Last updated: May 30, 2018
A. HOW CoinCut COLLECTS INFORMATION ABOUT YOU
CoinCut does not target its websites, mobile app, API, or any of the Services at children. CoinCut does not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.
If you create an account or use the Services, we, or our affiliates or Vendors (as defined hereunder) acting on our behalf may collect the following types of information for the purpose as set forth hereunder:
Account Information – your email address and password;
Contact Information – your name, birth of date, address, phone number;
Identity Verification Information - our ID number, image of your government issued ID, passport, national ID card, driving license, your selfie along with the above mentioned ID documents, and FATCA (Foreign Account Tax Compliance Act) related information;
Financial Information - withdrawal address, source of fund, the number of bank account linked with your CoinCut account, and image of bank statement or similar information;
Nationality/Residence Verification Information - your address, nationality, country of residence, and utility bill or similar information;and/or
Survey Information - certain personally identifiable information you provide in response to our survey. This may include details about your education history, income and your employment;
Information about geo-location - real-time location based information from your device at any time while you download or use our services. We may use this information to optimize your experience;
Information we receive from other sources - We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Internet infrastructure - cloud storage and cloud computing;
Communication tools and platforms - SMS services, email services, and push notification, and customer support tool;
Error collection tools - web page error message collection, APP crash tracking, web and APP experiment (A/B testing), and APP statistics;
User behavior analysis - user behavior tracking tool and bot prevention tool; and
Anti-money laundering tool - such as AML database.
If you seek permissions to raise digital currency buy and sell limits associated with your CoinCut account, we may require you to provide additional information to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal data. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect name and type of your computer, mobile device, or other access device, such as the name and device of your operating system, for fraud prevention purposes, to monitor for possible breach of your CoinCut account, and to identify any malicious software or other activity that may harm CoinCut or its users.
Finally, we collect additional information that you provide voluntarily to our customer success team.
B. HOW CoinCut PROTECTS AND STORES PERSONAL DATA
We store and process your personal and transactional data, including certain payment information, where CoinCut facilities or our service providers are located.
C. HOW CoinCut USES THE PERSONAL DATA WE COLLECT
Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to:
Provide the Services and requested customer support;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Customize, measure, and improve CoinCut Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and/or
Verify your identity by comparing your personal data against third-party databases.
We process your personal data on one or more of the following legal bases in accordance with applicable rules and regulations, including the General Data Protection Regulation (GDPR) in EU:
With the consent from you, we may provide you with CoinCut and our Services. On the same basis, we may also optimize and enhance CoinCut for all customers, or for you specifically;
For our legitimate business purposes, we may monitor the usage of CoinCut, conduct automated and manual security checks of our Service, to protect our rights and perform our lawful obligations; and/or
In order to comply with legal obligations under applicable rules and regulations, we may conduct AML procedure, anti-fraud procedure, identity verification and authentication checks.
We will not use your personal data for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal data with third parties for the purpose of provide the Services. You may refuse to provide or may withdraw your consent at any time without adverse consequence. Your refusal and withdrawal of consent will have no effect on the services we provide hereunder, provided that such consent is not necessary for our performance of the Services hereunder.
We do not engage in individual automated decision-making.
We will never sell or rent your personal data to any third parties.
Any communications we send to you will either be related to your account or will be related to CoinCut services or products. In the event CoinCut sends any communication to you which is not related specifically to your account, CoinCut will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future.
D. HOW CoinCut SHARES PERSONAL INFORMATION WITH OTHER PARTIESWe may share your personal data with the following parties for the following reasons.
Authorized Third Party Applications. If you authorize one or more third-party applications to access your CoinCut account, then information you have provided to CoinCut may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during you use of the Services.
Law enforcement, government officials, or other third parties. We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure.
Miscellaneous. We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.
Before CoinCut shares your personal data with any third party, CoinCut will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.
If you establish a CoinCut 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 CoinCut website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
E. SPECIFIC CONSENT BY USERS IN THE EUROPEAN ECONOMIC AREA
If you are located in, or a resident of, the European Economic Area (“EEA”), we, with your specific and voluntary consent, may transfer your personal data to our affiliates and Vendors in the United States and Israel, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
The United States and Israel may not have protections in place for personal data as extensive as those within the EEA and may not provide adequate protection for personal data within the meaning of the GDPR. Although we rely on your explicit consent to the transfer rather than an alternative data transfer mechanism, we require our service providers to treat your personal data in strict confidence and use appropriate security measures to protect it.
You may refuse to give or revoke your consent to this international transfer of your personal data at any time by emailing email@example.com with the subject line “Revoke EEA data consent”. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use CoinCut and our services. You will have the ability to withdraw Digital Assets; however, all other functionality will be disabled.
F. HOW YOU CAN CONTACT US ABOUT PRIVACY QUESTIONS AND EXERCISE YOUR DATA SUBJECT RIGHTS
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page by emailing firstname.lastname@example.org.
If you are located in, or a resident of, EEA, you have the following rights under EU data protection l Right of access: you can request information about your Personal Data and request a copy of that data.
Right of rectification: you can request that we correct or update your Personal Data if they are incomplete or incorrect by CoinCut at any time by submitting a request to: email@example.com with the subject line “Revise Personal Information”.
Right to restriction: you can request that we restrict the processing of your Personal Data.
Right to erasure: you can request erasure of your Personal Data, if the data are inaccurate or processed in a way which is incompatible with the purpose(s) pursued by us.
Right to data portability: if we process your Personal Data on the basis of a contract with you or based on your consent, you can request to receive your Personal Data in a structured, commonly used and machine-readable format, and ask us to transfer such data to a third party, where technically feasible. Furthermore, if you wish to have a copy of your ledger in CoinCut, you may download them by submitting a request to firstname.lastname@example.org with the subject line “Download Ledger”.
Right to objection: you can object to the processing of your Personal Data for direct marketing purpose at any time.
Right to lodge a complaint: you can lodge a complaint with a competent supervisory authority in the EU situated at your habitual residence, place of work, or place of alleged infringement of the GDPR.
Right to refuse or withdraw your consent: you can refuse to give and withdraw your consent to data processing at any time. You can also oppose processing of your Personal Data, based on our legitimate interests, including profiling based on this provision, on compelling grounds relating to your particular situation at any time.
Right not to be subject to automated individual decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to deactivate/delete your account: if you no longer wish to use our Services, you have the right to deactivate/delete your CoinCut account by submitting a request to email@example.com with the subject line “Deactivate/Delete Account”. Please note, however, that we may need to retain certain information for record keeping or regulation compliance purposes on a necessary basis.
If you want to exercise these rights, you can contact us at firstname.lastname@example.org.