Privacy Policy

Your privacy is important to us. Last updated: August 28, 2020

Welcome to Coinclustr

Welcome to Coinclustr

At Coinclustr (collectively “Coinclustr”, “we” and “us”) we respect your privacy. Coinclustr’s services include merchant processing services, online payment transactions, websites, mobile applications, products, and any other features, technologies or functionalities, including customer support offered by us. 

Scope

This privacy policy applies only to the actions of Coinclustr and users with respect to coinclustr.com. It does not extend to any websites that can be accessed from this site including, but not limited to, any links we may provide to social media websites. 

This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

For the purposes of the applicable Data Protection Laws, Coinclustr is the “data controller”. The means that Coinclustr determines the purposes for which and the manner in which your data is processed. 

This policy describes the types of personal data we collect through our payment products and services and via our online presence, how we use personal data, with whom we share it, your rights and choices and how you can contact us about privacy practices. 

What information do we collect?

Coinclustr obtains Personal and Technical Data about you to provide our services and to manage our site. Personal Data is any information that relates to an identified or identifiable individual. Technical Data is any information that relates to online identifies and usage. The information we collect depends on the type of user. 

“You” may be a visitor to our sites, merchants who sign up for our services, shoppers of merchants, Coinclustr wallet holders, Coinclustr app user and/or a payee.

Personal Data

At Coinclustr wemay collect the followingpersonal data from you whenyou interact with usthrough our sites and services:

  • Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
  • Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.(e.g. to verify your identity)
  • Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Employment Information: Office location, job title, and/or description of role.
  • Correspondence: Survey responses, information provided to our support team or user research team.

Please note that we may not be able to serve you as effectively or offer you our services if you choose not to share certain information with us. 

Technical Data

At Coinclustr wemay collect the followingtechnical data from you whenyou interact with usthrough our sites and services:

  • Online identifiers – geo tracking, IP address, the type of browser, devices and operating systems you use, identifiers associated with the device(s) you use to access our sites.
  • Usage data - the pages you visit and the features you use, access dates and times, navigation to and from website and information regarding your internet service provider. 

We may also use identifiers to recognise you when you access our sites via an external link, such as a link appearing on a third party site. For fraud prevention, we may also collect information about a visitor’s computer or other access devices, this information may be collected automatically using cookies or other similar technologies. (see Cookie Policy)

How we collect data

We collect Data in the following ways:

  1. Data if given to us by you

Any information you provide to us that is not required it is voluntary.

Coinclustr will collect your data in a number of ways, for example:

  • When you contact us through the website, by telephone, post, e-mail or through any other means
  • When you register an account with us 
  • When you complete surveys that we use for research purposes (no obligation)
  • When you make payments to us, through this website or otherwise
  • When you elect to receive marketing communications from us
  • When you use of services

in each case, in accordance with this privacy policy

  1. Data is collected automatically. 

We may also collect information automatically from your devices. The extent to which we collect data automatically will be permitted under the applicable law, we may collect certain types of information automatically to help us address customer support issues, improve performance of our Sites and applications, provide streamline personalised experiences and protect your account from fraud.

To the extent that you access the site, we will collect your data automatically, for example:

  • We automatically collect some information about your visit to the site. This information helps us to make improvements to website content and navigation, and includes online identifiers and usage information (see above)
  • We will collect you data automatically via cookies or other similar technologies, in line with the cookies settings on your browser. (see Cookie Policy)

in each case, in accordance with this privacy policy

Use of Data

Any or all of the above data may be required by us from time to time in order to provide you with a protected, secure, proficient, and tailored experience. We generally use personal information to create, develop, operate, deliver, and improve our services, content and advertising; and for loss prevention and anti-fraud purposes.

Specifically, data may be used by us for the following reasons:

  1. For legal and regulatory compliance - At Coinclustr the majority of our services are upheld by legal and regulatory compliance that require us to collect, use, and store your personal information in appropriate ways. At times this may include collection and storage of your photo identification. At Coinclustr we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will have to close your account.
  2. Enforce user and other agreement - Coinclustr handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services
  3. Anti-fraud and Security - We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss. We also process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. 
  4. Services and Communications - We process your personal information to provide the Services to you. We cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services. We also send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes. We process your personal information when you contact us to resolve any queries.
  5. Marketing and Advertising –For the delivery of direct marketing to you via email, we’ll need your consent, via an opt-in. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law. Based on your communication preferences, we may send you marketing communications. When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Coinclustr Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you.We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors. 
  6. Quality Assurance and Improvement - We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services. We also process your personal information to quality assure Coinclustr’s services to customise, measure, and improve services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.
  7. For any purpose - We may disclose your personal information for any purpose you consent to.

in each case, in accordance with this privacy policy

We may use your data for the above purposes if we deem it necessary to do so for our legitimate interest. If you are not satisfied with this, you have the right to object in certain circumstances (see “Your Rights” below).

When you register with us and set up an account to receive and use our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract. 

We may use you data to show you Coinclustr adverts and other content on other sites. If you do not want us to use you data to show you Coinclustr adverts and other content on other websites, please turn off relevant cookies (see cookie policy).

Who we share data with

We may share you data with the following groups of people for the following reasons:

  • With third party identity verification services in order to prevent fraud. 
  • With financial institutions with which we partner to process payments you have authorised.
  • With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. 
  • With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
  • With companies or other entities that purchase Coinclustr assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
  • With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
  • With law enforcement, officials, or other third parties 

Keeping Data Secure

We will use technical and organisational measures to safeguard you data, for example:

  • Password controlled accounts 
  • Data stored on secure servers
  • Payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology)

We are certified by SOC 2 and ISO 27001. This family of standards helps us manage your data and keep it secure. 

Technical and organisation measures include measure to deal with any suspected data breach. If you suspect and misuse or loss or unauthorised access to your data, please let us know immediately. See contact detail below. 

Data retention and security

Unless a longer retention period is required by law, we will only hold your data on our systems for the period necessary to fulfil the purposed outlined in this privacy policy or until you request that the data be deleted. 

Even if we delete you data, it may persist on backup or archival media for legal, tax or regulatory purposes. 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to any of our websites; any transmission is at your own risk. 

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. When possible, encryption is used, both in transit and storage. Access controls within the organisation limit who may access information.

If you register a Coinclustr Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a Coinclustr website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.

Your rights

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Coinclustr has absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

You have the following rights in relation to your data:

  1. Right to access - You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
  2. Right to correct - Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by Coinclustrthat is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
  3. Right to erase - Erasure. You may request to erase your personal information, subject to applicable law. If you close your CoinclustrAccount, we will mark your account in our database as "Closed," but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Coinclustrlegal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
  4. Right to Withdraw. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Coinclustr processing based on consent before your withdrawal.
  5. Right to Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  6. Automated individual decision-making, including profiling. Coinclustrrelies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

It is important that the data we about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it. 

Transfers outside of the EEA (European Economic Area)

Data which we collect from you may be stored and processed in and transferred to countries outside of the EEA. For example, this could occur if our servers are located in a country outside of the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA. 

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data

To ensure that you data receives and adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share data with. This ensures your data is treated by those third parties in a way that is consistent with the data protection laws. 

Changes to business ownership

Coinclustr may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Coinclustr. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to us. 

We may also disclose data to a perspective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected. 

Coinclustr reserves the right to change this privacy policy as we deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the site and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations. 

 

Contact us

If you have any questions or complaints about this Privacy Policy, please contact us electronically or call:

Privacy@coinclustr.com

 

 

 

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