Privacy Policy

for Cryptanite Ltd.

Effective Date: December 12, 2018 (v 1.8)

 

This Privacy Policy describes how we manage, process and store personal data submitted in the context of providing our services. “Personal data” refers to any information relating to an identifiable individual or their personal identity.

 

Scope and Consent

Acceptance.

Please read this Privacy Policy (the “Policy”) carefully. It may contain important legal rights, and constitutes a binding legal agreement between you and Cryptanite Ltd. (“Cryptanite Ltd.”, “us” or “we”). In order to use our Site and Services, we may collect personally identifiable information from you and your personal data, or request that you provide us with personally identifiable information (the “Personal Information” or “Personal Data”). Our collection of this information is detailed elsewhere in this Policy. Even information that is not immediately personally identifiable, or that cannot be currently traced back to you directly, may later, through technologies known or unknown, enable your usage of our Website and Services to be traced by to you, your computer, or a similar device. Examples of Personal Information include your IP address or Mac Address, your name, e-mail address, place of residence, and similar (for example, but not limited to, if provided to us via a registration form or similar), and any other Personal Information which you affirmatively make available to us, such as by your usage of a contact form, e-mail, or similar means.

 

We control the ways of collecting your personal data, and determine goals for which Cryptanite uses personal data. We are a “data controller” within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”) and other application European laws pertaining to data protection.

 

We process your personal data only if at least one of the following, but not limited to, terms stipulated by Article 6 of GDPR applies

 

-          you have given consent to the processing of your personal data;

-          processing is necessary for compliance with the legislation of the states to/from where we operate, etc.

 

By subscribing to our services or filling in a contact form on our website (www.Cryptanite.com) or other websites and applications owned by Cryptanite Ltd., you agree and accept that we may gather, process, store and/or use the submitted personal data under the rules set in this Policy and other public documents that published on this website.

 

By giving your consent to us, you also retain the right to have your personal data rectified and/or to be erased.

 

Cryptanite Ltd. may also collect non-personalized, or non-identifiable information (the “Anonymous Information”) in which we are unable, and do not foresee being able, to tie this data back to you or any particular User. Such data, by way of example, may include technical information regarding your anonymous usage of our website, aggregated data in which the uses of many Users, including your usage, is compiled in the aggregate, an anonymous User’s path through our Website or Services, and similar such data.

 

We may use the data we collect from you, whether Personal Information or Anonymous Information in various ways, as detailed throughout this Policy and other public documents that published on this website. We may also use third party services providers that may provide data collection services, or create software to enable data collection to facilitate our collection of your data. These service providers may also have access to Personal Information, consistent with their own privacy policies and terms of use.

 

Changes to the Policy

 

Cryptanite Ltd. reserves the right to update this Privacy Policy at any time, in particular pursuant to any changes made to the laws and regulations in force. You will be notified via our website or by email about any modifications made, to the extent possible, at least fourteen (14) days before any changes come into force.

 

Please feel free to contact us if you have any questions about Cryptanite Ltd.'s Privacy Policy or practices. You may contact our Data Protection Officer at DPO@Cryptanite.com or at our mailing address below:

 

Cryptanite Ltd.,

Ground Floor,

Palace Court, Church Street,

St. Julian’s STJ3049, Malta

 

If you do not agree with any alteration in our Policy, you must discontinue your usage of our Site and our Services. You may also request that your user account, if any, to be deleted or permanently disabled, and that we remove any information such as Personal Information, to the extent technologically possible, and consistent with additional provisions in this Policy.

 

Laws regulating personal data processing

Personal data of the clients being on the EU territory or being EU citizens is regulated, in particular, by the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”). Furthermore, legislation of the states to where we operate may determine additional requirements.

 

Collection of Personal Information

 

We collect the following types of personal information in order to provide you with the use of Cryptanite Ltd. Services under our products, and to help us personalize and improve your experience.

 

Information we collect automatically: When you use Cryptanite Ltd. Services, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information.

 

Information you provide to us: We may collect and store any information you provide us when you use Cryptanite Ltd. Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding Cryptanite Ltd. Services.

 

When you use Cryptanite Ltd. Services, depending on the services or products we provide, we also collect information about your transactions and your activities. In addition, if you open a Cryptanite Ltd. user account or use our Services, we may collect the following types of information:

●        Contact information, such as your name, address, phone, email and other similar information that will help us to verify you.

●        Detailed personal information, such as your date of birth or national ID number (including photo of your Driver's license).

 

We may also collect information from or about you from other sources, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with members of the Cryptanite Ltd. corporate family or other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole). Additionally, for quality and training purposes and/or for its own protection, Cryptanite Ltd. may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with Cryptanite Ltd., you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.

 

Information from other sources: You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and LinkedIn). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Cryptanite Ltd. account and authorizing Cryptanite Ltd. to have access to this information, you agree that Cryptanite Ltd. may collect, store and use this information in accordance with this Policy.

