Effective Date: 1 of March 2019
We believe your business is no one else’s. Your Privacy is important to you and to us. So we’ll protect the information you share with us. To protect your privacy, BITSMO follows different principles in accordance with worldwide practices for customer privacy and data protection.
- We won’t sell or give away your name, mail address, phone number, email
address or any other information to anyone. - We‘ll use state – of – the – art security measures to protect your
information from unauthorized users.
The Personal Information on the Technology Platform is collected, controlled and processed by the following entities: BITSMO LLC Peterburi tee 47, 11415 Tallinn, Eesti Vabariik
1.1 “Personal Data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.
1.2 “Special Category data” means personal date about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
1.3 “Processing” covers all activities relating to the use of personal date by an organization, from its collection through to its storage and disposal and everything in between.
1.4 “Data subject” means the person whose personal data is being processed.
2. Our Principles regarding user privacy and data protection
- We believe user privacy and data protection are human rights
- We take protecting your privacy seriously, and we recognize we have a duty of care to the people whose data we hold.
- We will only collect and process data when it is absolutely necessary, and when we do, we will make it clear why we are doing so and how it will be used.
- We will not send you regular email newsletters that you have not subscribed to
- We hate spam as much as you do! We will always give you the choice to unsubscribe.
- We will not share your personal information with anyone else without your permission.
3. What Kind of Personal Information We Collect
3.1. While providing our services we may collect the “Personal Information” which is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains. Namely, we may collect:
3.1.1. Identity information: name, facial image, social security number, ID number, documents proving your identity and any other information they may contain;
3.1.2. Residential information: IP address, residence address, documents proving your residency and any other information they may contain;
3.1.3. Contact information: email address, mailing address, phone number;
3.1.4. Security information: alias, passwords;
3.1.5. Financial and billing information: number of bank accounts and names of banking institutions, identifiers in payment systems or other means of payment, information on your balance accounts, your trade history, incoming and outgoing wallet addresses;
3.1.7. Your mobile devices You use with the Technology Platform may provide some information that may potentially identify You, such as the type (including identifiers) of the device, platform type, mobile phone number, Your internet service, operating system, geolocation information, browser You use, browser language, or the pages You visit, etc.;
3.1.8. The Technology Platform may collect some of your behavior information, such as your visiting the Technology Platform, clicking on ads or other similar information. Such information may be received with additional related data (or metadata), such as the time, date, and location related to such information;
3.1.9. Sometimes you decide to share with us some other Personal Information and we may collect it as well.
3.2. We do not collect any information that may identify you without your permission. However, We use Google Analytics on Our Technology Platform. If you want to know more about Google Analytics and its “do not track” policy, please visit https://www.google.com/analytics/terms/us.html
4. How We Use Your Personal Information
4.1. We, our authorized partners and our representatives store and use Your Personal Information only for providing and improving the Technology Platform. In particular, we use Users' Personal Information for the following purposes:
4.1.1. To provide you the Services: We may use information to execute your transaction requests and trade orders;
4.1.2. To comply with our legal obligations: In many jurisdictions we are obliged to collect certain information about our Users to be authorized to act (Know Your Client and Anti-Money Laundering regulations);
4.1.3. To protect your assets: We may use information to identify you and the assets belonging to you in order to secure access to your accounts and to prevent the fraud;
4.1.4. To improve customer service: information provided by Users helps Us respond to customer service requests and support needs more efficiently;
4.1.5. To personalize User experience: We may use information in a general manner to understand how Our Users as a group use the services and resources provided on Our Technology Platform;
4.1.6. To improve Our Technology Platform: We may use the feedback provided by Users to improve our products and services;
4.1.7. To maintain Our Technology Platform: We may use the information Users provide about themselves when receiving transaction request only to provide service to that request;
4.1.8. To send periodic emails: We may use the email address to send information and updates pertaining to your use of the transaction request;
4.1.9. To resolve disputes and enforce our agreements to the extent necessary and sufficient for protecting your interests or interests of other Users.
4.2. We strictly follow industry best practices in the industry and adhere to the rules set forth in GDPR, OPPA, CAN-SPAM and COPPA.
5. How We Can Share the Information
5.1. In certain situations, we may be required to disclose personal data in response to lawful requests by competent authorities, including to meet national security, public interests or law enforcement requirements. Our policies regarding exchange of information with competent authorities is reflected in Our Transparency Policy.
