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Privacy Policy

This Privacy Policy, combined with the Terms of Use, are the stipulations governing the collection, processing, and use of our Personal Data by Coinstockx.  As applied in the context of this Privacy Policy, “Coinstockx”, “we”, “us” or “our” means to Coinstockx Europe S.A., a Payment Institution registered under the Luxembourg Trade and Companies Register, specifically number 196.856, and registered address – 21-25, allee Schaeffer, L-2520, Luxembourg, and Coinstockx Limited, registered within Wales and England Companies Registrar under the number 8157033, and its registered address at 5, New Street Square, London EC4A 3TW, England.  Coinstockx Europe S. A. and Coinstockx Limited are data controllers under the conditions of this Privacy Policy, and as such, sets out the means in which both companies, as data controller, may make use of your Personal Data. 

“DP Law” – Data Protection Law applicable to Coinstockx, inclusive of the EU General Data Protection Regulation 2016/679, its implementing texts and/or its successors.  “Personal Data” has the meaning as stipulated in the DP Law.  This notice governs how we use your Personal Data resulting from the use of the Coinstockx website (www.coinstockx.com) and registering/subscribing/buying/using Coinstockx services and products.  In the event where you have inquiries or require any further clarity, kindly contact us.  Our contact details can be found in the Contact Us section of our website.

In this Privacy Policy, capitalised terms carry the definitions as contained in the Definitions section above.

 

Coinstockx is committed to the security, protection, and respecting of your privacy.  We are using this Privacy Policy to describe;

  • The forms of Personal Data we collect and the way we use it;
  • Our use of cookies and related technologies;
  • How and why we may make available your Personal Data to third parties;
  • The transfer of your Personal Data within and outside the European Economic Area (“EEA”)
  • The security measures we have put in place to guide against misuse, loss, or a change in Personal Data; and
  • Coinstockx safekeeping of your Personal Data.

 

COLLECTING AND USING PERSONAL INFORMATION

  1. THE PERSONAL INFORMATION WE GATHER

We only receive the Personal Data you provide us with expressly, or which we generate on your opening of a Coinstockx Account; make transactions on the Coinstockx Platform, or use other Coinstockx Services or our Site.  This may include;

  • Contact information, including name, home address, and email address;
  • Account information, including username, password, account settings, and preferences;
  • Financial information, including bank statement, bank account numbers, and trading information;
  • Identity verification information, including pictures of your ID (government-issued), passport, national identity card, or drivers’ license. Note: Residents in the United States may be required to drop their social security numbers;
  • Residence verification information, including utility bill details, or related information;
  • Information related to how you use our Services, such as when you make use of Services and the particular Services used; and
  • Information regarding your communications with us, either via the email or through a phone call or similar media.

Automatically, we retrieve certain computer, device, and browsing information when you make use of our Site or Services.  Such information is further gathered to provide us with statistical data on the browsing actions and patterns of our users, without identifying the individuals personally.  Such information may include;

  • A mobile device or computer information, such as IP address, operating system, network system, browser settings, and type;
  • Usage information of the website

 

Lastly, we may also retrieve Personal Data from third party partners as well as public sources, and these include;

  • Financial information
  • Reputational information
  • Business activities of corporate customers

We also require the collection of specific types of information for compliance with legal requirements that are in line with our anti-money laundering/anti-fraud/counter financing of terrorism and know-your-customer mandatory requirements.  In the case that such information is not given, we may be disabled to offer you the service.  It is possible that we process your Personal Data, if necessary, on a reasonable request by regulatory authority, body or agency; law enforcement authority, or to defend legal claims.  Note that we tend to keep personal data if we find them relevant to an ongoing investigation or a dispute.  Personal Data will be accumulated continuously until we can solve the issue fully.  We will never participate in the behavioural tracking of the data collection of a customer via our Service, except as clearly stated in this Privacy Policy.  The mandatory retention period is usually applied to the data we collected when you create an Account is set by the law and is crucial to effective management and regulation of proper documentation of our operations in line with the requirements expected if us as regulated financial sector professionals.  This is going to hold, either your account has been successfully activated or not, or no transaction has been made on such account.

 

  1. USING COOKIES AND SIMILAR TECHNOLOGY

There are cookies incorporated on the Site, and these are small text files which are embedded on your computer by websites you browse.  Cookies are used extensively to enhance your browsing experience, or improve efficiency while offering information to site owners.  Ordinarily, cookies will be stored on the hard drive of your computer.  When we collect information via cookies, we utilise them in the evaluation of how effective our Site is performing, make trends analysis, and administer the Platform.  Such information also enables us to discover such statistics as; which segments of our Site do Users visit the most, and which part do they encounter difficulties in accessing.  With such information, we can significantly improve the quality of Users’ experience in the process of visiting our Site.

