PRIVACY POLICY

Last updated on June 14, 2019

This Privacy Policy governs the privacy terms of our website, located at https://criptex.com/, mobile application Criptex Mobile app and the tools we provide you (all together are referred as the "Site", "Services" or the “Platform”). Our Privacy Policy is a legal statement that explains how Rozental1313 S.L. (“Company”, “we”, “us”, or “our”), with its registered address at Avinguda Diagonal, 534, Barcelona, Spain, collect, retain, process and transfer personal data that we receive when you access or use the Platform.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

INFORMATION WE COLLECT

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data. This is information you give us about you by filling in forms on the Platform, or by corresponding with us (for example, by e-mail). It includes information you provide when you register to use the Platform. If you contact us, we will keep a record of that correspondence. The information you give us may include:

Contact and personal information (full name, date of birth, gender, language, home address, email address, phone number);

Account information (username, password, account settings and preferences);

Financial information (trading information);

Identity verification information (copies of identification documents, such as passport, national ID card, driving license, residence verification information, such as utility bill details or similar information, and any other information you provide us in order to comply with our legal obligations and various anti-money laundering (AML) obligations and to prove your eligibility to use our Services).

All types of Personal Data described above are referred as the “Submitted Data”.

Information automatically collected. We automatically collect certain information when you visit, use or navigate the Platform. This information is primarily needed to maintain the security and operation of our Platform, and for our analytics and reporting purposes.

This information may include computer or mobile device and usage information, such as technical information, including the internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use (the “Usage Data”).

Data we may collect from third parties. We may receive data about you from other sources, including third parties that help us update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze your use of our Services (the “Third Party Data”).

Special categories of Personal Data. We do not collect any sensitive data about you, including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or sex life and/or sexual orientation.

USE OF DATA

We use personal information collected via our Platform for a variety of purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

In a table below you can find a description of the ways in which we 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.

Purpose and/or activity and legal basis

Submitted Data. We use this information to conclude a contract between you and us regarding the use of the Platform at your initiative and to perform this contract, including to:

  • create and maintain your account;
  • establish and maintain a responsible commercial relationship with you;
  • fulfill our obligations under the contract with you and guide you through the contract performance;
  • enforce our terms, conditions and policies for Services.

Submitted Data. Usage Data. Third Party Data. We use this information for verifying your identity to prevent fraud, deception and other illegal activities and to confirm your eligibility to use our services, and improve our counter-fraud practices. It is our legitimate interest to ensure that the Platform is not used for fraud, and all the users are eligible to use it.

Submitted Data. Usage Data. We use this information for communication with you and direct marketing: upon your consent we will provide you with news, changes to our Service, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about. These processing activities is necessary for our legitimate interests.

Submitted Data. Usage Data. Third Party Data. We use this information in our legitimate interests, namely to:

  • gather analysis or valuable information so that we can evaluate and improve our Service;
  • detect, prevent and address technical issues of our Platform;
  • administer our Platform for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our Platform is presented in the most effective manner for you;
  • keep our Platform safe and secure.

Submitted Data. Usage Data. It is our legal obligation to respond to legal, regulatory, arbitration process or requests for information issued by public authorities or other third parties, and prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

By accepting this Privacy Policy, you agree that we have the right to share and disclose your Personal Data in the following situations:

  • Compliance with Laws and Legal Rights. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). We may also disclose your information when we conduct or cooperate in investigations of fraud or other illegal activity and to prevent and detect fraud and crime.
  • Business Partners, Contractors and Affiliates. We may share your data with business partners, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do perform their obligations. For example: payment processing, data analysis, email delivery, hosting services, customer service, anti-fraud databases, screening agencies. We may allow selected third parties to use tracking technology on the Platform, which will enable them to collect data about how you interact with the Platform over time. We may also share information about you with our affiliates. Affiliates include our parent company and any subsidiaries, joint venture partners or other members of our group of companies. Our affiliates, partners and contractors will be required to meet our standards on processing data and security.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.

We do not share, sell, rent or trade any of your information with third parties without your consent, except as required by law.

WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share and disclose your Submitted Data, including, but not limited to: identification document number and/or issue date, copies of identification documents (for example, passport, driving license), with the following third parties on their request. If you do not use the following third parties’ services on our Platform, your Submitted Data will not be shared with them.

