This privacy policy ("Policy") informs you of your choices and our practices in relation to your Personal Information (as defined below). For the purposes of this Policy "we", "us", "our" and the “Company” refers to BitSafe Sentinel LLC, registration number: 3276 with its office located at Beachmont, Kingstown, Saint Vincent and the Grenadines.
This Policy explains areas of our Platform and Services that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights.
For the purpose of this Policy, "Personal Information" means any information relating to an identified or identifiable individual. This also includes information relating to your use of our Platform and Services. By accessing or registering on the Platform you accept our rules and policies which set out how we handle your Personal Information, and you understand we may collect, process, use and store your Personal Information as described in this Policy. If you do not agree with this Policy, you should not proceed to access the Platform or use our Services.
This Policy does not apply to information that you may submit to third-party websites or mobile applications that may link to the Platform or be linked to on the Platform. We are not responsible for the actions or privacy practices of third-party websites and applications. Please consult those websites and applications directly to understand their privacy practices.
As this Policy constitutes an integral part of the Terms & Conditions, capitalized terms used in this Policy have the same meanings as those defined in Terms & Conditions.
We are committed to protecting the privacy and security of Personal Information entrusted to us by Users. In order to ensure transparency and compliance with applicable data protection laws and regulations, we adhere to the following principles of Personal Information processing:
It is important to note that these principles guide our approach to Personal Information processing, and we continuously review and update our practices to ensure ongoing compliance with evolving legal and regulatory requirements.
We may collect and use the following Information about you.
Information you provide to us. We receive and store information provided to us or given to us in any other way, including your: full name, mailing address, phone number, email address, photo, date of birth, place of living, registration information, social media and messaging platform, optional biographic and demographic information, information for Wallets you connect, survey responses, and any other information that you provide. This includes information that you share with us on third party websites and platforms. This information is collected and used for the purpose of provision of Services, performance of contractual duties under the Terms and compliance with our legal obligations.
Information collected via our customer support channels, for example, when you contact us via email, you may provide us with your full name, email and any information you choose to provide to allow us to assist you. This information is collected and used for the purpose of assisting with your reason for contact.
Information we automatically collect or is generated about you when you access the Platform. This information is collected and used for the purpose of enhancing and personalizing your experience.
- Identifiers, such as IP address, device and app ID, unique ID, location data and device information (such as model, brand and operating system).
- Cookies: we use cookies and other similar technologies (e.g. web beacons, log files, and scripts) ("Cookies") ensure the functionality of the Platform with your device. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all Cookies or instruct the device or web browser to provide notice at the time of installation of Cookies or refuse to accept all Cookies by adjusting the relevant Cookie retention function in your device. However, in the event of your refusal to install Cookies, the Platform may be unable to operate as designed. For more information please read Cookie Policy.
- Information regarding your interaction with the Platform, such as date and time stamps of events, statistics on your page views, referral URL, ad data, transaction history, and your web log information.
Information received from third parties for the purpose of Services provision and improving the Platform.
- Information from social media. When you interact with the Platform using social media and messaging platforms we may collect the personal information that you make available to us, including your account ID, username, and other information included in your posts. If you choose to log into your Account with or through a social networking service, we and that service may share certain information about you and your activities. When you give us permission, we may also collect information from your social media account on your behalf.
- Analytics information. We integrate certain analytic software as third party analytics providers. They provide reports that help us optimize our features. This information may include user activity but is not identifiable information.
We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
WHY DO WE COLLECT YOUR PERSONAL INFORMATION
We collect and use your Personal Information in the following circumstances.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Some examples of purposes that either constitute a legitimate interest or should be regarded as a legitimate interest are: fraud prevention, network and information security, and indicating possible criminal acts or threats to public security. Some processing is necessary because it is in our or a third party’s legitimate interests, such as those of visitors, members, or partners.
Where we need to perform the contract, we are about to enter into or have entered into with you. More in particular, we will use Information to perform our contractual obligation towards you to allow you access to the Platform. If you reach out to us for support, we will use your Information to respond and resolve your queries and complaints, facilitate support, as our contractual obligation towards you.
Where we need to defend the Company against legal claims or disputes, enforce our Terms and comply with our legal obligations. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.
Where we got your explicit consent. By registering with the Platform, the User consents to the processing of his/her Personal Information in accordance with the provisions set forth herein. Such information may be used to serve the User with targeted advertisements, marketing purposes, allowing to identify the User and other cases.