Likewise, we are also using a third party service provider(s).  They assist us in achieving an improved understanding of the use of our Site.  Our Service provider(s) are allowed to place cookies on your computer hard drive and retrieve such information that we identify to help us with the knowledge of such things as how visitors navigate our website, which services or products are most checked, as well as the general Transaction information.  Our service provider(s) then do a thorough analysis of this information and in turn give us the aggregate reports, which we in turn use in having a better understanding of our visitors, and thus serving them better.  Information received from you while using our platform is not totally unlinked with that received from our service provider(s).  Our service provider(s) is/are contractually prohibited from utilising the information they retrieve from the visitors to our Site for anything different from helping us. 

If you are not interested in using cookies, there is an option to have it disabled in your browser.  But you should note that when you disable cookies, it might be impossible for you to assess specific features of our Services or website. Such features include but not limited to Coinstockx Account or making transactions.  However, when you use our website or service with a browser that is configured to accept cookies means that you accept all of our third-party cookies.

 

  1. USING YOUR PERSONAL INFORMATION

There are many reasons we collect your information.  We require some information to enter into and perform our contract – for instance, your payment details and contact.  Likewise, we will need some of your personal information to effect some processing, as stipulated by the law due to our anti-fraud screening obligations or in the public interest, including the verification of identities of customers.

The following processes are what we use your personal information for:

  • Create and make use of your Coinstockx account, for such purposes as accounting, billing, and maintenance of legal documentation, claim and dispute management. To achieve an effective performance of a contract with you, there is the need for related processing operations, as well as to ensure compliance with legal obligations to which we are subject;
  • Process your Coinstockx transactions; we will require related processing operations for the performance of a contract with you as well as to ensure compliance with legal obligations to which we are subject;
  • Confirm your identity as stipulated in the applicable money laundering, know-your-customer and related financial sector regulations and legislation. These also include the requirements for us to comply with the law enforcement requirements as elaborated in our Terms of Use, and generally as required for compliance with regulations and legislation applicable to Coinstockx.  There may also be the need to share your information – if you are a US citizen and a Coinstockx customer – with other financial institutions (as authorized under Section 314(b) of the US Patriot Act), or with tax authorities, including the US Internal Revenue Service (in accordance with the Foreign Account Tax Compliance Act – FATCA).  We will also need related processing operations to ensure the performance of a contract with you and to make sure we comply with legal obligations to which we are subject;
  • Personalise your Coinstockx Services experience; we require related processing operations for purposes of our legitimate interests (i.e., improving and promoting our services);
  • Make an excellent analysis of the Coinstockx website usage, while improving the contents and offerings; we require related processing operations for such purposes as legitimate interests (including the enhancement and promotion of our services);
  • Assist us serving better response to your customer service requests and support needs; we require related processing operations for the issuance of a contract with you, as well as for our legitimate interests (including improving our offering to serve you better);
  • Contact you about Coinstockx Services. The email address you dropped with us may be used as a means of getting back to you with information and useful updates to your use of Services.

 

AUTOMATED DECISIONS MAKING

Coinstockx may make decisions automatically on certain matters.  One of those instances is in making the decision either to offer you our services on a credit check or risk profiling basis.  Based on what we get as results of the credit check/risk profiling, we will reach an automated decision on whether you are worthy enough to enjoy our services on credit, using your creditworthiness as the determining factor.

 

In any event, where you do not agree with such automated decision, you have the right to contest such decision by reaching us through our email address – dpo@coinstockx.com.

 

  1. MARKETING

We hold the right to occasionally send you news, updates, promotions and similar information relating to Coinstockx’s products and services.  Likewise, we may also create a promotion, contest, survey or related site features, more details of which will be present on the website. This will only be done in situations where you have given us your consent, or when we are permitted under the DP law and in pursuit of our legitimate interests, which is the promotion of our services.

Also, we may share personal data with third parties in assisting us with our promotional and marketing projects, as well as sending marketing messages. In the event that you want to stop receiving such promotional and marketing emails, posts, text messages and related means of communications from us (or our promotional partners) about which we might send you per this section.  Here are the steps to opt out of these promotional messages:

  • Log into your account, and update your profile
  • Click “unsubscribe”; it is located towards the ending of the email you received
  • Reach us at dpo@coinstockx.com to opt-out.

Note that even though you have opted out of receiving marketing and promotional messages, we can still reach you on such matters about our business relationship with you.  Thus you may get messages from us based on account status, activity updates, survey requests as regards to products and services we offered you after you reserve from us.  Reservations are confirmations or responses to inquiries or complaints lodged by you, as well as related communications. 