  • Invoice and Billing

    PayPal (their Privacy Policy can be viewed at https://www.paypal.com/us/webapps/mpp/ua/privacy-full )

    Paysera (their Privacy Policy can be viewed at https://www.paysera.com/v2/en-RU/legal/privacy-policy)

    Stripe (their Privacy Policy can be viewed at https://stripe.com/US/privacy)

    We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

  • Retargeting Platforms (they allow us to optimize and serve advertising based on the use of the Platform by tracking Usage Data and by using Cookies):

    Facebook Pixel. It is operated by Facebook Inc., Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). This allows to track users’ actions after they have been forwarded to our Platform by clicking on a Facebook advertisement. This tool helps us to measure the effectiveness of Facebook ads for market research and statistical purposes, in particular to better understand and deliver ads and make them more relevant to you. The collected data is stored and processed by Facebook, and this data is anonymous to us. Facebook may connect this data with your Facebook account and use it for its own advertising purposes. You can opt-out of Facebook’s use of cookies and Facebook Pixel through settings on your Facebook Account.

    Facebook’s Privacy Policy can be viewed at https://www.facebook.com/about/privacy/

  • We share and disclose your Cookies and Usage Data for the web and mobile analytic purposes with the following third parties:

    Google Analytics. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google Analytics” or “Google”). Google Analytics uses cookies that are stored on your computer or mobile device in order to track and examine your use of the Platform. The information generated by the cookies is transmitted to Google’s server in the USA and stored there.

    Google’s Privacy Policy can be viewed at https://policies.google.com/privacy.

    You may opt-out of the data generated by cookies about your use of the Platform to be transmitted and processed by Google by installing the add-on for your browser (https://tools.google.com/dlpage/gaoptout)

USE OF COOKIES AND LOCAL STORAGE

We use cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.

A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our Platform.

Local storage allows a website or application to store data locally on your browser or mobile device, without transferring data to the server. Local storage allows us to receive information about your use of the Platform.

By using the Platform, you consent to the use of cookies and local storage.

Why do we use Cookies and Local Storage?

Cookies enable the webserver to respond appropriately on your web browser repeated requests an access because your web browser contains data linking the latter with the webserver. Cookies are to provide user-friendly services because they store previous users’ preferences. You can customize cookies, delete or refuse all cookies at any time in the settings of your browser. You can find the relevant information in the help functions of your browser. However, this can also lead to the fact that you will no longer be able to access certain functions of the Platform.

For more information regarding the Cookies management please refer the settings of the browsers:

We use local storage to store certain information about your use of the Platform, including essential and additional information. Essential information includes user profile data (such as a user token, i.e. a token required to identify a user account in the system), so that you can log in automatically and we can detect when you're returning to the Platform, associating you with your existing account. Additional information includes information about how you browse and use the Platform, to help us improve our services. We do not use any locally stored data for advertising or remarketing purposes.

You may erase locally stored data by deleting your browser’s history. Please note that if you choose to clear local storage this can affect the availability of our Platform and some features of the Platform may not function properly.

Management of cookies and types of Cookies

The types or categories of Cookies our Platform uses are the following:

  • Absolutely necessary cookies

    Our Platform uses absolutely necessary cookies which does not require your consent. This type of cookies cannot be de-activated via the “Privacy settings” on the Platform, however, you can switch them off in your browser whenever you want. Please, bear in mind that de-activation absolutely necessary cookies may affect the Platform functionality.

  • Third party cookies

    The third party may provide content on various sections of Platform. This type of cookies is called “Third party cookies”. To provide content the vendors or third party must also comply with applicable data protection and privacy legislation. Furthermore, we work with third parties to ensure that only necessary information is provided which you have chosen.

  • Functionality cookies

    Cookies on functionality are used identify your preferences and customize the Platform upon them. For these purposes we may collect the following information: pages opened, topics or rubrics opened.

  • Analytical and performance cookies

    Analytical and performance cookies collect information about how you use our Platform. This type of cookies is to provide the efficiency of the Platform its usability and user-friendliness. If you disable them, we are not able to customize and develop Platform upon your preferences. For the purposes of performance analyses, we collect the following type of information:

    • session duration;
    • page views;
    • traffic source;
    • browser;
    • device;
    • IP address;
    • actions taken (e.g. PDF downloads clicks, form submissions).

