Privacy Policy

This Privacy Policy is effective as of October 29, 2022.

 

1. INTRODUCTION

Cryptomarkings provides software as a service, which allows you to utilize several functionalities for managing your cryptocurrency holding across different accounts, including SmartTrade Terminal, copy trading terminals and automated Trading Bots. This Privacy Policy explains the principles on how Cryptomarkings, registry code 13798279, address 27 Worlingham Road, London, England, SE22 9HD, e-mail [email protected] (“Cryptomarkings”, „our“, “we” or “us”) as the personal data controller collects and processes your (“you”) personal data when you visit the website https://Cryptomarkings.net/ (“Website”) and in relation to the provision of web-based application https://Cryptomarkings.net, Cryptomarkings mobile application(s) and application program interface9s) ("Software"). In case you act as the Signals Provider, please see our privacy notice for signals providers.

 

Capitalised terms used in this Privacy Policy are used in the meaning given to them in the Terms of Use unless otherwise expressly set out herein.

 

2. DATA WE COLLECT

We have set out in the table below the categories of personal data we collect and use about you:

 

Category of personal data

Data collected

When you visit our Website, Download our app or contact with us

 

Technical Data

 

Upon visiting our Website and login into our mobile application, we process technical data related to your usage of the Website, including but not limited to IP address, location data (down to city level), access-provider, referring URL, date, time, access tokens, session key, browser type and version, browser language, operating system, amount and state of transferred data. This information can be related to you, therefore, Personal Identification Information can be processed as well. These data may also be processed as anonymized statistical data.

 

Cookie Data

 

We apply cookies on the Website, for optimising the Website and its functionalities. The cookies may collect your personal data. To learn more about the cookies we use, please read our Cookie Policy

 

Communication Data

 

In case you interact with us via e-mails and sign-up forms, Cryptomarkings Facebook page, Youtube channel, Twitter page or Telegram or any other official social media account, we process, in addition to Personal Identification Information (limited in case of contacting via social media), also the contents of your message.

 

When you use the Software

 

Personal Identification Information

 

Name, e-mail address, 2FA key, IP address, language, Google Analytics client ID, Gravatar image, if you choose to sign up via Facebook, we collect your Facebook UID, Facebook profile name, Facebook e-mail, if you choose to sign up via Apple, we collect your Apple profile name, Apple e-mail or Apple generated e-mail. If you sign up via mobile application, we collect your device language, device region, device type and model.

 

Financial and Transaction Data

 

Exchange Account username, API key, API secret, passphrase, transaction data (date/time/amount of transaction), transaction request/response, Referral status, billing information (country, phone number, address, city, postal code; in case of an entity: business name, registry code and VAT ID)

 

The personal data we process is collected from one of the following sources:

 

the data is disclosed by you directly to us;

we receive the data from your Exchange Account provider due to you connecting your Exchange Accounts to the Client Account;

we receive the data from social media service provider due to you registering or contacting with us via your existing social media account;

we receive the data from the payment service provider due to you concluding the Purchase Agreement and paying for the Subscription;

we receive Technical Data automatically from your browser, our servers and systems;

 

3. What we use your personal data for

We have set out in the table below the reasons why we process your personal data:

 

Purpose for processing

Category of personal data processed

Legal basis

Client authentication

 

Personal Identification Information

 

Performance of the Terms of Use

 

Client identity verification (KYC) for recovery

 

Personal Identification Information

 

Performance of the Terms of Use

 

Client’s transaction history

 

Financial and Transaction data

 

Performance of the Terms of Use

 

Responding to your enquiries and requests submitted via the website, sign-up forms, live chat or e-mail or any social media platforms

 

Communication Data, however, depending on the nature of your enquiry we can process all the data indicated in Section 2 above

 

In case your question clearly relates to matters connected to the Terms of Use, Client Agreement or Purchase Agreement we process the data for the performance of the Contract. In other cases, we rely on our legitimate interests in ensuring effective relations management with all the interested parties in our Software and services

 

Client invoicing for the Purchase Agreement or for mediating your payments to Signals Providers (no personal data are shared with Signals Providers)

 

Personal Identification Information, Financial and Transaction Data

 

Performance of the Purchase Agreement or our legitimate interest in performing the Signaller Agreement concluded with the Signals Provider

 

Transfer of funds from a payment service provider to your Client Account and making out payments upon your withdrawal request via payment service provider

 

Financial and Transaction Data, Personal Identification Information

 

Performance of the Terms of Use

 

Determining your location for designating applicable VAT rate

 

Personal Identification Information

 

Performance of the Purchase Agreement

 

