Privacy Policy

Privacy policy

This privacy policy ("Privacy Policy") describes how Bitsgap Holding OÜ, registry code 14004763, address Rotermanni tn 18, 10111, Tallinn, Estonia ("we" or "us"), as a data controller, collect, use and disclose personal data, and the steps we take to protect such personal data, provided by you or collected by us either on the website https://www.bitsgap.com/ ("Website") or when you use the services or products that we provide or may provide in the future ("Services").

By using Website, our Services or any other related product you signify your acceptance of this Privacy Policy. Please read this Privacy Policy each time before using the Website or the Services and before submitting any information to us. If you do not agree with the terms of this Privacy Policy, do not access or use the Services, the Website or any other aspect of our business.

1. DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data).

2. METHODS OF DATA COLLECTION

We use different methods to collect data from and about you including through:

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, including to provide you with the Services. In this case, we may have to cancel the Services you have with us but we will notify you if this is the case at the time.

3. USE OF YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Legitimate interest means the interest of our business in conducting and managing our business to enable us to provide you with the best Services and the best and most secure experience. 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).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We may use your identity, contact, profile, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contact us at any time.

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. 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.

4. COOKIES AND SIMILAR TECHNOLOGIES

Like most Internet sites, our Website may use cookies and similar technologies to enhance your user experience and provide customization and useful features to our Website and Services. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. DISCLOSURE OF YOUR PERSONAL DATA

Except as outlined in this Privacy Policy, your personal data will never be sold or disclosed with other companies or organizations for commercial purposes or otherwise.

We reserve the right at all times to disclose any personal data that we have collected when: (a) permitted or required by law; or, (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) trying to enforce the applicable terms of service or other agreements; or (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so. Finally, we may transfer personal data to a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.

We may disclose your personal data to our contractors (who may be located outside of the European Economic Area ("EEA")) to process it for us, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks, based on our instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security requirements. In addition, transfers to our contractors are covered by the service agreements with such contractors.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

6. DATA SECURITY

We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.

We store and process data, including personal data, in the EEA and possibly in other countries through third parties that we use to operate and manage the Services. When you access or use our Websites or the Services, or otherwise provide personal data to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of personal data in and to the other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.

7. DATA RETENTION

We will retain your personal data only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations (e.g. taxation purposes), resolve disputes and enforce our agreements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When your personal data is no longer required, we will destroy, delete or convert it into an anonymous form.

8. THIRD-PARTY LINKS

The privacy practices set forth in this Privacy Policy apply to the Website and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by us) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.

9. AEG LIMITATIONS

We do not allow use of our Services and the Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

10. YOUR RIGTHS

Under certain circumstances, you have following rights under data protection laws in relation to your personal data:

You will not have to pay a fee to access your personal data (or to exercise any of the other 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 these circumstances.

We may 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 rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. 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 and keep you updated.

11. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Website. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should stop using our Services, the Website or any other aspect of our business. Your continued use of the Website or our Services constitutes your agreement to all such changes.

This version was last updated on 23.10.2018 and historic versions can be obtained by contacting us.

12. CONTACT AND COMPLAINTS

For further information regarding the Privacy Policy and related practices or in case of any suspected infringement of your privacy, please contact us at support@bitsgap.com or by post: Bitsgap Holding OÜ, address Rotermanni tn 18, 10111, Tallinn, Estonia.

If you reside in the EEA, we will be the controller of your personal data provided to, or collected by, or processed in connection with our Services. You have the right to make a complaint at any time to the Estonian Data Protection Inspectorate (address 19 Väike-Ameerika St., 10129 Tallinn, Estonia, e-mail address info@aki.ee, phone +372 627 4135). We would, however, appreciate the change to deal with your concerns before you approach the Data Protection Inspectorate, so please contact us in the first instance.