Last Updated: October 21, 2019
Bittrex Global GmbH (Commercial Register No. FL-0002.613.705-0), domiciled at Dr. Grass-Strasse 12, 9490 Vaduz, Liechtenstein (“Bittrex”, “Bittrex Global”, “we”; “us”; “our”) respects your privacy and is committed to protecting your personal information or, as otherwise termed, your “personal data”. In that regard, Bittrex Global has launched and offers a service which provides our clients (subject to prior account registration) with access to certain virtual financial assets on an online trading platform (the “Platform”) which is accessible via the website global.bittrex.com (which is accessible by going to any number of websites including www.Bittrex.li) (the “Site”) or our mobile applications or any application programming interface (API) provided by Bittrex Global relating to the Site. The Platform automatically matches trades with open orders from other traders, In addition to the matching and trading services offered over the Platform, the Platform also offers digital wallet services to registered account users, allowing them to store the virtual financial assets which are traded over the Platform.
- visit and use the Site and/or the Platform (regardless of where you visit or use them from);
- apply for and open an account in respect of our Platform (your “Account”); and
- apply for, receive or use any of the related services that we offer in connection with the Platform, including our virtual financial assets exchange and digital wallet services (the “Services”).
This includes any data that you may provide for and in relation to our newsletters, updates, events and other marketing and promotional communications.
- Important Information and who we are
- Some key definitions
- The personal data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfer
- Data security
- Data retention
- Your legal right
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
We process your personal data in an appropriate and lawful manner, in accordance with the Liechtenstein Data Protection Act of 4 October 2018 (the “Act”) as amended, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), as well as subsidiary legislation and regulations promulgated thereunder.
This Policy aims to give information on how Bittrex Global collects and processes your personal data in the scenarios outlined above in the ‘Introduction’ (namely, through your use of the Site, the Platform and our related services, including any data that you may provide to us or which we may receive).
The Site and the Platform are not intended for minors (i.e., persons under 18 years of age) and we do not knowingly collect personal data relating to minors.
It is important that you read this Policy together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
Bittrex Global as defined above is the controller and responsible for your personal data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy and our processing activities in general. If you have any questions or requests, including any requests to exercise your legal rights as a data subject, please contact the DPO using the details set out below.
Full name of legal entity: Bittrex Global GmbH (Commercial Register No. FL-0002.613.705-0)
Name of DPO: Siegfried Herzog
Email address: firstname.lastname@example.org
Postal address: Dr. Grass-Strasse 12, 9490 Vaduz
Last update and Your Duty to Inform Us of Changes
This Policy was last updated on October 21, 2019.
It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the availability of our Platform (amongst other potential and salient issues). Please keep us informed if your personal data changes during your relationship with us. For your right to rectification of the processed information, please refer to sub-paragraph ii of Section 10 of the Policy.
Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.
2. KEY DEFINITIONS
“Data subjects” means living individuals (i.e. natural persons) about whom we collect and process personal data.
“Data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed.
“Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).
“Processing” means any activity that involves use of personal data. It includes collecting, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying it. Processing also includes transferring personal data to third parties.
“Sensitive personal data”, “sensitive data” or “special categories of personal data” includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, genetics and genetics-related aspects, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings, or the conviction or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions set forth in articles 9 and 10 of the GDPR.
Note that personal data does not include information relating to a legal person (for example, a company or other legal entity). In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data in terms of both the Act and the GDPR. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. Naturally, we will still treat any and all such information in a confidential and secure manner.
3. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed and is not relatable to an identified or identifiable person (anonymous data). In the course of your relationship with us (including during the account opening stage), we may collect, use, store and transfer different kinds of personal data about you which we have grouped together.
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive feature of the Services, fill out a form, participate in a community or forum discussion, complete an exchange transaction, apply for a job at Bittrex Global, request customer support or otherwise communicate with us. The types of information we may collect include your name, date of birth, email address, postal address, phone number, certain virtual financial asset information, and, in addition any further information you choose to provide. Only personal information necessary for carrying out and performing our tasks and services, or made available by you on a voluntary basis, is collected.
