Privacy Policy

Our website address is: cryptoapa.com.

DATA PRIVACY POLICY

  1.  Introduction

This is the data privacy policy of CryptoApa Group (“CryptoApa”).

CryptoApa respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit one of our websites (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

  1.  Important information:

Purpose of this privacy policy

This privacy policy aims to give you information on how CryptoApa collects and processes your personal data through your use of this website, including any data you may provide through this website when you provide your personal details or consent to receive further materials from us or our business partners.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

CryptoApa is the controller of and is responsible for your personal data (also collectively referred to as “we”, “us” or “our” in this privacy policy).

CryptoApa Group may, from time to time, be made up of different legal entities. This privacy policy is issued on behalf of each CryptoApa Group company so when we mention CryptoApa, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for operating this website and for processing your data.

We have appointed a data protection manager (“DPM”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPM in the following ways:

Full name of legal entity: CryptoApa Ltd

Email address: [email protected]

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1.  The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  •                Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  •                Contact Data includes billing address, delivery address, email address and telephone numbers.
  •                Financial Data includes bank account and payment card details.
  •                Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  •                Technical Data includes internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  •                Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  •                Usage Data includes information about how you use websites, products and services.
  •                Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect and store information about criminal convictions and offences.

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 into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. 4.      How is your personal data collected?

We use different methods to collect data from and about you, including through:

  •               Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o      applies or register for products or services;

o      creates an account on our website;

o      subscribes to our service or publications;

o      request marketing materials to be sent to you;

o      enter a competition, promotion or survey; or

o      give us feedback or contact us.

  •               Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. For more information about the cookies we use, please see ‘Cookies’ below.
  •               Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

o      Technical Data from the following parties:

  •  members of our affiliate network;
  •  our business partners;
  •  third party data exchanges;
  •  analytics providers (e.g. Google, Yandex);
  •  advertising networks; and
  •  search information providers.

o      Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

o      Identity and Contact Data from data brokers or aggregators.

o      Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

  1.  How we use your personal data

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 a 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.
  •               Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new user / customer(a) Identity (b) Contact(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To process and deliver orders including: (a) Managing payments, fees and charges(b) Collecting and recovering money owed to us(a) Identity (b) Contact(c) Financial(d) Transaction(e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover amounts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey(a) Identity (b) Contact(c) Profile(d) Marketing and Communications(a) Performance of a contract with you (b) Necessary to comply with our legal obligations(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use particular pages/products/services)
To enable you to complete a survey(a) Identity (b) Contact(c) Profile(d) Usage(e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use pages/products/services, to understand user preferences, to develop our pages/products/services and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity (b) Contact(c) Technical(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and other illegal activity and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with our legal obligations
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our sites and the advertising we serve to you(a) Identity (b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) TechnicalNecessary for our legitimate interests (to study how customers use particular pages/products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to map your journey through our sites, to improve our website, products/services, marketing, customer relationships and experiences(a) Technical (b) UsageNecessary for our legitimate interests (to define the types of customers visiting our websites, to understand their interactions with our sites, to keep our websites updated and their content relevant, to develop our business and to inform marketing strategies)
To understand your preferences and make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity (b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and CommunicationsNecessary for our legitimate interests (to develop and promote pages / products / services and grow our business)
To obtain professional advice or comply with our legal obligations(a)    Identity (b)    Contact(c)    Financial(d)    Transaction(e)    Technical(f)     Profile(g)    Usage(h)    Marketing and Communications(a) Necessary for our legitimate interests (for obtaining professional advice) (b) Necessary to comply with our legal obligations

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us and/or certain External Third Parties if you have requested information and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express “opt-in” consent before we share your personal data with any third party for marketing purposes.

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 at any time.

Cookies

Cookies are small pieces of information stored by your browser on your computer’s hard drive. We use cookies to allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited, to determine the most popular areas of a website and generally in order to monitor usage of a website. Most web browsers automatically accept cookies, though you do not have to. We do not control the use of cookies by third parties. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1.  Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  •               Companies within the CryptoApa Group.
  •               External Third Parties (defined in the Glossary below).
  •               Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1.  International transfers

We may transfer your data outside the European Economic Area (“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.
  •               Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  •               Where we use providers based in the US, we may transfer 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.