 

DISCLOSING AND TRANSFERRING PERSONAL DATA

Coinstockx may share your Personal Data with third parties, including regulatory and legal authorities.  Likewise, we may need to transfer your Personal Data within and outside the EEA, according to the procedures highlighted below:

 

  1. DISCLOSURES TO THIRD PARTIES

In some situations, we may have to transfer your personal data to employees, contractors and other third parties;

  • We may disclose your personal information with other members of our group of companies. This is to ensure that you enjoy the best customer service from every cadre of our group, and the receivers of such information are bound to keep your data following the stipulations of this Privacy Policy.
  • We may disclose your personal information with some contractors and service providers. These parties are into processing; thus they process your personal data for us. Such recipients include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres.  These set of recipients will be bound to satisfy our requirements for information processing and security, and we provide such information to them by its connection with their performance ONLY.

 

  • We may also disclose your personal information with some other third parties, and we do this either after receiving your consent or because there is the need to use this information to provide the products and services that you desire adequately. Such third parties in this context include reference agencies, anti-fraud databases, screening agencies and our business partners.

Here are the scenarios in which we may transfer your personal data to other third-party organisations

  • In an event where we are discussing transferring or selling a part or our entire business – the information may be assigned to prospective buyers, but under suitable terms that will ensure confidentiality;
  • In the event that we reorganise or are sold, information may be transferred to a new buyer who will continue with the provision of such services to you;
  • In the event that the law compels us, either under any regulatory code, a practice we follow or asked by a regulatory and public authority, e.g., police;
  • In the event that we are in the process of defending a legal claim, in which case your information might be needed to achieve an effective defence.

Your information may also be shared if aggregated and made anonymous, because, in such instances, your information is no more a personal data.  However, your information will never be sold, exchanged, or disclosed to any third parties, without your consent, except in the process of providing Coinstockx Services as stipulated by the law. 

Coinstockx’s third party service providers are always contractually bound to keep your information safe, and only utilise them for such purposes as stated in the contract, and as stipulated herein, except as otherwise demanded or permitted by law.  We always ensure that such contracts are drafted in line with the demands of the DP Law.

 

  1. DISCLOSURES TO LEGAL AUTHORITIES

We may also share your Personal Data with data protection authorities, government authorities, and law enforcement authorities, among others in such situations where;

  • We are compelled by court order or similar legal directives
  • Such disclosure is required to report perceived illegal activities
  • Such disclosure is required to effectively investigate violations of this Privacy Policy or our Terms of Use

 

  1. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Coinstockx usually stores and process your Personal Data in data centres around the world, and in such locations where our facilities or service providers are situated.  Thus, we may send your Personal Data outside the European Union.  However, some countries where your personal data may be sent to for these purposes are not located within the European Union; thus they do not benefit from an adequacy decision provided by the EU Commission concerning the protection is given to personal data in that Country.

For more information on these specific countries as described above, kindly check https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Please note that such transfers are done in compliance with our regulatory and legal obligations, while appropriate safeguards as stipulated under DP Law will be implemented, including standard data protection clauses with data processors or recipients approved by relevant authorities.  You can request a copy of such information at the address presented in the Contact Us section of our website. 

YOUR STATUTORY RIGHTS

You are entitled to some certain rights on your Personal Data, as stipulated under the DP Law.  Such rights can be exercised by contacting us at dpo@coinstockx.com.

Access:

You have the right to confirm the status of your personal information processing, and if we are, you can further ask to access your personal data.  With this, you can get a copy of the personal data we have about you as well as certain other information relating to it, in the bid to check if we are truly and lawfully processing it.  Kindly note that Coinstockx, most times, processes a large quantity of information, and thus, we may ask you, as allowed by the DP Law, to be specific about the information or processing activities to which your request is concerned with, before having them sent across to you.

Correction:

You have the right to ask for a correction of an inaccurate or incomplete personal data about you.

Erasure:

You have the right to request that we remove a part or delete entirely personal information in some situations.  However, there are particular exceptions to this right, in which case, we may decline a request for erasure.  An instance of such a situation is where your personal data is required in connection with claims or compliance with the law.

Restriction:

You have the right to request that we suspend the processing of some of your personal information, for instance, if you would like us to prove its accuracy or why we need to have it processed.

Transfer:

You may ask us to transfer some of your personal data to another party.

Objection:

In such situations where we are processing your personal data according to legitimate interests, or interests of a third party, you have the right to challenge such processing.  However, you should note that we may be entitled to continue the processing of such information in compliance with our legitimate interests, or in such situations where such processing complies with legal claims.  Likewise, you are entitled to the right to object in the event where we are processing your personal data for marketing purposes directly.

Automated decisions:

You have the right to contest every automated decision made about you, in such instances where such a decision has a legal or an equally significant effect, and subsequently request for reconsideration.

