We at Cryptohub Ltd., (the "Company", "We", "Us" or "Our"), are committed to securing your Personal Data and your privacy.
In this Policy, you ("You", "Your" or "User") may find information about the types of information that We collect about users of Coinscan, when We collect it, how We use it, share it with third parties, maintain it, etc.
We will uphold the following principles:
1. The Scope?
This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, process it, etc.
In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
You must be at least 18 years old to access and/or use Our Services and/or register with Us. We do not knowingly collect Personal Data about any person under the age of 13.
2. Data Controller
The Company is the data controller in respect of the Personal Data provided to the Company by You.
3. When Do We Collect Personal Data About You?
We collect Personal Data about You whenever You use Our Website or Our Services and/or contact Us.
In some instances, You will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about You by examining and analyzing Your use of Our Services and/or Our service channels.
4. No Obligation To Provide Personal Data To The Company And Its Implications
You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the products or services You requested Us to provide You, will prevent Your use of the Platform and the Services or a part thereof, and/or will cause the malfunctioning of Our Services.
5. What Personal Data About You Do We Collect?
Personal Data We collect upon registration with Premium account. Upon creation of a Premium account by linking your non-custodial wallet ("Wallet") with Coinscan, You will provide Us Your wallet ID and information regarding the contents of Your Wallet, including the amount of SCAN tokens that You hold in Your Wallet.
Personal Data We collect when You subscribe to Our Newsletter. Upon subscribing to our Newsletter and allowing Us to send You Marketing materials You provide Us with the following information: email address.
Personal Data We collect when you use or access Coinscan. Whenever You access to or use Coinscan, We collect from You by way of observation of Your use thereof certain usage information. This information includes online activity log, traffic information (including, without limitation, IP address or device ID, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used and information regarding the device you used.
Personal Data We receive from You: any Personal Data You provide to Us of Your own free will when contacting Us. We may record and/or document in writing your calls.
6. The Purposes Of The Processing Of Personal Data And Their Legal Basis
The Company processes Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
The Company will not process Personal Data about You unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about You are as follows:
Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, when You subscribe to Our Newsletter for the purpose of sending marketing materials to You. Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw your consent for the purposes for which you provided your consent.. Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
Processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract. This refers to all the information required for us to provide you with the Services and grant you access thereto.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.
The following list outlines the purposes for which We may process Personal Data about You and the legal basis for any such processing:
7. Your Right To Object To The Processing of Personal Data About You For Direct Marketing Purposes
When You subscribe to our Newsletter The Company provides You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Ours or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests. For this purpose, We use Personal Data automated analysis techniques that provide Us with analysis and conclusions concerning You in various aspects, including profiling.
Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials are tailored to offer You products and services which We think may be of more interest to You.
Where Personal Data about You is processed for direct marketing purposes, You shall have the right to object at any time to such processing for this purpose, including profiling to the extent that it is related to such direct marketing, by clicking the unsubscribe button at the bottom of the email in which case We shall cease to process Personal Data about You for such direct marketing purposes.
Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our Services or for other legitimate non-marketing reasons.
9. Transfer Of Personal Data To Third Parties
The Company may also share Personal Data about You with third parties that provide Us with the following services:
Storage and hosting providers, including cloud computing services;
IP address information;
Analysis of user experience;
CRM data management;
Accounting and legal services; and
Research, analytical, technical, and diagnostic services.
The Company may also share Personal Data about You with its related entities and business partners, which provide it with resources that enable the Company to enrich and improve the level of services and products it provides to its users.
The Company may share Personal Data about You with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims.
In addition, We may disclose Personal Data about You to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the Company is a part, or in the event of any similar transaction (including the sale of assets of the Company and/or of any company within the group of companies of which the Company is a part), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part.
In the preceding twelve (12) months, We have not sold any Personal Data.
Web Tracking Information: We, and third party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites You visited before and after You visited the Coinscan, the type of browser You are using, Your Internet Protocol (IP) address, what pages in the Service You visit and what links You clicked on, and whether You opened email communications we send to You. In order to collect Web Tracking Information and to make Your use of the Service more efficient, we may store cookies on Your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and our Contractors may also do so.