Handling the refunds related to Purchase Agreement

 

Personal Identification Information, Financial and Transaction Data, Communication Data

 

Performance of the Purchase Agreement or in certain situations performance of our legal obligation

 

Enabling your use of the Trial

 

Personal Identification Information

 

Performance of the Trial Terms

 

Enabling the Software and its functionalities

 

Personal Identification Information, Financial and Transaction Data

 

Performance of the Terms of Use and if relevant performance of the Purchase Agreement

 

Sending newsletters to your e-mail

 

Personal Identification Information

 

Consent

 

Providing you with notifications via your chosen channel (for example, mobile app, e-mail, Website, Telegram Bot)

 

Personal Identification Information

 

Consent given for the specific notification channel

 

Direct marketing campaigns - Client marketing campaigns in relation to the Software, its functionalities and products already provided to you

 

Personal Identification Information, Financial and Transaction Data (mainly the transaction activity)

 

Our legitimate interest in providing you with information relating to the services and products you have previously sourced from us

 

Processing data for predictive analytics and insights, improvement and development of the Software

 

All of the data categories indicated in Section 2 above

 

Our legitimate interest in improving and developing the Website and the Software within the course of our business activities or performance of the Terms of Use

 

Diagnosing and repairing technical issues related to the Software and the Website

 

Technical Data

 

Our legitimate interest in providing data security and preventing fraudulent actions related to the Software and the Website; ensuring the functioning of the Software and the Website

 

Storing information containing personal data in backup systems

 

All of the data categories indicated in Section 2 above

 

Our legitimate interest in ensuring the security of data processing operations

 

Data disclosures to potential acquirers of Cryptomarkings business, including legal advisors, auditing service providers in case of a merger, acquisition or selling the whole or part of our business

 

All of the data categories indicated in Section 2 above

 

Our legitimate interest in ensuring proper due diligence process and business continuity

 

Data disclosures to our service providers

 

All of the data categories indicated in Section 2 above

 

Our legitimate interest in utilising the information technology infrastructure and services provided by our co-operation partners

 

Mandatory disclosures to law enforcement and data protection authorities

 

All of the data categories indicated in Section 2 above

 

Performance of our legal obligation

 

We may process your personal data for other purposes, provided that we disclose the purposes and use to you at the relevant time, and that you either consent to the proposed use of the personal data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.

 

4. SHARING YOUR PERSONAL DATA

Any data you provide will not be publicly displayed or shared to other Website visitors or clients. Certain employees of Cryptomarkings have access to personal data to the extent necessary for the performance of their work duties.

 

We use third party processors and separate data controllers to help provide our service. They will have access to your personal data as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

 

We have set out in the table below the reasons why and with whom we share your personal data:

 

Categories of Recipients

Reason for sharing

Type of recipient

Service providers

 

We work with service providers that work on our behalf which may need access to certain personal data to provide their services to us. These companies include those we have hired to operate the technical infrastructure that we need to provide service, assist in protecting and securing our systems and services, and help market our service.

 

Most of the aforementioned service providers are located in the European Union or European Economic Area, however, some of those service providers are located in the United States and in the Russian Federation. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer.

 

Data processors

 

Payment processors

 

We will share your personal data with our payment processors as necessary to enable them to process your payments.

 

The aforementioned service providers are located in the United States and Canada. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer.

 

Data processors or separate controllers

 

Advertising partners

 

We work with advertising partners to enable us to customize the advertising content you may receive. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising. We and our advertising partners process certain personal data to help us understand your interests or preferences so that we can deliver advertisements that are more relevant to you.

 

The aforementioned service providers are located in the United States. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer.

 

We also provide you promotional e-mail campaigns related to our services (educational videos etc.) by using e-mail campaign service provider. In order to do this we may transfer your e-mail address to such service provider so that they can send you the materials.

 

Data Processors

 

You can verify your identity on our platform to recover your account when needed. The KYC verification process is operated by cryptomarkings.

 

Data Processor

 

Professional advisors (legal advisors, accounting etc. bound to confidentiality)

 

In case not operating as data processors, the legitimate interests in conducting and supporting our regular business activities.

 

Data Processors

 

Potential business acquirers and business transferee(s)

 

If necessary and required for successfully transferring our business or for the purposes of mergers and acquisitions, your Personal data may be disclosed to the specified acquirers and their representatives and / or legal counsels.

 

This is done based on our legitimate interests to sell and reorganize our business activities.