For avoidance of doubt, categories marked in blue are applicable to customers (i.e. individuals who hold a registered customer account with us). We shall request this information in order to be able to register you on our Platform.
- Identity Data includes your first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and/or passport number. This will form part of your account information on the Platform.
- Contact Data includes your billing address, email address and contact number (telephone and/or mobile).
- Financial Data includes your bank account and payment details.
- AML / KYC Data includes the following due diligence / KYC information and documentation about you: (i) copy of valid I.D. card or passport, (ii) proof of residence (e.g. confirmation of identity), (iii) KYC database checks, (iv) fraud database checks and (v) any documentation or information which we may, from time to time:
- be required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and global AML/KYC practices; and/or
- otherwise be mandated to collect by the Liechtenstein Financial Intelligence Unit (“FIU”), the Liechtenstein Financial Market Authority (“FMA”) and/or any other competent authority or law enforcement agency (national or international).
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
The categories of personal data marked in green below are applicable to customers holding a registered account with us who start trading over the Platform and otherwise make use of our Services, thus coming in addition to the data categories marked in blue above.
For the duration of this information being stored, please see Section 9. In accordance with the relevant legal obligations, AML / KYC Data will be stored until ten years after the termination of the customer relationship. The storage’s purpose is based on ensuring the operability of the system, ensuring the performance of the transactions on the Platform, the compliance with the legal duties concerning KYC/AML/due diligence duties.
- Transaction Data includes details about:
- the type of virtual financial assets involved, the order volume, price, value and, where applicable, the proceeds derived;
- your trading and transactional history on the Platform, including withdrawals and order activity; and
- the payments which we receive, or otherwise, charge you (e.g. our fees for your use of the Platform).
- Portfolio Data includes details about the virtual financial assets and amounts credited to your Account and your Account balances.
- Enhanced KYC Data applies in respect of instances mandated by our AML-KYC Policy, which would include, amongst other scenarios, situations where a higher risk of money laundering and funding of terrorism has been identified.
For the duration of this information being stored, please see Section 9. The storage’s purpose is based on ensuring the operability of the system, ensuring the performance of the transactions on the Platform, the compliance with the legal duties concerning KYC/AML/due diligence duties, and to maintain the integrity of the system.
In all cases, we collect the following information upon access to our Site:
- Technical/LOG Data includes the IP address, your login data to the Platform (username and password), information on your internet service provider, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Site and Platform. This also includes information about your use of the Services, including the type of browser time and date of access, pages viewed, and the page you visited before navigating to our Services.
- Device Data includes information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Usage Data includes information about how you use the Platform.
For the duration of this information being stored, please see Section 9. The storage’s purpose is based on the security of processing in order to ensure the stability and operational security of the system as well as for statistical purposes in order to derive Aggregated Data from Usage Data.
If you fail to provide Personal Data
Where we need to collect personal data about you:
- by law; or
- under the terms of, or in connection with, the contract that we have with you (as discussed in Section 1 above); or
- as part of our legitimate (business) interests to verify the identity of our applicants and clients, mitigate against risks (such as potential or suspected fraud) and in particular, to assess and take a decision on whether we will or should enter into a relationship with you (as subject to our client acceptance criteria and policies);
and you either fail to provide that data when requested, or else provide incomplete or insufficient data, we may not be able to perform or conclude the contract which we have or are otherwise trying to enter into with you (namely regarding your account opening on the Platform and provision of our related services).
In certain instances, particularly where this relates to AML / KYC Data, we may even need to exercise our prerogative to terminate our contract with you, and thus withdraw the availability of our services to you, or else, if still at application stage, we may have to decline to enter into a relationship with you. We will, however, notify you if this is the case at that point in time.
Sensitive Personal Data
We do not knowingly collect any information qualifying as Special Categories of Personal Data under article 9 of the GDPR (or Sensitive Personal Data) about you. Should we receive sensitive personal data about you, we will only process that data where there is a legitimate reason and purpose as set down in article 9 para. 2 of the GDPR to do so and, in all circumstances, in accordance with our obligations at law and under the appropriate safeguards.
