What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.”
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers (“Personal Information”).
How CoinBeam collects your data; What Information Does CoinBeam Collect?
When you establish an account with CoinBeam, you provide important information about yourself. Such information may include your name, e-mail address, government issued identification, passport, phone number and/or a user photograph. This information is either required by law (such as for identifying your identity), necessary to provide our Services, or relevant for a specific purpose. If you create a profile or utilize or Services, we may request certain Personal Information. CoinBeam may also collect the value of your portfolio and your transaction and exchange information including but not limited to the time of the transaction and/or exchange, the recipient, and the amount of the transaction and/or exchange. We may also collect any information from correspondence between yourself and CoinBeam.
We may also collect a variety of non-Personal Information including various analytics data such as the IP address of the computer or phone you use to access the Services, the type of browser software you are using, the operating system you are using, the date and time you access or use our Services, the website address, if any, you leave our website and travel to, and other non- personally identifiable traffic data. Other information we may collect could include your device type, how your device interacts with our Services, broad geographical location, and device event information such as when the application crashes, browser type, browser language and system activity.
We may collect data from third parties from time to time as required or permitted by law. These sources include but are not limited to: (i) ID Verification partners; (ii) blockchain data to ensure our Services are not being used to engage in illegal or prohibited activities under our Terms and for research and development purposes; and (iii) any affiliates we conduct business in connection with providing our Services.
Links to Third Parties
For your convenience, and to improve usage of the Website, we may insert links to third parties on the Website. If you decide to access those links, you will leave the Website. We do not control those third-party sites or their privacy practices, which may differ from our practices. Company is not liable for the content and activities of those sites. This includes links from partners that may use our logos as part of a co-branding agreement. Your visits and access to such websites is at your own risk.
How we use collected information
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. Your personal data may also be used to enforce our Terms in our Agreement, to detect fraud and/or funds loss, to provide you with our Services, to provide customer service, to ensure quality control, cloud storage, to provide Service communications, to ensure our network security, for research and development purposes, and for any purpose that you provide your consent.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data. The lawful basis under the Data Protection Legislation that allows CoinBeam to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of CoinBeam’s legitimate interests, in this case, the proper operation and functionality of CoinBeam’s Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR,
CoinBeam shares users’ Personal Information only as described below and with the subsidiaries or affiliates of CoinBeam that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice. which allows us to use your personal data with your consent for a particular purpose or purposes.
We may also use your Personal Information for:
Third party service providers: We may employ other companies and individuals to perform functions on our behalf. Examples could include analyzing data, providing marketing assistance, verifying user’s ID, and transmitting content. These third-party service providers only have access to Personal Information needed to perform their functions but may not use it for other purposes. Further, they must process the Personal Information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described below.
Business transfers: As we continue to develop our business, we might buy or merge with other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless the user consents otherwise).
How your information is secured
We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your Personal Information. Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account password. We recommend using a unique password for your CoinBeam account that is not utilized for other online accounts and to sign off when you finish using a shared computer.
Your information is an important part of our business and CoinBeam does not sell our user’s information to others. We cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at email@example.com.
International transfers of personal data
CoinBeam may transfer your data outside of the European Economic Area (“EEA”). CoinBeam puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection.
Children’s Personal Information
We do not knowingly collect Personal Information from any person under the age of 18. If a user submitting Personal Information is suspected of being younger than 18 years of age, CoinBeam will require the user to close their account and will not allow them to continue to use CoinBeam’s Services.
Access to your personal data
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request.”
All subject access requests should be made in writing and sent to firstname.lastname@example.org.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of CoinBeam’s progress.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- b) The right to access the personal data we hold about you.
- c) The right to have your personal data rectified if any of your personal data held byus is inaccurate or incomplete.
- d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose ofany of your personal data that we hold.
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to us using your personal data for a particular purpose orpurposes.
- g) The right to withdraw consent. This means that, if we are relying on your consentas the legal basis for using your personal data, you are free to withdraw that consent
at any time.
- h) The right to data portability. This means that, if you have provided personal data tous directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. Prior to lodging a complaint, we welcome the opportunity to resolve your concerns ourselves. All concerns can be addressed to email@example.com.
How long we store your Personal Information for
We keep your Personal Information to enable your continued use of CoinBeam’s Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you. If you delete your account or request that your information be deleted, we still may retain some Personal Information that you have provided to us in order to comply with relevant laws.
Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
For California Residents
Request to Know. You have the right to request to know: (i) the specific pieces of Personal Information we have collected about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. You may exercise your right to request to know twice a year, free of charge.
Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password or security questions and answers.
Generally, in the past 12 months:
We collected the categories of Personal Information from the sources detailed above in “Information We Collect from You and from Third Parties”. The purposes for the collection of the Personal Information are described above in “How We Use Collected Information.”
Request to delete. You have the right to request that we delete the Personal Information that we have collected from you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason why. You may submit a request for deletion via the following methods: E-mail firstname.lastname@example.org.
Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our website, application, or Services.
You have the right to know what personal information is sold, shared, or disclosed with third parties. As such, you may submit a verifiable consumer request via the following methods: E-mail us at email@example.com
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.