We may share your Personal Information with vendors and service providers, we rely on for the provision of the service. For example:
If you access the Platform through a third-party platform (“Third Party Services”), you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the Platform) in accordance with their own terms and privacy policies. The privacy practices described in this Policy do not apply to Third Party Services. Any links to Third Party Services do not imply that we endorse or have reviewed the Third Party Services.
Your Information will be processed by our employees and service providers on servers, located in the European Union (EU).
Your Personal Information may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Your consent to this Policy constitutes your agreement to that transfer. The Company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Information will take place to an organization or a country unless there is an adequate level of data protection in place.
If you are an EU, European Economic Area (EEA) or UK resident - your Personal Information may be processed by recipients outside of the EU, EEA or UK. In this event, we will ensure that the recipient of your personal information offers an adequate level of protection by entering into Standard Contractual Clauses for the transfer of data as approved by the European Commission (Art. 46 General Data Protection regulation, GDPR ) and by putting in place other appropriate safeguards in compliance with the GDPR and UK GDPR. This way, if we transfer personal data collected from individuals located within the EU, EEA or UK to a third party acting as a data processor, such a third party agent processes your Personal Data in a manner consistent with the applicable legislation, namely GDPR.
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy and as permitted by Applicable Law. If you withdraw your consent for the processing of your Personal Information and we have no other legal basis for retaining it, we will promptly delete your data. Termination of use of the Platform by deleting Account is equivalent to withdrawal of consent for the processing of Personal Information.
However, we will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
When Personal Information is no longer necessary for the purposes for which it was collected or processed, we will take appropriate steps to delete or anonymize the data. These steps may include removal from active databases and systems, erasure of electronic records, shredding of physical documents, discontinuation of data processing activities related to that data.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. These rights are:
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Services without some necessary information.
For Brazilian residents, please refer to Addendum 1 – Brazil Privacy Rights.
The Company works hard to protect its Users from unauthorized access to or alteration, disclosure or destruction of their Personal Information. Yet, as any other technology companies, although the Company takes steps to secure Users’ information, it could not be promised or guaranteed, that unauthorized access, hacking, data loss, or other breaches will never occur.
The Company reserves the right to suspend the Account without notice if there is a reasonable suspicion of breach of security or unauthorized access to such an Account. If you believe that your Account or information is no longer secure, please notify The Company immediately by sending a message to [email protected].
The User should take reasonable steps in order to keep his/her Personal Information (including the account’s password) safe. It is recommended that the User does not share the Account's password with anyone.
We may update our Policy from time to time. The most current version of these Policy will be posted onto the Platform and you may be invited to review and accept the revised Policy in order to continue accessing the Platform and using the Services. We suggest all users regularly check the Policy on the Platform. By continuing accessing the Platform and using the Services you will be deemed to have accepted the Policy as varied from time to time.
If you have any questions about this Policy or requests please contact us by email: [email protected].
The terms of this Addendum apply to residents of Brazil under the Lei Geral de Proteção de Dados (Lei nº 13.709, de 14 de agosto de 2018) and its implementing regulations, as amended or superseded from time to time (“LGPD”). For the purposes of this Addendum 1, Personal Information has the meaning as defined in the LGPD.
Categories of Personal Information collected and processed
To find out what categories of your Personal Information are collected and processed, see “Personal Information We Collect and Use” in the main portion of the Privacy Policy.
To find out how we process and use your Personal Information, including on what grounds, see correspondent sections in the main portion of the Privacy Policy.
Your rights under the LGPD
The LGPD provides residents of Brazil with certain legal rights; these rights are not absolute and are subject to exemptions. In particular, you have the right to:
• Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
• Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
• Obtain information on the possibility of refusing consent and the consequences of doing so.
• Obtain information about the third parties with whom we share your personal information.
• Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
• Revoke your consent at any time.
• Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.
To exercise your rights, please email us at [email protected]
Subject should say ‘I have a data related question connected to my account’
• Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.
• Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defense of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case.
• Note that where the Information is held by a third party data controller, such as a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your Personal Information is erased.
• Objection and withdrawal of consent. You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests (see above under How we use your personal information). You may exercise this right as follows:
- To stop receiving personalized advertising: please withdraw your consent in the in-app Settings. You can also find more information in our Cookie Policy.
- To stop our cookies being placed: please refer to our Cookie Policy.
• Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
Correction:You have the right to correct any Information held about you that is inaccurate.
• Restriction: You have a right in certain circumstances to stop us processing Information other than for storage purposes.