As set out below in Section 5, we collect and process AML / KYC Data in order to be able to (i) comply with legal and regulatory obligations, as applicable (ii) conduct our AML and KYC checks, and other due diligence checks, on you, (iii) verify your identity or claimed identity and identify and/or verify your source of funds and source of wealth, as appropriate, (iv) perform a risk assessment on the potential customer relationship, (v) take an informed decision on whether we want to enter into a customer relationship with you, and, if positive, to conduct initial and ongoing screening and monitoring and (vi) to comply with any legal or regulatory obligation that we may have and/or any Court, regulatory or enforcement order that may be issued upon us.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
(A) Account Registration and Opening.
We will ask you to provide us with your Identity, Contact, Financial and AML/KYC Data when you apply to register and open an account with us on our Platform (including at account finalisation stage). You provide these personal details and information to us, which we collect and process, when you fill in and submit our application form (together with other related forms), and complete our required application steps.
Your Account Data will be generated on the basis of your application, and is also processed and stored by us. For the duration of this information being stored, please see Section 9.
(B) Service Use.
This encompasses all of the data categories listed in Section 3 (namely, Identity, Contact, Financial, AML and KYC Data, Marketing and Communication Data; Enhanced KYC Data, Portfolio Data, and Transaction Data)
(C) Direct Interactions.
You may also give us your Identity, Contact, Financial, AML/KYC Data, Marketing and Communications Data, and Transaction Data by filling in our other forms (i.e. separate to our account opening and registration form), or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data that you provide when you, as applicable:
- apply to open an account;
- update or edit your account details;
- subscribe to our Platform;
- request withdrawals from your Account;
- contact us with complaints or queries;
- report issues;
- submit the (additional or supplementary) AML / KYC Data that we may request from you;
- request marketing to be sent to you;
- participate in a survey; or
- provide us with feedback.
(D) Automated Technologies or Interactions.
As you interact with the Platform and the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns (please see the bullet point “Technical/LOG Data” for the relevant information that is collected and processed). We collect this personal data by using cookies, server logs and other similar technologies.
Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits, manage the registration process for accounts, remember your site preferences, retain certain information to process orders for exchange transactions, and retain information to provide you with support. Web beacons are electronic images that may be used on our Platform or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. Cookies remain stored until you delete them. Thus, we can recognize your browser when you visit the Site again.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of our Services.
The legal basis for the data processed by the way of cookies is article 6 para. 1 subpara. 1 lit. f of the GDPR.
Cookies retain their validity for the minimum period necessary for their functionality
Furthermore, we analyse the use of our internet presence with the web analysis tool Google Analytics. This exclusively serves the optimisation of the Site with regard to user-friendliness and to making available useful information about our services. There is no consolidation of this information with other sources of information relating to persons; nor does a transfer to third parties occur.
The legal basis for the temporary storage of information and the logfiles is article 6 para. 1 subpara. 1 lit. f of the GDPR.
There is no personal evaluation. The analyses are based on anonymized sets of data.
(E) Third Parties or Publicly Available Sources.
We also obtain information from other sources and combine that with information we collect through our Services. For example, we collect information about you from third parties, including but not limited to social media platforms and publicly available sources.
We also receive personal data about you from various third parties and public sources, as set out below:
- Technical Data from the following parties:
- Analytic providers such as Google Analytics:
The information collected by Google will, if applicable, transferred by Google to countries outside the European Union and the European Economic Area, including in particular to the USA. However, Google has submitted to the Privacy Shield Framework. For further information regarding your rights as a result thereof, please see http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf.
Furthermore, we ensure that your IP Address is anonymised before the transfer to Google.
The legal basis for the use of Google Analytics is article 6 para. 1 subpara. 1 lit. f of the GDPR.
We also receive personal data from advertising networks such as Google Ads, which uses Google Analytics as explained above:
Regarding the transfer of the relevant information collected by Google, please see the corresponding statement on Google Analytics.
