SellBitcoin Platform

Privacy Policy

INTRODUCTION

SellBitcoin LTD. and its affiliates and subsidiaries (“ SellBitcoin”, “ we” or “ us”) are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy (the “ Privacy Policy ”) is to inform you about our privacy practices, including how we collect, use and disclose your personal information. This Privacy Policy applies to our website, mobile applications, digital asset trading platform and related services (collectively, the “ SellBitcoin Services”). By visiting, accessing, or using the SellBitcoin Services, you consent to the policies and practices of this Privacy Policy so please read them carefully. If any policies or practices of this Privacy Policy are unacceptable to you, please do not visit, access, or use the SellBitcoin Services.

WHAT’S IN THIS PRIVACY POLICY?
PRIVACY POLICY AMENDMENTS

Your privacy matters to us so whether you are new to the SellBitcoin Services or a long-time user, please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time. But don’t worry, you can always find the latest version of this Privacy Policy here on this page. Visiting, accessing, or using the SellBitcoin Services following any change to this Privacy Policy is considered to be your acceptance of any such changes. You should, therefore, read this Privacy Policy from time to time. If you do not agree to be bound by this Privacy Policy, you should not visit, access or use the SellBitcoin Services.

PERSONAL INFORMATION WE COLLECT

We do not collect any kinds of information about you, except you have any problem and you have to contact support department. The personal information we collect about you may include the following. In each case, we identify the grounds that we rely on to process your personal information under the General Data Protection Regulation (the “ GDPR”):

  • Account Profile – We are NOT under AML and KYC policies. AML & KYC Policy). Applicable legal grounds: contract performance, consent, legitimate interests (to enable us to perform our obligations and provide our services);
  • Device Information – information that is automatically collected about your device, such as hardware, operating system, browser, etc. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  • Location Information – information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  • Log Information – All this information is erased after you finish your session, we do not store any kind of log. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance;
  • Account Activity – information that is generated by your account activity including, but not limited to, trading activity, order activity, deposits, withdrawals, and account balances. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), legal claims, consent, contract performance;
  • Financial Account Transfer Information – information that you provide to us to facilitate the transfer of fiat currency or Digital Assets (as defined below) into and out of your SellBitcoin account, such as your bank account information and public cryptocurrency wallet address (we do not collect private keys) it will be deleted after a successful exchange procedure. Applicable legal grounds: legitimate interests (to allow us to provide the content and services on the website), consent, contract performance; and

SellBitcoin may also make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (“ Cookies”) on your computer or other devices used to access the SellBitcoin Services. Cookies are small bits of information that are automatically stored on the web browser of your device that can be retrieved by us. The type of information we collect includes, but is not limited to, uniquely identifying visitor information and information related to your usage preferences. We use these technologies to help us recognize you as a user, collect information about your use of the SellBitcoin Services to better customize our services and content for you, and collect information about your computer or other access devices to (i) ensure compliance with our BSA/AML Program (for more information, please read our AML & KYC Policy) We are NOT under the AML and KYC Policy.

HOW WE USE PERSONAL INFORMATION

We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We may use the personal information we collect to:

  • provide you with the SellBitcoin Services, including customer support;
  • optimize and enhance the SellBitcoin Services, including to develop new products, services, features, and functionality;
  • respond to inquiries and other requests;
  • provide you with information that we think may interest you, including in regards to our products and services;
  • monitor the usage of the SellBitcoin Services, including by conducting automated and manual security checks;
  • understand and analyze the usage trends and preferences of our users;
  • create aggregated and anonymized reporting data about the SellBitcoin Services;
  • carry out such purposes for which we may obtain consent from time to time;
HOW WE SHARE PERSONAL INFORMATION

We NOT disclose your personal information to a third party in the event of any potential or completed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business.

PRIVACY OF DIGITAL ASSETS

As used herein, “Digital Asset” means a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as Bitcoin, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Please be aware that Bitcoin, Ether, and other Digital Assets are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public Digital Asset address. We, and any others who can match your public Digital Asset address to other information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, information published on a block chain (such as your Digital Asset and IP address) can be correlated with information that we and others may have. We highly recommend the use of the tor network.

INFORMATION SECURITY

We take your privacy very seriously and have implemented physical, organizational and technological security measures with a view to protecting your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. In particular, we encrypt the SellBitcoin website with SSL; we require two-factor authentication for all user sessions; we periodically review information collection, storage, and processing practices; and we restrict access to your information on a need-to-know basis for our employees, contractors, and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

RETENTION OF PERSONAL INFORMATION

We will NOT use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

RIGHTS REGARDING YOUR PERSONAL INFORMATION

Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, you have the following rights:

  • Access – ask if we are processing information and, if we are, request access to your personal information. This enables you to receive a copy of the personal information we hold and certain other information about you;
  • Correction – request that any incomplete or inaccurate personal information about you that we hold be corrected;
  • Erasure – ask us to delete or remove your personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with legal claims;
  • Restriction – ask us to suspend the processing of your personal information, for example, to establish its accuracy or the reason for processing it;
  • Transfer – request the transfer of certain personal information to another party;
  • Objection – challenge our processing of personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information in certain circumstances;
  • Automated decisions – contest any automated decision made where it has a legal or similar significant effect and ask for it to be reconsidered; and
  • Consent – where we are processing personal information with consent, withdraw your consent.

You also have a right to make a complaint with a data protection supervisory authority, in particular in the Country (as defined below) where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us as set forth in the “Contact Us” section.

THIRD PARTY WEBSITES AND SERVICES

This Privacy Policy applies only to the SellBitcoin Services and does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

CHILDREN’S PRIVACY

The SellBitcoin Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the SellBitcoin Services at any time or in any manner. If we learn that personal information has been collected on the SellBitcoin Services from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided personal information, then you may alert us as set forth in the “Contact Us” section and request that we delete that child’s personal information from our systems.

CONTACT US

For any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer can be reached at contact@sellbitcoin.ltd.

This Privacy Policy was last updated on [15 MAY 2018]