and customer support services, and to optimize and enhance the Platform; and
Consent. Where User has consented to the transfer of User’s personal data to another country.
Where transfers to a third country are based on User’s consent, User may withdraw User’s consent at any time. Please understand, however, that the Platform may not be available if Company is unable to transfer personal data to other countries.
When Company transfers personal data to third countries, Company endeavors to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.
10 BRITISH VIRGIN ISLANDS PRIVACY NOTICE
This Section 10 explains the manner in which Company and its Affiliates collect, process, and maintain User’s Personal Information.
Company and its Affiliates are committed to processing Personal Information in accordance with applicable law. In their use of Personal Information, certain members of Company or its Affiliates will be characterized under applicable law as a data controller, whilst certain of Company’s service providers, Affiliates, and delegates may act as data processors under applicable law.
Personal Information. By virtue of using the Platform, Company and its Affiliates may collect, record, store, transfer, and otherwise process Personal Information by which individuals may be directly or indirectly identified. Company and its Affiliates may combine Personal Information that User provides with Personal Information that Company and its Affiliates collect from User. This may include Personal Information that the Company collects when User uses the Platform, such as User’s Wallet or Account information.
Why is User’s Personal Information Processed. The storage, processing, and use of Personal Information by Company or its Affiliates will take place for lawful purposes, including:
to comply with any applicable legal, tax, or regulatory obligations on Company or its Affiliates under any applicable laws and regulations;
to perform a contract to which User is a party or for taking pre-contractual steps at User’s request;
to operate Company, including managing and administering rewards, Airdrops, and Company’s and its Affiliates’ businesses on an on-going basis which enables Company and User to satisfy their contractual duties and obligations to each other;
to verify the identity of Company and its Affiliates to third parties for any purpose which Company and its Affiliates may consider necessary or desirable;
to assist Company and its Affiliates in the improvement and optimisation of advertising (including through marketing material and content) its Platform;
for risk management and risk control purposes relating to Company and its Affiliates;
to pursue Company’s and its Affiliates’ legitimate interests: (i) for direct marketing purposes; or (ii) to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity, and share this data with legal, compliance, risk, and managerial staff to assess suspicious activities; and/or
where User otherwise consents to the processing of its Personal Information for any other specific purpose.
Data Controller. As a data controller, the Company or its Affiliates will only use User’s Personal Information for the purposes for which it was collected as set out in this Privacy Policy. If Company or its Affiliates needs to use User’s Personal Information for an unrelated purpose, Company will contact User. In certain circumstances, Company may share User’s Personal Information with regulatory, prosecuting, and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory.
Transfer of Personal Information Outside the British Virgin Islands. Company may transfer User’s Personal Information outside of the British Virgin Islands, as permitted under applicable law. Neither Company nor its Affiliates will sell User’s Personal Information.
User’s Rights. User may have certain rights under applicable law, including:
the right to be informed as to how Company and its Affiliates collect and use User’s Personal Information;
the right to access User’s Personal Information;
the right to require Company and its Affiliates to stop direct marketing;
the right to have inaccurate or incomplete Personal Information corrected;
the right to withdraw User’s consent and require Company and its Affiliates to stop processing or restrict the processing, or not begin the processing, of User’s Personal Information;
the right to be notified of a data breach (unless the breach is unlikely to be prejudicial); and
the right to require Company and its Affiliates to delete User’s Personal Information in some limited circumstances.
Please note that if User does not wish to provide Company or its Affiliates with requested Personal Information or subsequently wishes to withdraw User’s consent, User may not be able to receive rewards or participate in an Airdrop as it will affect Company’s ability to provide the Platform to User.
Retention of Personal Information. The Personal Information shall not be held by Company or its Affiliates for longer than necessary with regard to the purposes of the data processing.
11 CONTACT US
If User has questions or concerns regarding this policy or Company’s use of User’s Personal Information, please feel free to email Company at [_________] or write to Company at:
Coinshift Limited
Attn: Disputes
Trinity Chambers, PO Box 4301
Road Town, Tortola
British Virgin Islands VG1110