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Privacy Statement

Last updated May 2018

This Policy explains when and why we collect personal information in relation to you, how we use it, the conditions in which we may disclose it to others and how we keep it secure.

Who are We?

We are Santiment GmbH, company number CHE-424.007.779, and with registered address Dammstrasse 16, 6300 Zug, Switzerland (“We”, “Us”, “Our”). We are the data controller of your personal data provided by you on Our website.

What personal data do we collect on you?

We only collect your personal data needed for your registration and creation of a user account on Our website. This includes your name, email address and information on your transactions through your account.

Why do we process your personal data?

We process personal information for specific purposes. We process your personal data provided by you during your registration on Our website to support your user account and provide you the full range of services available on Our website regarding the trading with crypto currencies.

Who else has access to your personal data?

We may disclose your personal information provided by you during your registration on Our website to other third parties. These third parties include:

  • Other companies from Our corporate group, including Our subsidiary in the Republic of Bulgaria. Any transfers within Our corporate group will be made solely on the grounds of concluded within the group data processing agreements;
  • Our suppliers of IT services which deliver, develop, and/or maintain the IT systems used by Us;
  • Our professional advisers such as Our auditors and lawyers;
  • Relevant state authorities to which We have to disclose your personal data to the extent required so by the law applicable to Us;
  • Any other party to whom you authorise Us to disclose your personal data to.

In any event, when disclosing your personal data, We will take reasonable steps to protect your personal information against unauthorised disclosure and will always disclose your personal data based on a valid legal ground to third parties on a need-to-know basis.

We only transfer your personal data outside of the European Economic Area when such transfers are necessary for the provision of Our services. We always put in place adequate legal safeguards when transferring your data as required by the applicable data protection laws.

What are your rights concerning your personal data?

You have the following rights with respect to the personal data that We process for you:

  • the right to request a copy of your personal data which We hold about you;
  • the right to request that We correct any personal data if it is found to be inaccurate or out of date;
  • the right to request your personal data to be erased where it is no longer necessary for Us to retain such data;
  • if processing is based on consent, contract or automated decision mechanisms, the right to request from Us to provide you with the personal data directly obtained from you and, where possible, to transmit such data directly to another data controller (known as the right to data portability),
  • the right to withdraw your consent to the processing at any time,
  • the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction on further processing;
  • the right to lodge a complaint with the supervisory authority. As a company established under the laws of Switzerland, the competent supervisory authority regarding Our compliance with the data protection laws is the Swiss.

Your rights might be subject to certain restrictions imposed by the data protection laws. If your request to exercise any of your rights places Us or any of Our related companies in a breach of the applicable data protection laws or codes of conduct, We may refuse to fulfil your request.

How long will We retain your personal data?

We will retain your personal information while you have an active account on Our website. If you decide to deregister by sending as an email to [email protected], We will without any undue delay delete in a manner that does not allow for recovery of your personal data. If you deregister from Our website, We will no longer be in the position to provide Our services to you.

You can contact Us at any time to withdraw your consent to receive Our marketing materials. If you withdraw your consent, We will immediately seize to send you marketing materials but We will continue to process your personal data necessary for your user account on Our website.

How do We protect your personal data?

We will take reasonable efforts to protect your personal information in Our possession or Our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

While we strive to protect your personal information, we cannot nor retain liability or ensure the security of the information you transmit to Us via the Internet and we urge you to take every precaution to protect your personal data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

Will We change the way We handle your personal data?

We may amend this Policy at any time to reflect any changes We may make in the manner We handle your personal data. We will always reflect in this Policy the date of its latest revision. If We have made any material changes to this Policy, We will always underline them in the way We provide you with information and will, when possible, inform you directly on the amendments.

How can you contact Us?

If you have any questions in respect of the manner in which we process your personal data, let Us know by sending Us an email to [email protected] or by post to Santiment GmbH, Dammstrasse 16, 6300 Zug, Switzerland.

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