SpectroCoin Pro Privacy Policy

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Valid from: 2021-03-23

SpectroCoin Pro Privacy Policy

The purpose of this Privacy Policy (hereinafter the “Policy”) is to inform you about ways in which we collect, use and otherwise process your personal data provided to us or collected by us in any other manner. This Policy is prepared in line with the General Data Protection Regulation (EU) 2016/679 and aims to ensure fair and transparent collection and use of your personal data.

The information below includes information on purposes and scope of processing personal data, description of your rights as a data subject, personal data storage terms, provision of data to recipients, and other conditions for fair processing of your personal data. Please kindly devote some of your time to look through the Policy and in case of any query, do not hesitate to contact us. In the future there may be changes in this Policy, therefore, we encourage you to periodically review it.

The data controller responsible for processing of your personal data is a service provider (hereinafter “SpectroCoin Pro company” or “we”), defined in the General Terms and Conditions of SpectroCoin Pro service (hereinafter “SpectroCoin Pro services” or “exchange services”), which are accessible via exchange.spectrocoin.com or main platform spectrocoin.com (hereinafter the “Site”).

Should you like to exercise your data subject’s rights or have other questions regarding the processing of your personal data, contact us by following contact details: [email protected] ; +372 683 8000; BNK Systems Ltd, company code 1999191, Craigmuir Chambers, Road Town, Tortola, VG1110, the British Virgin Islands.

  1. Definitions

    1. Personal data means any information relating to you which you yourself have provided or which we obtain from other sources and which enable to identify you. It may be your name, surname, personal ID number, contact information, information relating to agreements you have concluded with us, etc.;
    2. Data subject (hereinafter “you”) means a natural person (customer, his or her representative, etc.) whose personal data we obtain and use further;
    3. Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  2. Purposes and scope of processing personal data

    1. Your personal data received from you during the process of registration for SpectroCoin Pro services and later collected from other sources shall be processed for the purposes of
      1. compliance with anti-money laundering and prevention of terrorist financing and other applicable legal regulation,
      2. provision of exchange services,
      3. performance of support services,
      4. quality assurance and
      5. direct marketing.
    2. During the registration for the SpectroCoin Pro services natural persons shall be asked to provide their name, surname, country, phone number, email address, date of birth, address, city, post code, a copy of identification document, proof of address and other information which may be necessary in order to provide the preferred services. All the listed data shall be used for the purposes of provision of exchange services and compliance with anti-money laundering and prevention of terrorist financing and other applicable legal regulation.
    3. During the provision of the SpectroCoin Pro services we may process information regarding:
      1. SpectroCoin Pro wallets, such as your active wallets, operations in those wallets (including, but not limited to exchange, deposit, withdrawal, etc.), operation’s amount, type of cryptocurrency used in the operation, cryptocurrency wallet address (including those used for deposit or withdrawal), date and time, order number, and any other data related with the execution of SpectroCoin Pro services;
      2. history data, such as your experience using the SpectroCoin Pro services and the register of all your actions performed on the website or services used (e.g. operations, such as exchange, deposit, withdrawal, balances, log-ins and log-outs, information about operating system from which you log-in to or log-out from the website, information about your internet provider, your used IP addresses, your location data, reset passwords, etc.);
    4. In order to provide customer support services and ensure the quality of SpectroCoin Pro services, in relation with categories of personal data indicated above, we may also process our communication with you data, such as date, time, correspondence, video and voice calls, chats;
    5. In case of compliance with anti-money laundering and prevention of terrorist financing and other applicable legal regulation purpose or due to registration or provision of access rights, we might receive your personal data from other services providers, you have relations with on the SpectroCoin platform, available at www.spectrocoin.com. Following data might be received – name, surname, contact details, data of ID card or passport, transaction information (amounts, account numbers, etc.), login information, etc.
    6. In order to be able to send direct marketing offerings, we shall use your email address or phone number . To provide direct marketing offerings that answer your needs we, besides the above indicated data, we may also collect and use your IP address and the date when you gave a consent and or you have renewed it (and later on also the day of termination of services or expiration/revocation date of the consent). You have a right not to consent to direct marketing or, if you have already agreed to such processing, to revoke your present consent at any time by clicking on the withdrawal link provided in the received newsletters or by sending us a request at [email protected] .
    7. In relation with the processing of your personal data for the purposes indicated in Article 2.1. of the Policy, we may also process information related to your electronic device, such as IP address(es); time zone; browser information; electronic device's operating system information; location data (country (code), city), internet service provider (ISP); selected language).
    8. Information with regard to use of cookies is provided in the Cookie Policy.
  3. Legal basis of processing personal data

    1. We process your personal data if you intend to conclude or have concluded an agreement with us (e.g. registered for SpectroCoin Pro services, use exchange services) or processing of personal data is possible on the basis of legislative acts (e.g. anti-money laundering and prevention of terrorist financing regulation obliges us to identify you and assess your eligibility to become our customer before starting to provide you with our services).
    2. If you fail to provide us with your personal data that is necessary for the conclusion and/or performance of an agreement (e.g. registration for SpectroCoin Pro services) or provision whereof is required by law or under the agreement, we will be unable to provide our services to you.
    3. Direct marketing shall be performed on the basis of your consent or laws allowing to send direct marketing by e-mail without prior consent.
    4. Decision regarding your eligibility to become our customer can be fully or partly automated. For example, if a person registers with IP address of excluded country or if already registered email address is used, registration can be automatically rejected. Partly automated decisions can also be made during anti-money laundering procedures, e.g. checking your data within special databases.
  4. Terms of personal data storage

