PRIVACY POLICY

Last updated: Aug 7, 2018

We, at Bitfair Technologies Private Limited (hereinafter referred to as “Company” “we”, “our” and “us”), are committed to protecting your interests against potential instances of money-laundering and related financial crimes, and promoting legal and transparent trade in Digital Assets on your use of this Platform. The terms “User”, “you” and “your” refer to the Users of our Platform.

BY USING THIS PLATFORM, YOU CONFIRM THAT YOU ARE CONSENTING TO BE BOUND BY THIS PRIVACY POLICY. THEREFORE, WE REQUEST YOU TO CAREFULLY READ THE TERMS CONTAINED HEREIN. WE RECOMMEND THAT YOU PRINT A COPY OF THIS FOR FUTURE REFERENCE. YOU ARE ENCOURAGED TO REVIEW THIS PRIVACY POLICY EVERY TIME YOU ACCESS OUR PLATFORM TO MAKE SURE THAT YOU UNDERSTAND HOW ANY INFORMATION YOU PROVIDE WILL BE USED.

WE MAY REVISE THE TERMS OF THIS PRIVACY POLICY AT ANY TIME BY AMENDING THIS PAGE. PLEASE CHECK THIS PAGE FROM TIME TO TIME TO TAKE NOTICE OF ANY CHANGES WE MADE, AS THEY ARE BINDING ON YOU. ANY CHANGES WILL ONLY APPLY TO ACTIVITIES AND INFORMATION ON A GOING FORWARD BASIS.

PRIVACY POLICY IS A PART OF OUR TERMS

This Privacy Policy is a part of and incorporated within and is to be read along with the User Terms and Conditions available at https://flux.coindelta.com/agreement and the Anti-Money Laundering Policy available at https://flux.coindelta.com/privacy-policy , hereinafter collectively referred to as “Terms”. The capitalized terms used in this Privacy Policy, but not defined herein, shall have the meaning given to such terms in the Terms.

ACCURACY OF INFORMATION PROVIDED BY YOU

We request you to ensure that all your data and/or information shared with us is accurate, correct and complete, at all times. You must promptly inform us of any changes to your data and/or information which may impact your use of our Services. You understand that we shall not be liable or responsible for the authenticity of your data and/or information, and any loss or damage that may occur to you or other third parties on account of the data and/or information being provided by you.

WHAT INFORMATION DO WE COLLECT?

We may collect and process the following data about you:

  • Verification Information. If you register / attempt to register as a User of our Platform, you may be required to give us information about yourself, including without limitation, your name, e-mail address, age, nationality, phone number and postal address, and certain personally identifiable information, including without limitation, your government issued national identity document, passport, taxpayer number, bank account information, wallets held on third-party exchanges/websites, or other similar information (“Information”). We may share this Information with third party service providers acting on our behalf to verify your identity for risk management purposes, and to detect and protect against frauds and similar criminal activity. We may request other information from time to time for providing the Services.
    We may also occasionally require you to participate in optional surveys. Your information may be collected through such surveys.
    Further, we may also require additional information about you necessitated under the applicable law, based on your risk assessment, transaction value, etc.
  • Automatically Collected Information .During each of your visits to our Platform, we may automatically collect and analyse demographic and other information, including without limitation, (a) technical information about your device, including its operating system and the browser, the Internet Protocol address (IP address) being used, location and other similar information; (b) information about your activity, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); (c) information about transactions and trades executed or attempted to be executed by you, material or information that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); (d) information about fund-transfer requests executed while accessing Services through our Platform. In such transactions, we may collect information relating to such transactions provided by you or by a Selected Third Party (defined below); and (e) metadata and other technical data associated with the content you submit, post or share on the Platform. Users can add or may have metadata added to their content including geolocation, date, attribution, or other data.
  • External Information. We may receive information about you from external sources such as from your use any of the other websites/apps we operate or the other Services we provide. We also work closely with third parties (including, for example, sub-contractors such as advertising networks, analytics providers, search information providers) and may receive information about you from such sources.
  • Statistical Information. We collect non-personally identifiable information to track the total number of visitors to our Platform in aggregate form and identify the type of internet web browser (e.g. Google Chrome®) and operating system (e.g. Windows®) used by the visitor.