 

Separate data controllers

 

In addition to the information provided in the table above, in some cases, we may transfer your personal data outside the European Union, Africa or European Economic Area, if the recipient is located outside the European Union, Africa or European Economic Area. We shall opt to use special personal data protection safeguards, in order to ensure the safety of your personal data. For obtaining further information on the processors and recipients engaged by us or if you wish to get acquainted with or obtain information on the transferring of your personal data outside the European Union, Africa or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Privacy Policy.

 

5. ENSURING THE SECURITY OF PERSONAL DATA

We have taken necessary technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against the unauthorized disclosure, abuse or other processing in violation of applicable law. We also encourage you to take measures to ensure the safety of your personal data. In particular, we advise you not to share your personal data with us or any of our partners via any public forums or other public channels, unless you acknowledge and accept that relevant data will be publicly accessible.

 

6. RETENTION AND DELETION OF PERSONAL DATA

Your personal data (all data categories mentioned in Section 2) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 3 above, or until the legal obligation stipulates that we do so. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the processing purposes and whether we can achieve these purposes through other means, and applicable statutory obligations. Whilst retaining the personal data, we take into account the viable need to resolve disputes and enforce the contract between us or anonymize your personal data and retain this anonymized information indefinitely.

 

In case you are a Client, as a general rule we will retain all your data for 7 days after the termination of the Client Agreement in a manner that would allow you to re-activate the Client Account. Otherwise, please see the following non-exhaustive summary on storing your personal data:

 

For accounting purposes, we retain Financial Data and Transaction Data and Personal Identification Information connected to it for a period of 7 years from the end of the financial year when the respective business transaction took place;

Data connected to the Client Agreement or the Purchase Agreement, which is first and foremost Personal Identification Information, is retained for the whole period when the respective agreement is in force and at least 3 years from the moment of termination of the respective agreement under our legitimate interests to protection ourselves against potential disputes or enforce claims. In case we have a reasonable doubt that a party has acted in bad faith, has breached any obligations intentionally or has threatened us with a dispute, we may prolong such retention period for a maximum of 10 years.

Technical Data will be retained for 30 days as of the collection of such data;

Communication Data, unless clearly connected to the Client Agreement or the Purchase Agreement, will be retained for a period of 3 years from the moment the respective communication-flow has been closed.

In case any of the data stipulated in Section 2 above is needed for purposes of protection against ongoing or threatened disputes, we shall retain the related data as long as the dispute is solved.

 

After the expiry of the retention period determined above or the termination of the legal basis for processing purpose, we may retain the materials containing the personal data in the backup systems, from which the respective materials will be deleted after the end of the backup cycle. We ensure that during the backup period appropriate safeguards are applied and the backed-up materials are put beyond use.

 

7. YOUR RIGHTS AND PREFERENCES

Under data protection law, you have rights including:

 

Right to be informed and to access. You may get information regarding your personal data processed by us.

Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. Moreover, you may request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.

Right to erasure. You the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes.

Right to object and restrict. You have the right to object to the processing of your personal data and restrict it in certain cases.

Right to rectification. You have the right to make corrections to your personal data.

Right to withdraw consent. When you have given us consent to process your personal data, you may withdraw said consent at any time.

To exercise any of the abovementioned rights, please contact our customer support team via e-mail indicated in Section 8 below.

 

Please note that in case you are requesting to use the above described rights or any other rights related to our services, on someone elses name (legal representative, close relative of deceased customer etc), we have the right to ask additional information from you to prove the authorization for such request (signed authorization from customer, requestor ID, death certificate etc.). 

 

Such additional information is required to protect our customers’ personal data and financial interests. 

 

8. OTHER IMPORTANT INFORMATION

Newsletter, notifications and direct marketing campaigns

 

With your explicit consent, you may be subject to direct marketing campaigns, we may send you our newsletter or provide you with notifications. You may opt out of the direct marketing campaigns, newsletters and notifications on your account settings. We may also provide you with news, 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 unless you have opted not to receive such information.

 

Please note that email marketing messages include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you). Clicking on the link in an email will opt you out of further messages of that category. You can use the Account Settings page to exercise choices about all categories of email and push marketing communication.

 

Dispute resolution

 

If you have questions, please feel free to contact us at [email protected]

 

Disputes relating to the processing of personal data are settled through our Complaint Procedure.

 

We may amend or modify this Privacy Policy from time to time to reflect changes in the way we process personal data. In case of material changes, we will notify you, as required under applicable laws.

 

Age limitations

 

We do not knowingly collect any information from individuals under 18 years of age. If we discover a user of being younger than 18 years old we will require the user to close their account and we will take steps to delete any collected information as soon as possible.

 

 

The above summary of how we collect, use and share Personal Information describes our practices currently and for the 12 months preceding the effective date of this Privacy Policy.

 

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