    1. We process your personal data no longer than it is required for the purposes for which they have been collected or for a period as provided by legislation, e.g. we process data collected from rendering services till you continue using our services and store it for up to10 year period after you cease using them.
    2. We might use your personal data for the purpose of direct marketing throughout the term your consent is valid (up to 3 years, if not renewed) and after the day of termination of contractual relationship or expiration date/ revocation of the consent we store it for additional period of time due to possible claims (for example, possible prescription period for claims can be 3 years) although newsletters will not be sent during this period. This time limit may be additionally extended if a competent authority conducts an investigation and the further data processing is necessary to execute it or if the we feel necessary to maintain data longer, especially, due to the nature of its business or business relationship (transactions).
    3. In case the contractual relationship between you and the SpectroCoin Pro company has not been established (e.g. you decided not to finish application or verification procedure due to your own personal reasons) your personal data will be stored for up to 3 years since the last contact with you or action from your side.
  5. Transfer of personal data to recipients

    1. We can transfer or provide access to your personal data to:
      • IT, server, mail, archiving, marketing, accounting, security and performance service providers;
      • payment services providers, as well as intermediary services providers;
      • other services providers, you have relations with on the SpectroCoin platform, available at www.spectrocoin.com or other our domains;
      • lawyers, consultants, auditors;
      • law enforcement and supervisory authorities, courts and other dispute settlement bodies;
      • potential or existing successors of our business or part thereof, or their authorized consultants or individuals.
      • to other parties if we have to comply with a legal obligation to which we are a subject or if such requested personal data is necessary for the concrete data receiver to carry out a particular inquiry in the general interest, in accordance with the law, or if the data requesting party has a legitimate interest to get such information
  6. Data subject’s rights

    1. You have the following data subject’s rights:
      • the right to request that we provide you access to your personal data;
      • the right to request rectification of incorrect, inaccurate or incomplete data;
      • the right to limit the processing of your personal data until, at your request, the lawfulness of your personal data processing is checked;
      • the right to request erasure of personal data;
      • the right to disagree with personal data processing for direct marketing purposes, including profiling, and when personal data are processed aiming at our legitimate interests;
      • the right to request to transfer your personal data to another data controller or provide directly in a format that is convenient for you (applicable to the personal data, which you have provided yourself and which are processed by automated means on consent basis or on agreement conclusion and performance basis);
      • the right to withdraw your consent without any impact on the use of your personal data that was performed before the withdrawal of the consent;
      • the right to lodge a complaint to data protection authority.
    2. In order to implement your data subject’s rights, we will have to identify you. Without identifying you, we will not know if the person contacting this is indeed the same person whose personal information we process, and therefore we will not be able to exercise your rights.
    3. We will reply to your request within a period of not more than one month since the day of receipt of the request. In exceptional circumstances, which require additional time, we will, by giving you a relevant notice, have the right to extend the deadline for the submission of the requested data or for the consideration of claims set out in the request for two more months.
  7. Principles of personal data protection that we abide

    1. By collecting and using the personal data that you have entrusted to us, and received from other sources, we adhere to the following principles:
      • your personal data is processed in a lawful, fair and transparent manner (the principle of legality, integrity and transparency);
      • your personal data is collected for specified, clearly defined and for legitimate purposes, and not further processed in a way incompatible with those purposes (the purpose limitation principle);
      • your personal data is adequate, appropriate and necessary only for the purposes for which they are processed (the data reduction principle);
      • the processed personal data is accurate and updated, if necessary (principle of accuracy);
      • your personal data is stored in such a form that you can be identified no longer than is necessary for the purposes for which your personal data is processed (the principle of limiting the duration of storage);
      • your personal data is managed in such a way as to ensure the adequate protection of personal data, including the protection against unauthorized processing or processing of unauthorized data and unintentional loss, destruction or damage by appropriate technical or organizational measures (the principle of integrity and confidentiality).
  8. The level of personal data security

    1. We use various security ensuring technologies and procedures with the aim to protect your personal data from illegal access, usage or disclosure. Our suppliers are carefully selected, we require that they use appropriate measures that can secure your confidentiality and ensure your personal data security.
    2. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we shall implement appropriate technical and organizational measures to ensure a level of security of personal data appropriate to the risk.
    3. The security of information transfer via email or by mobile communication in some cases cannot be ensured for reasons not dependent on us, therefore, you should take due care when providing confidential information to us by other than our electronic systems.
  9. Applicability of the Policy

    1. Rules established in this Policy shall apply to processing of personal data of natural persons. However, confidentiality of data belonging to legal persons shall be also ensured.
    2. The present Policy shall take effect on the date it is approved and posted on the Site. By our sole decision it may be unilaterally amended within the limits of changes in the legislation and in our activities or due to other important reasons.
    3. Rules with regard to jurisdiction, applicable law, dispute resolution, miscellaneous provisions, liability and indemnification established in the General Terms and Conditions shall apply to relations arising from this Policy to the extent it does not contradict this Policy or applicable obligatory laws.
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