Last updated: October 12, 2022
INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Platform, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Platform, and information from other sources such as third-party services and organizations, as described below.
We may ask for personal information — for example, when you register an account, make a listing, or when you contact us — which may include one or more of the following:
- Social media profiles
- Date of birth
- Phone/mobile number
- Home/mailing address
- Digital Asset Wallet Address
- Other information necessary for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance purposes
We use different methods to collect information from and about you, including through:
Direct interactions. You may give us your identity data, contact data, financial data, account data and marketing and communications Data by directly interacting with us, including by filling in forms, by email or otherwise. This includes personal data you provide when you:
- visit our Platform;
- apply for our services offering via our Platform;
- create an account on our Platform;
- make a listing on our Platform;
- request marketing to be sent to you;
- enter a competition, promotion, or survey, including through social media channels;
- give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Platform, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We will also collect transactional and usage data. We may also receive technical data and marketing and communications data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We also obtain information about you from third parties or publicly available sources. These sources may include:
- public blockchain,
- publicly available information on the Internet (websites, articles etc.)
LEGITIMATE REASONS FOR PROCESSING AND USING YOUR PERSONAL INFORMATION
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide you access to our Platform and our services to you.
Most commonly, we will use your personal data in the following circumstances:
- performance of a contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; we use this basis for provision of our services offered on the Platform;
- legitimate interests: means our interests (or those of a third party), where we make sure we use this basis as far as your interests and individual rights do not override those interests;
- consent: means freely given, specific, informed, and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you; under specific circumstances this consent should be explicit – if this is the case, we will ask for it properly.
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to enable you to access and use our Platform, associated applications, and associated social media platforms;
- to provide you with our Platform’s core features and services;
- to facilitate with payment and transaction on the Platform;
- to enable you to customize or personalize your experience of our Platform;
- to contact and communicate with you, including promotional communications;
- to monitor and analyze trends, usage and activities for marketing and analytics purposes;
- to comply with our legal obligations and resolve any disputes that we may have;
- to detect, prevent, or investigate security breaches, fraud and other unauthorized or illegal activity;
- to enforce our Terms of Service;
- to fulfill a purpose with your consent;
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.
Information you post publicly on our Platform may be accessed, collected, or used by others and it may result in unsolicited messages or contact from others. We strongly encourage you to use caution and discretion when sharing information publicly.
SECURITY OF YOUR PERSONAL INFORMATION
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our Platform. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
While there is an inherent risk in any data being shared over the internet, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:
- organizational measures (including but not limited to staff training and policy development);
- technical measures (including but not limited to physical protection of data, pseudonymization and encryption); and
- securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:
- in the event of a complaint;
- if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims;
- to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data, if information is needed for audit purposes and so forth;
- in accordance with relevant industry standards or guidelines;
- in accordance with our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal data for the time of the promotion and for a certain period after its end to prevent the appearance of abusive behavior.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Platform and services to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We may disclose personal information to:
- a parent, subsidiary, or affiliate of the Company
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our assets and business
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by opting out of the promotional communications or contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Period for replying to a legitimate request: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The Platform is not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Platform without your consent, you may contact us at [email]. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, members of the European Union, or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
LIMITS OF OUR POLICY
Our Platform may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
CHANGES TO THIS POLICY
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information by visiting: https://www.oag.ca.gov/privacy/ccpa.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
YOUR RIGHTS AS A DATA SUBJECT (GDPR)
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). You can find out more about the GDPR and your rights by accessing the European Commission’s website.
CONTACT US FOR QUESTIONS AND REPORTING VIOLATIONS