 

Authentication and Fraud Detection: In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with Cryptanite Ltd. Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

 

Using Your Mobile Device: We may offer you the ability to connect with Cryptanite Ltd. Services using a mobile device, either through a mobile application or via a mobile optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.

 

When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.

 

Rights of personal data subjects in accordance with GDPR

Cryptanite are considerate towards ensuring your rights established by GDPR.

Right to information

We are ready to give data subjects the information on their personal data which we process.

If you want to know which of your personal data we process, you can request this information at any time, including by reference to the Cryptanite data protection officer. You can find the list of data we must provide you in Articles 13 and 14 of the GDPR.  Thus, when applying you must state your specific requirements, so we could legitimately consider your request and provide a response.

Please note that if we are unable to verify your identity by e-mail messages or at your application to the call center, or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity. This is the only way we can avoid disclosing your personal data to a person who can perpetrate your identity.

We will process your request in the shortest possible time, but at the same time please remember that it is a complex process to provide you a full and legitimate answer in relation to your personal data, that can take up to a month.

Right to correct your personal data

If you find that some personal data which we process about you are incorrect or outdated, please inform us about it, including through Cryptanite data protection officer. In this case, we may ask you to provide a proof of identity, including by your personal appearance in Cryptanite office.

Withdrawal of consent to personal data processing and right to be forgotten

If Cryptanite processes your personal data subject to a consent to personal data processing, further processing can be terminated at any time. All you must do is to withdraw your consent to such processing.

You may also exercise your right to be forgotten. In cases stipulated in Article 17 of GDPR, Cryptanite will delete your personal data it processes, except for those personal data which we are obliged to store in accordance with the requirements set forth by the applicable legislation

Furthermore, in this case, for the purposes of safety, Cryptanite may request you to present your ID document, including directly at the Cryptanite office.

Technical, organizational and other measures of data protection

Technical, organizational and other measures of data protection

For safe storage of your personal data we have implemented various technical and organizational measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

Cryptanite observe the principle of personal data minimization. We process only the information we need, or the information you provide of your own free will beyond the required processing range. In addition, we have configured all the interfaces of our website and application to comply with highest confidentiality requirements.

We always use the safest and most proven routes of data transmission, when transferring personal data to public authorities.

 

Cookies

 

Cookies are one example of data that we automatically collect from Users, and a manner in which we interact with Users. Cookies may include Personal Information, or may be compiled from or along with Anonymous Information. A cookie is a piece of data stored on your computer that is tied to information about you and your usage of our Website or Services. We may use both session ID cookies (which are cookies that are specific to your usage of our Website or Services during one given browsing session), or persistent cookies (which are cookies that remain on your device beyond a single browsing session).

 

Session ID cookies are usually deleted when you close your browser, log out, or do a similar action on your device. Your browser’s help file may contain information on affirmatively deleting such cookies.

 

Persistent cookies are not deleted when you close your browser, but may be deleted manually, or may expire in time. Your browser’s help file may contain information on manually deleting such cookies.

 

We may also use other means of tracking your usage beyond the use of cookies, such as by using web beacons, or other forms of technology. This technology may change over time, and you may not be notified of changes in our methods of data collection.

 

You may also be able to prohibit our Website from placing cookies or similar web beacons on your device, and to limit our collection of your data in general, however this may limit your ability to use our Website and Services, or certain features. Your browser’s help file may contain information on disabling such access.

 

Cookies and similar data are used for various purposes, which include minimizing load times to our Website and Services, tracking and saving your preferences and those of other uses when you or they log in to or access our Website or Services, tracking your usage for technological or statistical purposes, tracking your usage in an attempt to improve or alter our Website or Services, or for various other purposes.

 

Certain third-party service providers and websites with whom we may partner, such as, but not limited to, Google Analytics, may also utilize cookies or other, similar web beacons that are loaded onto your device during the navigation of our Website or use of our Services. These third-party services providers may not be disclosed to you prior to your usage of our Website or Services. We may not have control over these cookies. These third-party websites may use these cookies to help provide insight into which areas of our Website and Services are frequently visited by you and other Users. These cookies may also be used to provide targeted advertisement to you and other Users. You may review the applicable privacy policies of these service providers to learn more about how they may use information they collect from cookies and other similar means.