HOW DO WE USE YOUR PERSONAL INFORMATION?

As a matter of practice, we will use your personal information only for the following purposes and inform you in advance if any purpose is changed:

  • Verification Information. We will use this information:
    • to verify and process your personal particulars;
    • for verification of identification documents provided by you. You understand that in order to verify that such information belongs to you: (a) we may send you a verification e-mail; and (b) share information with a Selected Third Party (defined below) who may contact you to verify and authenticate your identification documents;
    • to facilitate and provide the Services offered through our Platform;
    • to update and back-up our records;
    • to carry out our obligations arising from any contracts entered into by you with other Users of our Platform (including processing of any transactions executed or attempted to be executed by you) and to provide you with the information and Services, that you request from us;
    • to enhance the security of our Platform;
    • to personalise content/Services offered to you;
    • to remember information to help you efficiently access your User Account;
    • to provide you with information about other Services we offer that are similar to those that you are already using or have enquired about;
    • to inform you of promotions, offers, surveys, events, products, and services, which may be of interest to you;
    • to provide you, or permit Selected Third Parties to provide you, with information about Services we feel may interest you. If you are a registered User, we will only contact you by electronic means (e-mail or SMS) with information about services similar to the Services being used by you;
    • to notify you about any changes to our Services;
    • to ensure that content from our Platform is presented in the most effective manner for you and for your computing device;
    • to send you Service-related notices or emails and other non-essential promotional material. In case you do not wish to receive such e-mails or SMS, you may unsubscribe at any time by clicking on the ‘Unsubscribe’ link in the promotional e- mail or SMS or by contacting our Grievance Officer; and
    • to prevent and identify suspicious / other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities.
  • Automatically Collected Information. We will use this information:
    • to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our Platform to ensure that the content is presented in the most effective manner for you and for your device;
    • to allow you to participate in interactive features of our Services, when you choose to do so;
    • as part of our efforts to keep our Platform safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • to better understand the volume of traffic in particular areas of our Platform;
    • to make suggestions and recommendations to you and other Users about Services that may interest you or them;
    • for fulfilling our obligations under applicable law including performing on-going due diligence and reporting suspicious/other illegal transactions;
    • as part of our security, anti-fraud, and authentication checks in order to mitigate risks relating to money laundering and other illegal activities; and
    • in order to comply with directions of various law enforcement agencies/regulators.
  • External Information. We may share this data internally and combine it with data collected through your use of the Platform. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
  • Statistical Information. We may share statistically anonymised information with third parties or publish generic transactional information relating to the trades undertaken on the Platform such as current and historical bids, asks, and market prices, opening and closing range prices, high-low prices, trade prices, estimated and actual trade volumes, settlement prices, etc. This information allows us to improve the Platform and Services continuously.

WHEN MIGHT WE DISCLOSE AND SHARE YOUR PERSONAL INFORMATION?

We will only share your information in accordance with the circumstances outlined in this section.

We reserve the right to export your personal information and other data outside of your jurisdiction of citizenship/residence. Under those circumstances, your personal information may be processed and stored in a foreign country or countries, and the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your personal information under the relevant foreign laws.

We also reserve the rights to distribute any information that (i) you voluntarily disclose or chose to make public, or (ii) is freely accessible in public domain.