You have the right also to subject a complaint with supervisory authority, especially in the Member State in the European Union where you are residing habitually, where we are situated, or where an alleged violation of Data Protection Law has occurred.  In the United Kingdom, the applicable authority is the Information Commissioner’s Office (Telephone – 0044 1625 545 700 or via www.ico.org.uk).  If you are in Luxembourg, the right authority will be the Luxembourg Data Protection Authority, which is reachable at www.cnpd.public.lu or on the phone via 00352 26 10 601).

 


 

PERSONAL DATA SECURITY

Coinstockx has put in place several security measures to make sure there is no breach of the confidentiality of your Personal Data and protect it from loss, theft, unauthorised access, alteration, destruction or misuse.  Some, but not all, security measures we use are;

  • Password protection databases and directorates;
  • Secure Sockets Layered (SSL) technology, which ensures that your information stays encrypted and sent across the internet without breach; and
  • PCI Scanning to actively protect our servers from hackers and related attacks

We ensure that we transmit through the SSL technology as well as encryption, all financially sensitive and/or credit information, safely into our database.  We only allow authorised Coinstockx personnel to access your Personal Data, and such personnel are compulsorily required to be maximally confidential with such information.  We will endeavour to review the security measures consistently, in reaction to a new and relevant technical and legal developments.

We will never ask you for financial or payment data, including your credit card number, account number, passcodes or pin number, either in an email or via text or any other communication you may receive from us.  Please, ensure that you check carefully any website that asks you for financial payment information as related to our services or reservations as operated by Coinstockx.  If you do not receive a suspicious request, never provide your information and ensure you immediately report it by contacting one of the service representatives as indicated in this Privacy Policy.

You hold the full responsibility for safeguarding your account passcode, membership pins and numbers; you must never share this sensitive information with anyone.  In the event of unauthorised use or similar breach of security concerned with your information, you shall notify us below immediately.

 

RETENTION OF PERSONAL DATA

Coinstockx only keeps Personal Data for so long it is still required to fulfil the purposes identified in this Privacy Policy, subject to Coinstockx legal and regulatory obligations.  In determining how long we will retain your personal data for certain categories of data, we make use of the following criteria;

  • The period you have spent as a Coinstockx member;
  • If there exist legal or contractual obligations that are in existence and which require us to keep the data for a specified period;
  • If there is an existing legal or financial claim that involves your relationship with Coinstockx;
  • If any applicable law, statute, or regulation allows for a specific retention period; and lastly
  • What the expectation for retention was at the period of receiving such data.

In compliance with our record keeping obligations, we will retain Account and related Personal Data for a period not less than five years (or up to ten years, as stipulated by the applicable law) after the closure or termination of an Account.

 

UPDATES TO THIS PRIVACY POLICY

The last revision date for this Privacy Policy is May 25, 2018, and it has been effective since then.  We reserve the right to change this Privacy Policy from time to time; thus we advise you to do a periodic review of the same.  Modifications, additions and subtractions effected to this Privacy Policy will be announced on our website, or via other similar means, and for a considerable period before and after the changes have been effected.

Account

This is the contractual agreement, wherein, a Coinstockx Member understand, acknowledge and give consent to Coinstockx Terms of Use and Privacy Policy, thus receiving approval to access and use Coinstockx services, including the sales, purchase and trading of cryptocurrencies, as well as associated Transactions. 

DP Law

Data Protection Law applicable to Coinstockx, inclusive of the EU General Data Protection Regulation 2016/679, its implementing texts and/or its successors. 

Coinstockx Platform

Software and hardware techs used by Coinstockx to offer the Coinstockx Service as stipulated in our Terms of Use

Personal Data

All information that can aid the identification of an individual.  Such include but not limited to name, address, email address, trading information, and banking details.  Kindly note that “Personal Data” is not inclusive of anonymised and/or aggregated data which does not identify a certain user.

Service(s)

The platform powered by technology, functional rules and market under the management of Coinstockx Ltd which allows Buyers and Sellers to sell, purchase and trade Bitcoins. 

Transactions

Transactions include any or all of:

  • The agreement between the Seller and the Buyer to trade Cryptocurrencies via Coinstockx Service for currencies. Such trading or exchange is usually at a commonly agreed price (“Purchase Transaction”);
  • The conversion of currencies into Cryptocurrencies deposited by Members on their Account (“Conversion Transaction”);
  • The transfer of Cryptocurrencies among Members (“Transfer Transaction”);
  • The transfer of currencies among Members (“Currency Transfer Transaction”); and
  • The buying of ancillary products (“Purchase Transactions”).

 

CONTACT US

Please contact us with questions, comments, or concerns regarding our Privacy Policy and/or practices at dpo@coinstockx.com.

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