The legal basis for the use of Google Ads is article 6 para. 1 subpara. 1 lit. f of the GDPR.;
- Identity, Contact, AML / KYC Data from publicly available sources such as public court documents, the Commercial Register and the company houses and registers of other jurisdictions, and from electronic data searches, online KYC search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists, outsourced third-party KYC providers and from general searches carried out via online search engines (e.g. Google).
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when Liechtenstein law allows us to. Most commonly, we will use our personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you in respect of your customer relationship with us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will Use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of Data
Lawful Basis for Processing (including Basis of Legitimate Interest)
(i) To conduct due diligence checks on you (following your application to open and register an account).
(ii) To determine if we will enter into a customer relationship with you and, if positive, to register your account and on-board you as a new customer.
(d) AML / KYC Data;
(a) Performance of a contract with you.
(b) Necessary for compliance with our legal obligations
(c) Necessary for our legitimate interests, including to establish and verify:
- your identity and suitability for our Platform,
- the existence of any risks that you may present as a prospective customer,
- your ability to meet financial commitments,
- and ultimately, to enable us to take an informed decision on whether we should enter into a customer relationship with you.
(i) To establish and verify your identity.
(ii) To fulfil our other internal KYC policies and requirements, including, but not limited to a risk assessment.
(iii) To fulfil any external mandatory reporting obligations that we may have to the FIU, the FMA, the Commercial Register, the Police and any other (including overseas) public, regulatory, law enforcement or tax authority.
(c) AML / KYC Data;
(e) Enhanced KYC Data.
(a) Necessary to comply with a legal obligation.
(b) Necessary for our legitimate interests (for risk assessment purposes, to prevent and mitigate against fraud, to safeguard the reputation of our business).
To provide the Services, in particular:
(i) to match any orders for virtual financial assets in order to find an appropriate trade with another registered user;
(ii) manage payments, fees, charges and subscription costs; and
(iii) collect and recover money as may be appropriate; and
(iv) investigate any suspected fraudulent transactions
(a) Performance of a contract with you
(b) Necessary for our legitimate interest to collect and recover debts and prevent fraudulent transactions
For legal, tax and accounting purposes (e.g. reporting to tax authorities, and accounting record requirements).
(a) Financial; and
Necessary to comply with a legal obligation.
To detect, prevent and report fraudulent or suspicious orders/transactions.
(d) AML / KYC Data
(e) Enhanced KYC Data;
Necessary for our legitimate interests, including in particular to:
- protect the reputation of our business;
- avoid any complicity or association with fraud;
- report fraudulent or otherwise suspicious orders that we receive (or which later came to our knowledge) to relevant public authorities.
To manage our relationship with you, including in particular to:
(i) notify you about changes to our terms and conditions or privacy notices;
(ii) inform you about changes to our Platform (including the addition of new virtual financial assets that are available to trading);
(iii) deal with your enquiries, requests, complaints or reported issues;
(iv) provide you with customer support and assistance;
(v) contact you in relation to your account, portfolio and other related matters;
(vi) ask you to participate in a survey;
(vii) request feedback from you;
(viii) advise you of industry and legislative updates;
(ix) inform you about our events;
(x) provide you with information about our Platform;
(xi) administer your account;
(xii) provide you with any other information or materials that you have requested to receive from us;
(xiii) manage disputes with you or other players;
(xiv) to identify and correct issues with the Platform and/or the Site.
(i) Marketing and Communications.
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (for ‘customer care’ and service matters, to study how clients use our Platform, to assess our operations, to develop them and grow our business).
To administer and protect our business, including the Platform and the Site, (including troubleshooting, data analysis, testing, system maintenance, support, safety and security testing, reporting and hosting of data).
(a) Necessary for our legitimate interests (for running and administering our business, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
(c) Performance of a contract with you.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising which we serve to you.
To ensure that our content is presented in the most effective manner for you and your computer and devices, and in a user friendly manner.
(e) Marketing and Communications;
Necessary for our legitimate interests (to study how clients use our Platform, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics, including those collected by third parties such as Google Analytics and Google Ads, to improve the Site and Platform, marketing, customer relationships and experiences.
Necessary for our legitimate interests (to define types of clients and investors that have registered an account on our Platform, to keep the Site and the Platform updated and relevant, to develop our business and to inform our marketing strategy).
