Coinperday appreciates the opportunity to help you meet your financial needs. We are committed to safeguarding the privacy and confidentiality of the Personal Information you have entrusted to us. It is important for you to understand what Personal Information we will collect, how we will use it, and who may access it.
This Privacy Policy applies to the operations of Coinperday, its subsidiaries and certain other affiliated entities. Regional and local policies supersede this Privacy Policy. Please see existing privacy policy for Coinperday’s operations in the USA, Australia, Hong Kong and Israel.
If you are an existing customer of ours, further details about how we use your Personal Information is set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided when we collect Personal Information from you.
Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Information to such third party websites.
This Privacy Policy outlines our commitment to you.
All + symbols can be clicked to provide further detail.
We have strict policies and procedures governing how we deal with your Personal Information. Each and every one of our employees is responsible for respecting and protecting the Personal Information to which the employee has access.
Our Group Data Protection Officer oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors on privacy matters. Please see Contact Us for information on how to reach our Group Data Protection Officer.
We only collect the Personal Information that we determine we need for the purposes set out in 3. Purposes for which we use your personal information.
For example, we may collect:When we collect your Personal Information, we may use or disclose it for the following purposes. Below each purpose we note the “legal ground” that allows that use of your Personal Information. An explanation of the scope of the “legal grounds” can be found at here.
To provide and manage products and services you have requested
To verify your identity, protect against fraud and manage risk
To comply with legal or regulatory requirements, or as otherwise permitted by law
To monitor certain activities
To inform you of changes
To communicate with you regarding products and services that may be of interest
To understand our customers and to develop and tailor our products and services
To reorganise or make changes to our business
To communicate effectively with you and conduct our business
Most of our processing is permitted by “legal grounds” other than consent (see section 3 above and here). In relation to Direct Marketing,where we are required to do so, we will obtain your consent before using your Personal Information for this purpose. If you prefer not to receive our Direct Marketing communications, you can have your name deleted from our Direct Marketing and/or shared information lists. If you want to change your privacy preferences, see Contact Us
In relation to processing of criminal convictions data and politically exposed person data for the purposes of complying with our anti-money laundering obligations and to combat fraud we consider that our processing is permitted by the substantial public interest ground (to prevent or detect crime) but to the extent it is not, you give and we rely on your consent to process that type of ;. Personal Information. Although you have a right to withdraw such consent at any time, as we consider the processing to be necessary for us to provide our services its withdrawal (to the extent the processing cannot be justified on substantial public interest grounds) may require us to cease to provide certain services.
We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy.
Sharing outside the Coinperday group: Personal Information may be provided to third parties, including anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organisations, or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts).
Sharing within the Coinperday group: We may share your Personal Information within the Coinperday group, including locations outside of the European Economic Area where we do business, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.
Business sale or reorganisation: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with any accounts, products or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganisation or other change in corporate control.
Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these companies to standards of confidentiality equivalent to ours.
Transfers outside of your country: Your Personal Information may be accessed by staff, suppliers or other persons in, transferred to, and/or stored at, a destination outside your country, including outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in your country/the EEA. We will, in all circumstances, safeguard Personal Information as set out in this Privacy Policy.
Where we transfer Personal Information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Information to these jurisdictions. In countries which have not had these approvals (see the full list here (http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm) we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Please Contact Us if you would like to see a copy of the specific safeguards applied to the export of your Personal Information.
Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When Personal Information is no longer needed, our policy is to either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
We are committed to maintaining the accuracy of your Personal Information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision as described in Contact Us.
We use physical, electronic and procedural safeguards to protect against unauthorised use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of.
If you have any questions in relation to our use of your Personal Information, you should first contact us as per the Contact Us section below. Under certain conditions (in particular where Hedgefundsltd has directed the use of your Personal Information from one of its European subsidiaries), you may have the right to require us to; provide you with further details on the use we make of your information; provide you with a copy of information that you have provided to us;
transmit your data directly to a third party, where technically feasible;
update any inaccuracies in the Personal Information we hold (please see paragraph 7);
delete any Personal Information that we no longer have a lawful ground to use;
where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 4 for marketing);
object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
if you are not satisfied with our use of your Personal Information or our response to any exercise of these rights you have the right to complain to the data protection regulator in the country where the Hedgefundsltd entity with which you deal is established (listed here below under Contact Us).
If you have any questions or concerns about our privacy practices or the privacy of your Personal Information, please let us know.
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