 

How We Use the Personal Information We Collect

 

Our primary purpose of collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience.  Depending on the services or products we provide, we may use Personal Information to:

●        provide Cryptanite Ltd. Services and customer support;

●        process transactions and send notices about your transactions;

●   verify and identify your identity, including during account creation and password reset processes - to help prevent fraud or assess and manage risk;

●      Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing;

●        Determining that clients are not known or suspected terrorists by checking their names against lists of known or suspected terrorists;

●        Application of anti-money laundering solution, which delivers transaction risk scoring and reporting necessary to comply with AML regulation. We can use for this purpose company`s monitoring system or can involve our partners/contractors;

●        resolve disputes, collect fees, and troubleshoot problems;

●        manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;

●        detect, prevent or remediate violations of policies or applicable user agreements;

●        improve the Cryptanite Ltd. Services by customizing your user experience;

●        measure the performance of the Cryptanite Ltd. Services and improve their content and layout;

●        manage and protect our information technology infrastructure;

●        provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;

●        contact you at telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our User Agreement;

●        for customer service purposes, including to help service your accounts or resolve disputes;

●        or for any other means reasonably related to the means described in this section.

 

 

 

We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about the Services and the services of our corporate family. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you.

 

Marketing

 

We do not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. We may combine your Personal Information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.

 

If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by logging into your account and going to the Notifications section and updating your preferences, or by following the directions that may be provided within the communication or advertisement, or by contacting us directly.

 

We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.

 

How We Protect and Store Personal Information

 

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, the use of third-party service providers. We, and third-party service providers on our behalf, store and process your personal information in the United States and elsewhere in the world. If your information is transferred to other countries, including countries which may not have data protection laws that provide the same level of protection that exists in your country, we will protect the information as described in this Policy.

 

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers, and information access authorization controls.

 

We may store your Personal Information for as long as you are an active User of our Services and Website, for, by example, maintaining a user account with us, and for a reasonable amount of time after. We may also continue to store Personal Information to comply with legal, financial reporting, or other compliance obligations, such as to enforce this Policy, or the Terms. In the event you wish to affirmatively ensure that your Personal Information has been deleted or removed, you may send an e-mail request to support@Cryptanite.com, and we will make reasonable efforts to comply with your request, consistent with any applicable privacy laws, and other requirements as set out in this paragraph.

 

Anonymous Information may be stored indefinitely.

 

How We Share Personal Information with Other Cryptanite Ltd. Users

 

When transacting with others, we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. To facilitate dispute resolution, we may provide a buyer with the seller’s address so that goods can be returned to the seller. The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is against our policies and constitutes a violation of our Terms.

 

If someone is sending you money and enters your email address or phone number, we will provide them your registered name so they can verify they are sending the money to the correct account.

 

How We Share Personal Information with Other Third Parties

In order to provide our Services, we capture and store some information about customers, and also users uploading material to the service. Depending on the services or products we provide, we may obtain the following information from our users:

1.      IP Addresses

2.      First name, Last name, email address

3.      Information entered on our website or mobile app

4.      Photo of Driver License/Passport/ID (back and front side)

5.      Photo of a User  showing  his ID (passport or Driver License) in his hand

6.      Billing information

7.      Phone number
8.      Physical addresses (utility bills for confirm)

 

The data listed above are stored on secure servers. We don’t use data from uploaded files for anything, except for:

1.      Detecting its MIME-type (Multipurpose Internet Mail Extensions)

2.      Generating preview on request

3.      Converting or modifying the files on request from a Cryptanite Ltd. User who owns that file

4.      Verification and identifivation of the users

5.      Fraud prevention purposes and provision of our internet security services

6.      Internal marketing (not third party marketing)

7.      Billing

8.      Account management

 

All data stored by us is only used for internal processing, and never sold or otherwise given away excluding possible data transferring to agents on our behalf.

 

We may share your personal information we collect from you, including, but not limited to, your name, contact details, and transactions and activities, with:

●        Members of the Cryptanite Ltd. corporate family to provide joint content, products, and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services.

●        Banking and financial partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you meet their criteria which includes having Cryptanite Ltd. close your Cryptanite Ltd. Account due to your breach of the Cryptanite Ltd. Terms of Service).

●        Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice.)

●        Our partners or contractors that we may involve only for providing us with processing/monitoring system services/solutions to verify and identify your identity for help us preventing fraud or assess and manage risk. In these cases Cryptanite Ltd. liable  of onward transfers of personal information to these third parties. These third parties may situated outside EU;

●        Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Cryptanite Ltd. or one of its affiliates; when we need to do so to comply with law; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement including to meet national security or law enforcement requirements.

 

●        Other third parties with your consent or direction to do so.  

 

If we receive personal data subject to GDPR and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the GDPR - if  the agent on our behalf processes the personal data in a manner inconsistent with the GDPR, in this case we are responsible for the event giving rise to the damage.

 

Anyway, Cryptanite Ltd., as a Personal Data Controller responsible in the cases of onward transfers of personal information to third parties on our behalf.

 

Questions or Complaints

 

In compliance with the EU and Maltese legislation in particular GDPR, Cryptanite Ltd. commits to resolve complaints about our collection or use of your personal information.

