Privacy Policy

This Privacy Policy outlines how our online platform, operating from the Netherlands, collects, uses, maintains, and discloses information collected from users (each, a "User") of our cryptocurrency-focused services. This policy applies to the site and all products and services offered by us. We are committed to protecting your privacy and handling your data in an open and transparent manner, in accordance with the General Data Protection Regulation (GDPR) and other applicable Dutch and European data protection laws.

1. Who We Are

We are a company based in the Netherlands, providing services related to the cryptocurrency ecosystem. Our registered address is located in the Netherlands. For any privacy-related inquiries, please contact us at our registered office in the Netherlands.

2. Information We Collect

We may collect various types of information from Users, which may include personal data. The types of personal data we collect depend on the services you use and how you interact with our platform.

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• Identity Data: This includes information such as your full name, date of birth, nationality, and gender, typically collected for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance as required by law.
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• Contact Data: Your email address, postal address, and telephone number.
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• Financial Data: Bank account details, payment card details, and details of transactions you carry out through our service. For cryptocurrency transactions, this includes blockchain addresses and transaction hashes.
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• Technical Data: Your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our service.
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• Usage Data: Information about how you use our website, products, and services, including navigation patterns, service interactions, and session durations.
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• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
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• Publicly Available Data: We may collect publicly available data from blockchain explorers or other public sources to verify transactions or enhance security.
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3. How We Collect Information

We collect information through various methods:

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• Direct Interactions: You provide data directly to us when you register for an account, apply for our services, subscribe to our newsletters, complete forms, or contact us.
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• Automated Technologies or Interactions: As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. This data is collected by using cookies, server logs, and other similar technologies.
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• Third Parties or Publicly Available Sources: We may receive personal data about you from third parties and public sources, such as identity verification services, fraud prevention agencies, and public blockchain networks.
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4. Legal Basis for Processing Your Data

We process your personal data based on the following legal grounds under GDPR:

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• Performance of a Contract: To fulfill our contractual obligations with you, such as providing access to our services, processing your transactions, and managing your account.
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• Legal Obligation: To comply with legal or regulatory obligations, particularly those related to financial services, anti-money laundering (AML), counter-terrorism financing (CTF), and data protection laws in the Netherlands and the EU.
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• Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided your fundamental rights do not override these interests. This includes improving our services, ensuring network and information security, detecting fraud, and for administrative purposes.
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• Consent: Where you have given explicit consent for specific processing activities, such as for marketing communications. You have the right to withdraw your consent at any time where we are relying on consent to process your personal data.
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5. How We Use Your Information

We use the collected information for various purposes, including:

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• To provide and maintain our services, including processing transactions and managing your account.
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• To verify your identity and conduct necessary due diligence (KYC/AML) to comply with legal obligations.
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• To improve, personalize, and expand our online platform and services.
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• To understand and analyze how you use our services to enhance user experience.
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• To detect, prevent, and address technical issues, security incidents, or fraudulent activities.
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• To communicate with you, including providing customer support, sending service updates, and promotional materials (where consent is given).
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• To fulfill legal and regulatory requirements.
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6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. This typically means we will keep your data for the duration of your account and for a period thereafter as required by Dutch and EU law (e.g., for AML/CTF purposes, which can be up to 5-7 years after the relationship ends). We may retain data for longer if required for legal claims or legitimate business interests.

7. Sharing Your Information

We do not sell, trade, or rent Users\' personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.

We may share your personal data with:

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• Service Providers: Third-party vendors and service providers who assist us in operating our business and the service (e.g., cloud hosting, payment processors, identity verification services). These parties are obligated to maintain the confidentiality of your information and are prohibited from using it for any purpose other than to perform their services for us.
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• Legal and Regulatory Authorities: When required by law or in response to valid requests by public authorities (e.g., a court or government agency), particularly for AML/CTF compliance.
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• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
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8. International Data Transfers

As we operate globally, your personal data may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Where we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
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• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as Standard Contractual Clauses (SCCs).
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9. Your Data Protection Rights (GDPR)

Under GDPR, you have the following rights regarding your personal data:

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• The right to be informed: About how your personal data is collected and used.
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• The right of access: To request copies of your personal data.
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• The right to rectification: To request that we correct any information you believe is inaccurate or incomplete.
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• The right to erasure ("right to be forgotten"): To request that we erase your personal data under certain conditions.
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• The right to restrict processing: To request that we restrict the processing of your personal data under certain conditions.
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• The right to object to processing: To object to our processing of your personal data under certain conditions.
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• The right to data portability: To request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
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• The right to withdraw consent: Where we rely on consent to process your personal data, you have the right to withdraw that consent at any time.
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• The right to lodge a complaint: With a supervisory authority, particularly the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe your rights have been violated.
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To exercise any of these rights, please contact us using the details provided in this policy.

10. Security Measures

We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data, username, password, transaction information, and data stored on our site. Our security measures include encryption, firewalls, and secure socket layer (SSL) technology, as well as regular security audits and employee training on data protection practices.

11. Cookies and Other Tracking Technologies

Our site may use "cookies" to enhance User experience. Your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about them. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, note that some parts of the service may not function properly.

We use cookies for purposes such as:

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• Authenticating users and preventing fraudulent activity.
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• Remembering user preferences and settings.
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• Analyzing site traffic and trends to improve our services.
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12. Third-Party Websites

Users may find advertising or other content on our site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our site. Browsing and interaction on any other website, including websites that have a link to our site, is subject to that website\'s own terms and policies.

13. Children\'s Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to remove that information from our servers.

14. Changes to This Privacy Policy

We have the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

15. Contacting Us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at our registered office in the Netherlands.