We reserve the right to share your personal information to any third party only under one of the following circumstances:

  • For Crime Prevention or Investigation.We may share this information with government/enforcement agencies or other companies assisting us, when we are:
    • Obligated under the applicable laws or in good faith to respond to court orders and processes;
    • Detecting and preventing against actual or potential occurrence of identity theft, fraud, money laundering, abuse of Services and other illegal acts; or
    • Under a duty to disclose or share your personal data in order to enforce or apply our Terms and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with third parties for the purposes of fraud protection and KYC verification.
  • For Activities on the Platform.
    • Interaction with Users You may routinely execute Digital Asset transfers on our Platform. In order to process such transactions between you and other Users on our Platform, we may share information about you with such User, including your email address or mobile phone number or any peer to peer banking id (for example, unified payment information (UPI) address for Indian Users) to inform such User that a transfer has been sent to or received by such User.
    • For Authorizing and Verifying the Transaction We may use this information in connection with transfers and/or transactions undertaken by you with other Users on the Platform to confirm that you are our customer, that Digital Asset transfers are enabled, and/or to notify you that you have received Digital Asset.
  • For Internal Use. We may share this information:
    • With any member of our Group. The term “Group” means, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any ‘Relative’ (as such term is defined in the Companies Act, 2013) of such person.
    • In the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets.
    • If the Company or substantially all of its assets are acquired by a third party, in which case personal information held by it about its Users will be one of the transferred assets.
  • With Selected Third Parties. We or our Group entities may disclose and share your personal information with selected business partners and third parties including but not limited to service providers who authenticate KYC and details as furnished/provided by you to us or suppliers that host our data or provide customer support service. (“Selected Third Party”).
  • With Advertisers and Advertising Networks. We do not disclose personally identifiable information of our Users to any advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that any given number of people in a specified age group clicked on their advertisement on any given day) to select and serve relevant adverts to you. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
  • Statistical Information. We reserve the right to share current and historical bids, asks, and market prices, opening and closing range prices, high-low prices, trade prices, estimated and actual trade volumes, settlement prices, and other aggregate data and information related to the Digital Assets traded on the Platform.

HOW MAY YOU ACCESS YOUR PERSONAL INFORMATION?

Under the Act, you have the right to review the information we collect about you. To the best extent possible, we will attempt to ensure that such information is correct and updated.

To exercise this right, you may send us a request at support@coindelta.com. However, this right is subject to our Terms and other legal and regulatory obligations.

You may deal with your personal information available with us in the following ways:

  • You may correct, amend, add or update personal information from your User Account at any time by logging in to your User Account;
  • You are free to remove or delete your content from your User Account at any point in time, provided, however, the Company may retain all or some of your data in accordance with the AML Policy in force or as per applicable laws. Copies of public content may be retained indefinitely in our systems, including in cached and archived pages of our Platform, or if other Users have copied or saved that information.

OPT-OUT OF SHARING YOUR INFORMATION

By using our Platform, you agree and consent to the collection and use of information collected in the manner described above and in accordance with this Privacy Policy. You also agree and consent to any changes made to this Privacy Policy in due course and without notice. If you do not agree with the terms of this Privacy Policy, please do not provide any information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any information as required by us, we may not be able to provide you with the Services that are being offered through the Platform.

VOLUNTARY DISCLOSURE TO THIRD PARTIES

This Privacy Policy shall not apply to any information voluntarily disclosed by you to other Users of our Platform or third parties other than Selected Third Parties (defined below). We shall not be held responsible for any liability or obligation you might face due to your sharing of details with anyone.

HOW DO WE USE COOKIES ?

Our Platform uses cookies and tracking technology (including pixels and/or web- beacons) depending on the features offered. “Cookies” are small files that are placed on your device (either temporarily or until manually deleted by you) in order to distinguish you from other Users of our Platform.

The use of such technology allows us to (a) statistically monitor how many people are using our Platform and those of our affiliates, or opening our messages, and for what purposes; (b) to provide you with a customised experience when you browse our Platform; and (c) to improve our Platform, our Services, and advertising. Third parties may also use such Cookies and tracking technology if you interact with any content provided by them through our Platform..

Limited personal information, in its anonymized form, may be collected through the Cookies and tracking technology, including but not limited to transaction information and other generic information such as number of visitors, device information, etc. Further, if any personal information has been previously provided, Cookies may be tied to such information.