If you are a resident of a EU country and you believe we maintain your personal data within the scope of GDPR, you may direct any questions or complaints concerning GDPR compliance to our Data Protection Officer at DPO@cryptanite.com or at our mailing address:


Cryptanite Ltd.,

Ground Floor,

Palace Court, Church Street,

St. Julian’s STJ3049, Malta

Contact us and afford us the opportunity to resolve the issue

We will work with you to resolve your issue.

 

Your rights regarding your Personal Data

 

You have the following rights, in certain circumstances, in relation to your personal information:

●        Right to access your personal information.

●        Right to rectify your personal information:  you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.

●        Right to restrict the use of your personal information.

●        Right to request that your personal information is erased.

●        Right to object to processing of your personal information.

●        Right to data portability (in certain specific circumstances).

●        Right not to be subject to an automated decision.

 

You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

If you would like to exercise these rights, please contact our Data Protection Officer DPO@Cryptanite.com or send your request to us, in writing to

Cryptanite Ltd.,

Ground Floor,

Palace Court, Church Street,

St. Julian’s STJ3049, Malta

 

We will aim to respond to you within period established by applicable law. We will need to verify your identity before we are able to disclose any personal data to you.

 

Using Log In with Cryptanite Ltd.

 

Log In with Cryptanite Ltd. allows you to streamline and simplify the account creation and login process when using third-party websites, and it allows these websites to enhance your experience on their sites. Instead of creating multiple usernames and passwords for each website you visit, Log In with Cryptanite Ltd. allows you to sign in to a participating website using your existing Cryptanite Ltd. login information. When you use Log In with Cryptanite Ltd., you agree that Cryptanite Ltd. can share the information listed on the Log In with Cryptanite Ltd. consent screen or in your Log In with Cryptanite Ltd. account settings with the participating website. Information you allow Cryptanite Ltd. to share with these third-party websites is subject to each third-party’s terms of service and privacy agreement, so you are encouraged to review their policies.

 

How You Can Access or Change Your Personal Information

 

If you a resident of  European Union, in accordance with the European General Data Protection Regulation (GDPR), you have a right of access, correction, and removal your personal data which you may exercise by sending us a support ticket at DPOt@Cryptanite.com.

Your requests will be processed within (thirty) 30 days. We may require your request to be accompanied by a photocopy of proof of identity or authority.

You are also able at any time to modify personal data by logging into your account and clicking on “Account Settings” or you can contact us via email at DPO@Cryptanite.com.

 

You can review and modify your personal information at any time by logging in to your account and reviewing your account settings and profile. You can also close your account through the Cryptanite Ltd. website. If you close your Cryptanite Ltd. account, we will mark your account in our database as "Closed," but may retain personal information from your account for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy for accounts that are not closed. We also may retain personal information from your account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce our Terms of Services, or take other actions as required or permitted by law.

 

SECURITY

 

Within the framework of its services, Cryptanite Ltd. attributes the very highest importance to the security and integrity of its customers’ personal data.

 

Thus and in accordance with the GDPR, Cryptanite Ltd. undertakes to take all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorized circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorized persons.

 

To this end, Cryptanite Ltd. implements industry standard security measures to protect personal data from unauthorized disclosure. In using industry recommended methods of encoding, Cryptanite Ltd. takes the measures necessary to protect information connected with payments and credit cards.

 

Moreover, to avoid in particular all unauthorized access, to guarantee accuracy and the proper use of the data, Cryptanite Ltd. has put the appropriate electronic, physical and managerial procedures in place to safeguarding and preserving the data gathered through its services.

 

Notwithstanding this, there is no absolute safety from piracy or hackers. That is why in the event a breach of security was to affect you, Cryptanite Ltd. undertakes to inform you thereof without undue delay and to use its best efforts to take all possible measures to neutralize the intrusion and minimize the impacts. Should you suffer any loss by reason of the exploitation by a third party of a security breach, Cryptanite Ltd. undertakes to provide you with every assistance necessary, so that you can assert your rights.

 

You should keep in mind that any user, customer or hacker who discovers and takes advantage of a breach in security renders him or herself liable to criminal prosecution and that Cryptanite Ltd. will take all measures, including filing a complaint and/or bringing court action, to preserve the data and the rights of its users and of itself and to limit the impacts.

 

How You Can Contact Us about Privacy Questions or Complaints

 

If you have questions or concerns regarding this Privacy Policy, you should contact our Data Protection Officer by e-mailing at DPO@Cryptanite.com. or to our mailing address below:

 

Cryptanite Ltd.,

Ground Floor,

Palace Court, Church Street,

St. Julian’s STJ3049, Malta

 

Place of personal data storage

 

Cryptanite has a large database of personal data. To ensure their safety, we use cloud services of Amazon Web Services EMEA SARL (5 rue Plaetis, L-2338, Luxembourg). Data stored by Amazon Web Services EMEA SARL are kept at data processing centers in Ireland.