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at the following email address: firstname.lastname@example.org.
We strive to provide you with choices regarding certain personal data uses in relation to your account. Through your Account, Identity, Contact, Technical, Usage and Marketing and Communications Data, we can form a view on what we think you may want or need. We will send details as to how you may enhance your trading activity in relation to the account.
You may receive marketing communications from us (which may consist of newsletters, industry updates, mailshots, publications, promotional materials and/or information about our events) where:
- you provide your consent to receiving such marketing material; or
- you have an ongoing commercial or contractual relationship with us (e.g. where we consider you to be an active customer and user of the Platform); and
- provided you have not opted out of receiving marketing from us (see Your right to object in Section 10 below).
We will get your express opt-in consent before we share your personal data with any third parties (including our associated or related corporate entities) for marketing purposes. If consent is not provided, your personal data shall not be shared.
You can ask us to stop sending such advertising and marketing communications at any time by:
- following the opt-out links on any marketing message sent to you;
- contacting us at any time at email@example.com.
Where you opt out of receiving such communications, this will not apply to personal data processed or provided to us as a result of your entry into a customer relationship with us and our Platform for the other respective purposes.
Change of Purpose / Processing under a Different Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court or other enforceable orders.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose based on a legal provision requiring such processing, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 5 above.
- External third parties.
- Suppliers and external agencies that we engage to process information on our and/or your behalf, including to provide you with the information and/or materials that you have requested.
- Our subsidiaries, associates and agents where necessary to facilitate your relationship with us.
- The Liechtenstein Tax Administration (Steuerverwaltung), the Office for Data Protection, regulators, law enforcement agencies and other authorities who require reporting of processing activities, or may request information from us, in terms of applicable law and in certain circumstances.
- Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
- Other organisations where exchange of information is for the purpose of fraud protection or credit risk reduction.
- Debt recovery agencies who assist us with the recovery of debts owed to us.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way and for the same purposes as set out in this Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties access and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.
We may also disclose your data:
(i) if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority, or
(ii) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Bittrex Global or others, or
(iii) 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; or
(iv) if we have your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
7. INTERNATIONAL TRANSFERS
We do not generally transfer your personal data to entities outside the European Economic Area (“EEA”) except as may be necessary to: (i) enable your use of the Platform and our Services, (ii) fulfil our contractual obligations to you or exercise our contractual obligations against you, (iii) comply with our legal or regulatory obligations or (iv) assert, file or exercise a legal claim. Where we do need to transfer your personal data outside the EEA (whether for these stated purposes or any other purpose listed in Section 5 above), we will ensure a similar degree of protection is afforded to that personal data by ensuring at least one of the following safeguards applies or is otherwise implemented:
- 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 in a corresponding adequacy decision.
- In the absence of an adequacy decision, we will use standard contractual clauses that have been approved by the European Commission.
- Where we use providers based in the U.S., we may transfer data to them if they have submitted to the Privacy Shield Framework which requires them to provide similar protection to personal data shared between the Europe and the US.
In particular, we intend to share your personal data with Bittrex, Inc. of 800 5th Street, Suite 4100, Seattle, Washington, USA.
Such transfers of your personal data shall only take place subject to the appropriate safeguards. In particular we make use of Standard Contractual Clauses approved by the European Commission in order to transfer your personal data to our service providers indicated above.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
While no online or electronic system is guaranteed to be secure, we take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.
In relation to you visiting our Site, we use the industry standard encryption for the connection between our servers and the user's browser. Whether an individual page of our internet presence is transmitted through encryption can be seen by e.g. the shut padlock symbol in your browser’s address bar.
We have put in place appropriate technical and organisational security measures to prevent your personal data from being partially or entirely lost, accidentally or intentionally manipulated, used or accessed in an unauthorised way by third parties, altered, disclosed, or destroyed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Our security measures are improved in accordance with technological progress.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
How long will you use my personal data for?
Please note that we consider our relationship with you to be an ongoing and continuous customer relationship, until terminated.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (i.e. the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax, KYC and AML, and reporting requirements or obligations to which we may be subject and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.