Cookie and tracking information collected by us may be shared with third-parties which directly support our advertising/promotional activities and are involved in the development of/updating our Platform.

Commonly used browsers automatically accept Cookies; however, you can modify your device’s settings to either alert you when you receive Cookies or block Cookies. If you disable/block Cookies, it may affect the performance and functionality of our Platform and may also restrict your experience. If you use different devices to access our Platform, you would be required to modify each device’s settings individually to suit your Cookie preferences.

HOW LONG DO WE RETAIN YOUR DATA?

We may, at our sole discretion, retain any information and/or data provided by you for as long as your User Account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under our policies and applicable laws. The retention period may be extended in accordance with the applicable law.

We make no warranties and shall not be liable regarding non-availability or non- retention of any information and/or data provided by you beyond the deletion of your User Account.

HOW DO WE KEEP YOUR DATA SECURE AND WHERE DO WE STORE IT?

We have in place appropriate technical and security measures to secure the information collected by us. We have implemented reasonable and appropriate security measures which we developed in-house along with using security services from third party service providers to protect the information provided by you, including without limitation virtual private network, private IPs, virtual private cloud, SSL certificates, AWS CloudHSM, shields, proxy layers, web application firewall (WAF) and encryption techniques. We store your data with the cloud platform provided by Amazon Web Services (AWS), which may store this data on their servers located outside of India. AWS has reasonable and appropriate security measures in place to protect the loss, misuse and alteration of the information, details of which are available at https://aws.amazon.com/agreement/. The privacy policy adopted by AWS are detailed in https://aws.amazon.com/privacy/. In the event you have questions or concerns about the security measures adopted by AWS, you can contact their data protection/privacy team/legal team or the designated grievance officer at their organisation, whose contact details are available in their privacy policy. Alternatively, you can also write to our Grievance Officer at the address provided below:

Bitfair Technologies Private Limited, Ground B, Midas Tower, Hinjewadi Phase 1, Pune, MH – 411057.

THIRD PARTY WEBSITES

This Platform may contain links to third party websites. When you click on a link to any other website or location, you will leave the Platform and go to another website, and a third party may collect personal information or other information from you. We have no control over, do not review, and are not responsible or liable for, these third- party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your personal information after you click on links to any such third-party websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are provided merely as a convenience and do not signify or imply our endorsement of, or association with, such third parties or their products, services, content, or websites. You use any such links and the products, services, and content accessed thereby at your own discretion and at your own risk.

DISCLAIMER

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to the Platform. Any transmission is at your own risk. Once we have received your information, we use the procedures and security features as provided under the terms of this Privacy Policy to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a username and password which enables you to access our Platform, you are responsible for keeping these details confidential. We ask you not to share your password with anyone. You must log out when you leave our Platform protected by a password. We recommend closing the browser completely and re-opening it before accessing other websites over the internet

You understand and acknowledge that generally, information published on a blockchain (including, without limitation, transactional information) is susceptible to public disclosure since any blockchain ledger is publicly accessible. As a result, Digital Asset transactions, whether executed on the Platform or otherwise, are not truly anonymous. Similarly, the balance and transaction history of any public Digital Asset address can also be viewed by the public at large. Further, the information relating to a public Digital Asset address can also be correlated / matched with technical information automatically collected over the internet, in order to ascertain your identity. Also, data- analysis techniques can be used on a blockchain to identify information about you. You understand and acknowledge that we cannot be held liable for any loss of your information sustained due to the inherent lacunas of blockchain technology.

IF YOU WISH TO CONTACT US

In the event you have any questions or concerns, or wish to file a grievance or complaint, or wish to provide feedback, please contact us at https://support.coindelta.com/support/how-to-create-submit-a-ticket.html with a thorough description, and we will try to resolve it. You may also contact us at the address below:

Our mailing address is Bitfair Technologies Private Limited, Ground B, Midas Tower, Hinjewadi Phase 1, Pune, MH – 411057.



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