Cookies’ life

The cookies are stored depending the webserver setting, therefore, their storing period may vary. The cookies may be stored either for session period or permanently. However, you can easily delete cookies in the web browser setting.

When you use the Internet, specific information will be automatically transmitted from your Internet browser and stored by us in so-called log files (Logging).

The log files are saved for malfunctions’ identification and for safety reasons for a short period time. If a further retention of log files is required for evidence purposes, these logs will be exempted from deletion until the incident investigation completion.

The following data, may be stored in the log files of the source of access:

  • IP address (Internet protocol address) of the end device which was the tool to online access;
  • Operating system and information on the Internet browser used, including add-ons (e.g. for the flash player);
  • Volume of transferred data;
  • Internet address of the website (or URL);
  • Name of the service provider;
  • Name of the retrieved files or information;
  • Date, time and duration of the access;
  • http status code.

TRANSFER OF YOUR INFORMATION

The data that we collect from you is stored within our secured servers in Germany and may be transferred to the United States, Spain, Ukraine. By accepting this Privacy Policy and providing us with your Personal Data, you give us your consent to such transfer. If you decline to consent to such transfer, you will no longer be able to use the Platform. If you are a resident in the European Economic Area (EEA) your data may be transferred outside of the EEA in order for us to fulfill our contract with you to provide the Service as we provide an international service. Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under applicable law are implemented. We will take all steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

This Privacy Policy applies regardless of the location in which we store and process your Personal Data.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

RETENTION OF YOUR INFORMATION

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, subject to our own legal and regulatory obligations, unless a longer retention period is required or permitted by law.

We will either delete or anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes or in order to improve our Service (in which case we may use this information indefinitely without further notice to you):

  • Within 1 month after you delete your account on the Platform;
  • If you don’t commit any action on the Platform for 12 months, and remain inactive for 1 month after we email you reminding of possibilities offered by our Platform and asking if you wish to delete your account.

Personal Data collected on you when you register an account with us will be stored for the mandatory period of time set forth by our legal and regulatory obligations, even if your account has not been successfully activated (e.g., if account verification has not been completed) or no transaction has been made using it.

SECURITY OF DATA

We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of any personal data we process. However, please also remember that we cannot guarantee the security of your data transmitted to our Platform via the Internet. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the services within a secure environment. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage.

YOUR DATA PROTECTION RIGHTS

Depending on the applicable data protection laws, you may be entitled to certain rights in relation to your Personal Data. We may refuse your request where permitted or required by applicable laws.

These rights include:

  • The right to access personal data – you have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us.
  • The right to rectify inaccurate data – you have a right to request that any incomplete or inaccurate personal data concerning you is corrected.
  • The right to object to processing– you have a right to object to processing of your personal data being carried out by us if we are processing it based on legitimate interests or if we are using personal data for direct marketing purposes.
  • The right to data portability – in certain circumstances you can request to be provided with a copy of personal data concerning you in structured, commonly used and machine-readable format.
  • The right to erasure – you can request that certain personal data held by us is deleted in some circumstances such as where we no longer need it or if you withdraw your consent (where the consent was the basis for processing).
  • The right to withdraw consent – where we have relied on your consent for the processing of your personal data, you have the right to withdraw that consent at any time, but this will not affect the lawfulness of any processing carried out before you withdraw your consent.
  • The right to restriction of processing – you can ask to restrict or stop the collection, use, processing and/or disclosure of your Personal Data.

If case you wish to exercise any of the rights stated above, please contact us using the details provided below.

Please note that we may ask you to verify your identity before responding to such requests and, in certain circumstances, charge a fee to cover our costs. Our time limit to respond is within one month after receiving the request. If it takes longer to process your request, we will notify you.

You also have the right to withdraw consent to electronic marketing at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list – however, we will still need to send you Service-related emails that are necessary for the administration and use of your account.

If you are a resident in the EEA, you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.

CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this policy, we may notify you on our Platform or by email. We will also change the "Last updated" date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

CONTACT US

If you have questions, comments or requests regarding this Privacy Policy, please email us at [email protected]