Privacy Policy

Last Updated: June 14, 2018

General

Spotcoin and its affiliates (hereinafter, "Spotcoin", "we", "us" or "our") are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms and Conditions of Use) collects, uses, discloses and protects your information. We define "Personal Information" as information which identifies you personally, e.g. your name, address, e-mail address, trades etc.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some circumstances, we may provide you with additional notice, including, sending you an email notification. We strongly encourage you to review the Privacy Policy whenever you access or use Spotcoin to stay informed about our information practices and your privacy rights and choices.

The purpose of this Privacy Policy is to inform you of:

  1. The kinds of Personal Information which we may collect about you and how it may be used;
  2. Our use of information regarding IP Addresses and our use of cookies;
  3. Any disclosure of Personal Information to third parties;
  4. Your ability to correct, update, restrict use, ask us transfer and/or delete your Personal Information;
  5. The security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control;
  6. Your rights to lodge a complaint.

Gathering and Use of Personal Information

We may collect your Personal Information if you use the Website, open an Account to use the Platform (also noted as "website" or "service") or perform any Transactions on the Platform. The types of Personal Information which we collect may include:

  1. Your name, your date of birth, your mailing address, your telephone number, and email address;
  2. Your government identification numbers, such as your social security number or state-issued identification number;
  3. Your banking details including account numbers, credit card numbers and virtual currency account information.

We may use your Personal Information for the following purposes:

  1. To allow you to open and operate an Account on the Platform;
  2. To enable you to complete Transactions on the Platform;
  3. If you contact us, to reply to your queries;
  4. To analyze use of our Website;
  5. As required for regulatory purposes;
  6. To provide you with information about products and promotions that may be of interest to you, from ourselves and third parties, although only if you have specifically agreed to receive such information;
  7. For market research e.g. surveying our Users' needs and opinions on issues, such as our performance, etc. We will process your Personal Information only for the purpose(s) for which it has been provided to us.

LEGAL GROUNDS FOR PROCESSING

Our processing of your Personal Information is based on the following legal grounds:

  • consent – where you have consented to our use of your personal information;
  • legal obligation – where we need to use your personal information to comply with our legal obligations (identification and verification of your identity to manage the risk of our client base and to ensure you fall within our acceptable risk profile);
  • contract performance – where we need to collect and use your personal information to perform the services to you (delivering SPOT tokens for those performing Transactions on the platform);
  • legitimate interest – it is our legitimate interest to promote our business, develop our communication with the user, build our community in order to further develop, test and improve our service and website. The latter involves analyzing your use of our Website and undertaking market research. If you are a data subject protected by the GDPR you may have rights to restrict or object to this processing, however, please note that this may adversely affect the service we offer as well as our ability to effectively communicate with our users.

IP ADDRESSES

We may collect information about your computer, including where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and will not be used to identify any individual other than the same individual who is applying/submitting/using our service.

COOKIES

We use a browser feature known as a "cookie", which assigns a unique identification to your computer. Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Website. The information collected from cookies allows us to determine such things as which parts of our Website are most visited and difficulties our visitors may experience in accessing our Website. With this knowledge, we can improve the quality of your experience on the Platform by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalised experience when using our Website.

We use third-party service provider(s), Sum & Substance to assist us in better understanding the use of our Website. Our service provider(s) will place cookies on the hard drive of your computer and will receive information, that we select, that will educate us on such things as how visitors navigate around our Website, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Website and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Website. Our service provider(s) is/are contractually restricted from using information they receive from our Website other than to assist us.

By using our Website you are agreeing that we may use cookies for the purposes set out above.

TRANSMISSION, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

The transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks may not always be secure, and is subject to possible loss, interception, or alteration while in transit. Accordingly, Spotcoin does not assume any liability, without limitation, for any loss or damage you may experience or costs you may incur as a result of any transmissions over the Internet or other publicly accessible networks, including but not limited to transmissions involving the Platform or e-mail with Spotcoin containing your personal information. While Spotcoin will take commercially reasonable efforts to safeguard the privacy of the information you provide to Spotcoin, and will treat such information in accordance with Spotcoin’s Privacy Policy.

Your Personal Information is being stored at our Servers and solely Authorized Employees has/have access to your Personal Information.

We provide all organizational and technical measures for the data protection, which are required under the GDPR, including encryption and pseudonymization of your Personal Information.

We take necessary and sufficient organizational and technical measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

Immediate access to the personal information is allowed only to our Authorized Employees involved in providing the services. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.

Spotcoin is implementing state of the art security for the securing of all exchange information and stored value in accordance with Cryptocurrency Security Standard (CCSS). This includes software and hardware components that are identified by digital currency experts as the best course of action for an exchange, as well as coin throttling.

LIMITATION OF LIABILITY

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, trusted service providers and contractors for these limited purposes. We may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organization.

We may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law. Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for Spotcoin, unless otherwise required or permitted by law.

We will ensure that any third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

SHARING YOUR PERSONAL INFORMATION WITH THIRD-PARTTIES

Your privacy is important to us.

We share your personal information with Sum and Substance, company conducting KYC for our ICO.

We only share your information with third parties as outlined in our Privacy Policy or as required to do so by law enforcement, court order, or in compliance with identity verification or legal reporting obligations in Spotcoin’s sole judgment.

The company will keep records of all transfers of Personal Information to third parties and this information, where possible, can be provided to you.

Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for Spotcoin, unless otherwise required or permitted by law.

We may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law.

CORRECTION⁄UPDATING⁄DELETION OF PERSONAL INFORMATION

You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at: [email protected].

You may also request the deletion or destruction of both the Account and Personal Information by sending an email to us at: [email protected]. However, please note that if you close your account, we may retain your information as required by law or for our legitimate business purposes, such as to collect fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or enforce our user agreements.

SECURITY

We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Only authorized personnel of Spotcoin have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments. In the event of a personal data breach or the failure of the measures of protection of such information, we will immediately notify you without undue delay.

DATA PROTECTION OFFICER

Our Data Protection Officer ensures that Spotcoin is compliant to this privacy policy. You can contact the Data Protection Officer on [email protected].

RETENTION OF PERSONAL INFORMATION

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our record keeping obligations, we will retain Accounts and Personal Information for at least a period of five years after they are closed by Users. Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.

DISPOSAL OF PERSONAL INFORMATION

Once we do not have any obligation to provide you with a service you requested, nor an obligation to hold Personal Information for regulatory or legal purpose, we will anonymise or dispose of your Personal Information in line with acceptable industry and security standards so that this information cannot be subsequently retrieved and associated with you.

LINKS

There may be links from our Website to other websites and resources provided by third parties. This Privacy Policy applies only to our Website. Accessing those third-party sites or sources requires you to leave our Website. We do not control those third-party websites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third-party websites, including without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those websites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.

MARKETING

You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise the right at any time by contacting us at [email protected].

CHANGES

Our Website Our Website policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Spotcoin. If we change this Privacy Policy, will take steps to notify all users with a notice on our Website and will post the amended Privacy Policy on the Website. If we consider that your rights may be affected by any such changes, we will request you confirm your consideration and acceptance prior to our continued relationship with you. content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Spotcoin. If we change this Privacy Policy, will take steps to notify all users with a notice on our Website and will post the amended Privacy Policy on the Website. If we consider that your rights may be affected by any such changes, we will request you confirm your consideration and acceptance prior to our continued relationship with you.

CONTACT US

If you have any questions, comments, or concerns regarding our Privacy Policy, please contact us via E-Mail at [email protected].

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