By and large, our retention of your personal data shall not exceed the period of three (3) years from the date of the termination of your relationship with us (which would typically arise from the closure/de-registration of your account on the Platform). This period of retention enables us to use the data in question for the possible filing, exercise or defence of legal claims (taking into account the timeframe of applicable statutes of limitation and prescriptive periods). In certain cases though, we may need to retain your data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data).
In the event that Bittrex Global’s activities are held by competent legislators and regulators to amount to a ‘relevant activity’ under due diligence law, we will retain your AML and KYC Data for the duration of your business relationship with us and for a further period of ten (10) years following its termination. We may need to revise this AML retention period in the event of applicable legal or regulatory developments, but we will notify you if this is the case at the time.
In some circumstances, you can ask us to delete your data. See below for further information.
Kindly contact our DPO for further details about the retention periods that we apply.
Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you (anonymous data).
In order to collect, use, and share Aggregate Data (see section 3), we will even anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
10. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org . These rights are explained below.
No Fee usually required
You will not normally have to pay a fee to exercise your data subject rights.
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in the above circumstances.
What we need from you
We will 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 data subject rights). This includes your name, address, date of birth, and (in case of a passport/identity card being requested) its validity period.
Time limit to Respond
We try to respond to all legitimate requests within the period of one month from receipt of the request.
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 within four weeks and keep you updated.
Your Legal Rights
According to the GDPR, you have the right to:
i. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. In particular, you are entitled to receive information on the processing purposes, the categories of personal information, the categories of recipients to whom your personal data has been or is disclosed, the intended duration of storage, the existence of a right to correction or rectification, erasure, restriction of or objection to processing, transfer (data portability), the information’s origin (as far as it has not been collected on our part), as well as on the existence of automated individual decision-making including profiling. You may send an email to email@example.com requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed may incur a charge of € 10.00.
If the confirmation as stated above cannot be delivered to you within one month after receiving the request due to the complexity of the request, we will inform you of the extension of the deadline (of two months maximum) within one month after receiving your request, while providing reasons for the delay. The requested information will be delivered no later than within three months after receiving the request (article 12 para. 3 GDPR), about the third party or publicly accessible source from which we have collected your personal data.
ii. Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which occur during the course of your relationship with us.
iii. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:
- there is no need or legitimate reason for us continuing to process it;
- you have withdrawn your consent to the processing (where applicable);
- you have successfully exercised your right to object to processing (see below);
- we have processed your information unlawfully; or
- we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. These may include instances where continued processing is necessary in order to be able to:
- comply with a legal or regulatory obligation to which we are subject; or
- establish, exercise or defend our legal claims.
iv. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes (see Marketing in Section 5 above).
In some cases, the right to object will not lead to us no longer processing the personal data due to compelling legitimate grounds to further process your information overriding your interests, rights and freedoms. In such cases, we will demonstrate these grounds in a clear and specific manner.
v. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you contest the data’s accuracy, enabling us to verify said accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it (see subpara. iv).
vi. Request the transfer (data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information (see Section 4 subsection D) with regard to which you initially provided consent for us to use or where we used the information to perform a contract with you.
vii. Withdraw consent at any time where we are relying on consent to process your personal data (which will not generally be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected by the withdrawal of consent.
Kindly note that none of these data subject rights are absolute, and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.
viii. Right to file a complaint with the supervisory authority: If you are of the opinion that your personal information has been processed unlawfully or that your rights under the Act and/or the GDPR have been breached, you have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as in particular the supervisory authority in the place of your habitual residence or your place of work. In the case of Liechtenstein, this is the Datenschutzstelle (Office for Data Protection), Städtle 38, P.O. Box 684, 9490 Vaduz, Liechtenstein (https://www.datenschutzstelle.li). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance .
Your Choices Regarding Your Account Information
You may update, correct, or delete information about you at any time by logging into your online account. If you wish to delete or deactivate your account, please visit https://bittrexglobal.zendesk.com, but note that we may retain certain information as required by law or for legitimate business purposes, as further highlighted above.
If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to us using the details on our website.