5.2. We may disclose your Personal Information where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on BITSMO), and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.
5.3. We share Personal Information with certain companies that perform services on our behalf on a need-to-know basis. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for BITSMO. You may find a list of these third-party sub-processors.
5.4. You agree that We may share and transfer Your information which no longer identifies You to the third party (pseudonymisation) who is a contracting party with Us, usually Our service providers or advertising partners.
6. For How Long We Retain Your Personal Information
6.1. We will retain your information for as long as your account is active, your information is needed to provide you services, or as required to fulfill our legal obligations.
6.2. By contacting us at (write a contact e-mail) you can at any time obtain the confirmation whether or not the personal data concerning you is being processed.
7. How We Protect Your Information
7.1. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal information, username, password, transaction information and data stored on Our Technology Platform.
7.2. Sensitive and private data exchange between the Technology Platform and its Users happens over an SSL-secured communication channel and is encrypted and protected with digital signatures. Our Technology Platform is functioning in compliance with PCI vulnerability standards in order to create an environment as secure as possible for Users.
7.3. Unfortunately, there is no such thing as completely secure data transmission or storage, so we cannot guarantee that our security will not be breached (by technical measures or through violation of our policies and procedures).
7.4. Without prejudice to Our efforts on protection of Your information nothing herein constitute a warranty of security of the Technology Platform, and You agree to transmit information at Your own risk. Please note, that the Technology Platform does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
8. What Are Your Rights to Your Data
8.1. All Your Personal Information we collect will always belong to you. However, we are a collector and a processor of Your Personal Information. That implies on us obligations to respect your rights to Personal Information and facilitate the exercise of your rights thereto. In order to use any of your rights at any time please contact us and we will facilitate the exercise of your rights free of charge. We will inform you on the actions taken by us under your request as soon as practically possible, but in any case not later than in 30 (thirty) calendar days.
8.2. In accordance with effective regulations you have a significant number of rights related to your Personal Information, such as e.g.:
8.2.1. Right to access. You may obtain from us the confirmation as to whether or not personal data concerning you is being processed and get an access to such personal data;
8.2.2. Right to rectify your inaccurate Personal Information and to have incomplete personal data completed, including by means of providing a supplementary statement
8.2.3. Right to erase your Personal Information. Please note that a request to erase your Personal Information will also terminate your account on the Site. We will automatically and without undue delay erase your Personal Information when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
8.2.4. Right to restrict processing of your Personal Information;
8.2.5. Right to data portability. You may obtain from us the personal data concerning you and which you have provided to us and transmit it to another Personal Information Controller;
8.2.6. Right to object to processing of Your Personal Information,
8.2.7. Right to withdraw your consent to the usage of your Personal Information at any time
Office of the Privacy Commissioner for Personal Data https://www.pcpd.org.hk/english/complaints/how_complaint/complaint/complaint.html
or (for EU) Information Commissioner’s Office https://ico.org.uk/make-a-complaint/.
9. Basis for Personal Data Processing
We collect and process your personal data only when we have a legitimate reason for such processing. Legal grounds include consent (in cases where you provide it), a contract (in cases where processing is necessary to fulfill the terms and conditions of contracts between you and BITSMO), compliance with a legal obligations (in cases where BITSMO is required to request / receive and process as well as to store your personal data in order to comply with the requirements of applicable laws, for example the laws related to legalization (laundering) of proceeds of crime, financing of terrorism and financing the proliferation of weapons of mass destruction) and legitimate interest (for example, when processing is necessary to protect you or us from certain threats (fraud, security, etc.), compliance with the provisions of applicable laws, the proper level of conduct of our business (the quality of the services provided, identification of needs, preparation of reports), conclusion and implementation of corporate transactions (sale of participant interests / shares, mergers, acquisitions), etc.).
In cases where the basis for data processing is the consent, you have the right to withdraw it at any time.
10.1. We do not intend to solicit or collect Personal Information from anyone under the age of 16 or under the legal age of your country, if it is higher. If you are under 16 or are not of a legal age of your country, do not enter any personal information on our Technology Platform.
Peterburi tee 47, 11415 Tallinn, Eesti Vabariik