1. Important information and who we are
Our European representative
We have appointed the following entity as our local representative in Europe:
Local representative: Circle Trade Europe Limited
Postal Address: White Collar Factory, 1 Old Street, London, England, EC1Y 8AF
If you are based in Europe, you have the right to make a complaint any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. What information does Coinsky collect?
We collect Personal Data and Anonymous Data, as described below.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, photographs, biometric information (including but not limited to device fingerprinting), company name, and password when you use our Site.
- We may also collect other Personal Data provided by third party identity verification services or via social networking websites.
- If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
- Certain services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- We also collect other types of Personal Data that you provide to us voluntarily when seeking support services, such as email, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
- We may collect other data, including but not limited to, referral URLs, your location, blockchain analytics information related to blockchain addresses you provide.
Some information is collected automatically by our servers:
- Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
- We retain information on your behalf, such as transactional data and other session data linked to your Account.
Information about criminal convictions
When you register for or otherwise use our Services, we may receive information about your criminal convictions whe we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to close your Account but we will notify you if this is the case at the time.
3. How does Coinsky use the information it collects?
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you and perform identity verification through a service provider;
- provide improved administration of our Site and Services;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
- identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
- notify you about important changes to our Terms; and
- respond to your inquiries related to employment opportunities or other requests.
All data collected automatically will be used to administer or improve our services.
- We use IP address to make our Site and Services more useful to you, and to perform identity verification.
- We use NetVerify by Jumio (“Jumio”) to verify your identity by determining whether a selfie you take matches the photo in your form of identification. NetVerify’s facial recognition technology collects information from your photos that may include biometric data, and it shares this information with us. We use that information to verify your ID. We will store your biometric data for as long as is necessary to perform the services and comply with applicable law. By using the Coinsky services, you agree Jumio may collect your biometric data from the photos you submit to perform ID verification and that Jumio may share that information with us.
- We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
Coinsky does not sell user data to any third party.
We provide you with choices regarding certain Personal Data that Coinsky uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
(i) Promotional offers from us
We may use your Personal Data to determine what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
By using our Services or requesting information from us, you opt-in to receive marketing communications, except in Vermont.
Vermont customers can opt-in to receive promotional offers by contacting us.
(ii) Third-party marketing
We will obtain your express consent (opt-in) before we share your Personal Data with any company outside of the Coinsky group for that company's own marketing purposes.
(iii) Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
4. How does Coinsky share my personal information?
- It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of Coinsky, our users, or the public.
- We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
Coinsky may contain links to other third party websites which are regulated by their own privacy policies. Coinsky is not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Site.
5. Transfers outside of the EEA if you are based in Europe
We share your Personal Data within the Coinsky group of companies which are based in various locations globally. If you are based in Europe, this will involve transferring your data outside the European Economic Area (EEA)
In addition, many of our external third parties are also based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- In respect of transfers to entities in the US, we may transfer Personal Data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
6. How can you update your information?
You can update your information by contacting support and making a request.
We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account, open a ticket in our support center. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.
8. What security precautions does Coinsky take to protect me?
We take the protection of your personal information seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information. Coinsky servers and business operations are entirely located in the United States.
Please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:
This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request".
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
If you need to add or change any information, you can log into your Account and make the change in your settings. If it doesnt look like you can make the change on your own, please reach out to us via the Support Center and we'll take care of it.
This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law.
Please note: your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request.
|Object to processing||
You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your Personal Data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
|Request restriction of processing||
This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
|Request to transfer||
If you ask us, we will provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
|Withdrawal of consent||
This applies where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Children's privacy
Unfortunately, if you're under 18, you can't use our Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we'll delete it immediately.
11. Contacting Us
12. Other Important Information
For Vermont customers:
In accordance with Vermont law, Coinsky will not share your non-public personal financial information with nonaffiliated third parties, except as required or permitted by law, or if you specifically consent to the disclosure. In addition, Coinsky will not share credit reports with third parties, including affiliates, except with your express consent.