2. Collection of information
If you decide to apply to open an account with us and hence become our client there is certain information that we will require from you, in order to be able to do so.
Information will be collected directly from you (in your completed account opening Application Form or other way) or from other persons including, for example, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third authentication service providers and the providers of public registers. This information includes, but is not limited to personal details such as name, address, date of birth, contact details, payment details, including credit card, debit card and bank account details, and other necessary financial information. With the acceptance of this Policy which is an inseparable part of the Coinlager Client Agreement (Terms and Conditions), you acknowledge and accept that your personal data will be collected, stored and processed by the Company according to all the relevant laws and regulations the Company needs to abide with. Your information will be kept encrypted.
We may ask for other personal information voluntarily from time to time and if you choose not to provide the information, we require to fulfil your request for a certain product or service, we may not be able to provide you with the requested product or service. Please note that we keep records of your trading history including:
- products you trade and their performance;
- products we trade on your behalf and their performance;
- historical data about the trades and investments you made including the amount invested;
- your preference for certain types of services and products.
Coinlager may also collect your information regarding your use of our website(s), such as pages visited, frequency, duration of visit and trading activities.
From time to time we may also request further information to help us improve our service to you under our relevant Agreement or comply with Applicable Regulations. The Company will do its best to collect only the information necessary in order to adhere with the relevant laws and regulations and avoid collecting more documentation than necessary.
3. Use of data
The information we collect is primarily intended to facilitate account access and provide smooth functionality of the site and its features. We make use of the information for the below mentioned purposes
- to allow You to open and operate an Account on the Website and/or on the App;
- to enable You to complete exchange and trade transactions on the Website and/or on the App;
- to reply to your queries when You have contacted us;
- to analyse the use of our Website and/or our App;
- to carry out our anti-money laundering (AML) procedures as required by law. These procedures are outlined in our AML Policy;
- as required for other regulatory purposes;
- to provide You with information about products and promotions that may be of interest to you, from ourselves and third parties, although only if You have specifically agreed to receive such information.
- for market research, e.g., surveying the users of our Website and/or our App about their needs and opinions on our services.
4. Retention of data
5. Transfer of data
We may transfer your personal information outside the EEA to other service providers (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of the EEA, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the GDPR.
6. Disclosure of data
Your Personal Information may be disclosed to third parties and/or legal authorities under the following circumstances/conditions:
6.1.1 Disclosure to third parties
We may disclose your Personal Information with third parties including:
- Business partners, suppliers, sub-contractors and other service providers.
- Advertisers and/or advertising networks that require data in order to select and show you relevant advertisements;
- Analytics and/or search engine providers that assist us in the optimization of our site.
All our third party service providers are bound by contract to protect and use our users’ Personal Information only for the purposes listed above, except as otherwise required by law.
6.1.2 Disclosure to legal authorities
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities in the following cases:
- If we believe disclosure is in accordance to any law, regulation or legal procedure.
- If we think disclosure is needed to prevent any harm or financial loss;
- If disclosure is necessary to report certain illegal activity;
- To protect the rights, property or safety of Coinlager.
7. Security of data
We use multiple security measures to ensure confidentiality your Personal Data. We aim to only keep your Personal Data for as long as we need it.
We store your electronic records in secure systems. Access to your Personal Data is permitted only for authorized employees
8. YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
Right to obtain confirmation as to whether or not his or her personal data are being processed (Article15 EU GDPR);
Right to obtain rectification of inaccurate personal data without undue delay (Article 16 EU GDPR);
Right to erase personal data or “right to be forgotten” (Article 17 EU GDPR); please note that in accordance with our obligations under anti-money laundering laws, we are obligated to retain certain personal and transactional data from you for a period of at least 5 years after we have ended our business relationship or you have requested us to erase your personal data.
Right to restrict data processing, in particular when the accuracy of the data is contested (Article 18 EU GDPR);
Right to receive communications as to rectification or erasure of personal data or restriction on processing (Article 19 EU GDPR);
Right to receive personal data in the form that is machine-readable and ready for transmission to another controller (Article 20 EU GDPR);
Right to object data processing (Article 21 EU GDPR);
Right not to be subject to a decision based solely on automated processing (Article 22 EU GDPR).
9. ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT
We respect your privacy rights and therefore you may contact us at any time and request:
- to access, delete, change or update any Personal Information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted); or
- that we will cease any further use of your personal information (for example, you may ask that we will stop using or sharing your personal information with third parties) or that we shall remove your personal information (subject to any other legal obligation that may require us to keep the information).
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. If you wish to raise a complaint on how we have handled your personal information, please contact us directly at [email protected]
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.
10. Service providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
The User may block, delete, or disable these technologies if his/her web-browser or device allows this.
- Recognize you as a Coinlager user;
- Customize the content you see;
- Track the effectiveness of affiliate or marketing campaigns;
- Collect basic information about your computer, device, and browser in order to prevent security;
- Identify breaches and improve functionality of the website
We use both “session” and “persistent” cookies in order to effectively achieve the above results. “Session” cookies are used to improve the website function within a single session, “persistent” cookies stay on your computer after your logout in order to remember your preferences next time you visit.
12. Links to other sites
Although we are not responsible for the content and activities of such third parties, we do seek to protect the integrity of our trading platform, and would thus welcome your feedback regarding such third parties if you have any concerns you wish to share with us.
13. Children’s privacy
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
15. Contact us