We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to You. You may be able to modify Your browser settings to alter which web tracking technologies are permitted when You use the Service, but this may affect the performance of the Service. .
Types of cookies:
The cookies We may use have been classified according to their functionality, as follows:
The Cookies incorporated in our Website are as follows:
Blocking and removal of cookies
You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:
Please note, however, that if You do so, some or all of the Platform’s features and functionalities might not perform as intended.
We use mobile analytics software to allow us to better understand the functionality of Our website on Your device. This software may record non personal information such as how often You use the Platform, the events that occur within the Platform, aggregated usage, performance data, and where the Platform was downloaded from.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
10. Retention Of Personal Data About You
The Company shall retain Personal Data about You for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us.
In order to ensure that Personal Data about You is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.
11. Transfers Of Personal Data To A Third Country Or An International Organization
Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
If you are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:
The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR");
The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.
You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: [email protected].
12. Protection Of Personal Data About You
We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed. We do not guarantee however, that it will not be subject to a security event.
We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about You to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about You by such third parties.
Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to Us.
The Services may provide links to websites and/or applications of third parties. The Company does not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.
Whenever You access such third parties' websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.
14. Your Rights In Respect Of The Personal Data About You
Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict your consent to certain processing of your Personal Data.
If you are an EEA resident, please read this section below:
You are entitled to the following rights in respect of the Personal Data about You. To exercise such rights, you may send a request to exercise Your rights to the following email address: [email protected].
Right of access
You have the right to receive from the Company confirmation as to whether or not Personal Data about You is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about You or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from You, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.
The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by You. If you make the request by electronic means, and unless otherwise requested by You, the information shall be provided in a commonly used electronic form.
The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.
Right to rectification
You have the right to obtain from the Company the rectification of inaccurate Personal Data about You. Taking into account the purposes of the processing, You have the right for incomplete Personal Data about You to be completed, including by means of providing a supplementary statement.
Right to erasure
You have the right to obtain from the Company the erasure of Personal Data about You if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) You withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) You object at any time, on grounds relating to your particular situation, to the processing of Personal Data about You that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about You for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about You has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.
This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.
Right of restriction of processing
You have the right to obtain from the Company the restriction of processing of Personal Data about You if one of the following applies: (a) the accuracy of the Personal Data is contested by You, for a period enabling the Company to verify the accuracy of the Personal Data about You; (b) the processing is unlawful and you oppose the erasure of the Personal Data about You and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about You for the purposes of processing, but the Personal Data is required by You for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about You is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about You is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
If the processing of Personal Data about You has been restricted following Your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to data portability
You have the right to receive the Personal Data about You, which you have provided to the Company, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on Your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.
In exercising your right to data portability, You have the right for the Personal Data about You to be transmitted directly from the Company to another controller, where technically feasible. The exercise of Your right to data portability is without prejudice to Your and the Company’s rights under Your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.
Right to object
You have the right to object at any time, on grounds relating to Your particular situation, to the processing of Personal Data about You that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about You, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
You have the right to object at any time to the processing of Personal Data about You for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
Right to withdraw consent
You may withdraw Your consent provided to Us for the purpose of processing Personal Data about You at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
Your rights in respect of Personal Data about You as outlined in this section 14 may be restricted by European Union or Member State law to which the Company is subject.
We shall provide You with the information requested according to Your rights outlined in this section 14 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.
The information requested according to your rights outlined in this section 14 shall be provided free of charge, unless stated otherwise in this section 14. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.
The Company may require You to provide additional information necessary to confirm Your identity in order to fulfill your request according to your rights outlined in this section 14, if We have reasonable doubts concerning the identity of the natural person making the request.
If you reside in California, please read below with respect to the California Consumer Privacy Act (CCPA) rights you have:
In order to exercise your CCPA right, please contact us using the following details: [email protected].Please note that We may need to receive Personal Data from You in order to verify Your identity prior to allowing you to exercise Your rights.
15. Changes To This Policy
We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify You of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform You about such amendments via means of communication We believe are reasonably appropriate to inform You of such amendments and by publishing a notice about such amendments on the Platform. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page in the Services.