BUX Crypto,Privacy Notice,Date: December 2019,Version 1.0,BUX Alternative Investments B.V is a private limited liability company (besloten vennootschap met beperkte ,aansprakelijkheid) with its statutory seat in Amsterdam, the Netherlands, registered with the Trade Register of the ,Dutch Chamber of Commerce in Amsterdam under number 76895327.
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introduction,BUX Alternative Investments B.V.
(hereafter named as “BUX Crypto”or “We”) values the ,privacy of our users and clients and strives to protect the privacy and the confidentiality of ,personal data that we use in connection with our mobile apps.,This privacy notice describes how we use your personal data (as a data controller).
We collect, ,use, disclose and otherwise process your personal data where this is necessary for the ,purposes identified in this Privacy Notice and only where permitted by the EU General Data ,Protection Regulation (GDPR) and local data protection laws (the Data Protection Rules).
We ,treat your personal data with the utmost care and security.
Please read this Privacy Notice ,carefully to understand how we process your personal data.,In this Privacy Notice we use a number of terms that have a specific meaning under the Data ,Protection Rules (such as “personal data”, “processing” and “data controller”).
Section 10 of this ,Privacy Notice contains an overview of these defined terms.,2.
Identity of data controller and contact details,BUX Crypto is the data controller in respect of the personal data we receive in connection to our ,Services.
BUX Crypto is a private limited liability company and has its registered office address ,at Spuistraat 114B, 1012 VA Amsterdam, Netherlands.,BUX Crypto has appointed a data protection officer.
In case of any questions in relation to our ,use of your personal data, you can contact our data protection officer using the following email ,address: dpo@getbux.com.,3.Personal data that we process,We collect and process the following personal data:,(a)Device information:Information about the device that you use, including your IP ,addresses and information about its operating system, platform and version.,(b)Your contact information:You are able, but not required, to link your email address to ,your account through the settings of our app.
If you decide to do so, we will process your ,email address.,(c)Your username:Your public username that is visible to other users of ourmobile apps ,and which you are using to log-in to your account to access our apps.,(d)Device ID: We process the unique ID number of your device.,(e)Usage Details:The date and time you use our mobile apps, usage patterns, traffic data ,and logs.,(f)Other personal information that you share with us: Any other information that you ,share with us through your use of our apps, such as chat messages.,(g)Your individual details:Name, address incl.
proof of address, date of birth, contact ,details (e.g.
email address, telephone number), nationality and gender.,(h)Your identification details:Identification numbers issued by government bodies or ,agencies (e.g., depending on the country you are in, social security, citizen service or ,national insurance number, passport number, ID number, tax identification number, ,driver’s license number), a copy of your identification document.,(i)Transactions and financial data:Credit card details, bank account details, ,cryptocurrency wallet details and details of transactions you carry out through the BUX ,Crypto application and of the fulfillment of any orders.,(j)Information on your trading knowledge and experience:Informationgathered ,through various questions asked during the client acceptance process in our BUX app.,(k)Personal data relating to criminal convictions and offences: BUX Crypto will, under ,certain circumstances, collect personal data relating to your criminal convictions, criminal ,offences (including, but not limited to, fraud).,Information collected in all categories are collected when opening a cryptocurrency exchange ,and wallet account with BUX Crypto.
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How we process and disclose your personal data,In this section, we set out the purposes for which we use personal data, explain how we share ,your personal data, and identify the “legal grounds” on which we rely to process the personal ,data.,These “legal grounds” are set out in the GDPR, which allows data controllers to process ,personal data only when the processing is permitted by the specific “legal grounds” set out in ,the GDPR.
The table below provides a description of the legal grounds that BUX Crypto relies ,on:,For processing ,personal data and ,special categories of ,personal data,Legal groundDetails,(1) Performance of our Processing is necessary for the performance of a contract to which ,contract with youyou are a party or in order to take steps at your request prior to ,entering into a contract.,(2) Compliance with a Processing is necessary for compliance with a legal obligation to ,legal obligationwhich we are subject.,(3) For our legitimate Processing is necessary for the purposes of the legitimate interests ,business interestspursued by us or by a third party, except where such interests are ,overridden by your interests or fundamental rights and freedoms ,which require protection of personal data.These legitimate interests ,are set out next to each purpose.,For processing special ,categories of personal ,data,(4) Your explicit You have given your explicit consent to the processing of those ,consentpersonal data for one or more specified purposes.,You are free to withdraw your consent, by contacting our Data ,Protection Contact.
However withdrawal of this consent may impact ,our ability to provide the services.,(5) For legal claimsProcessing is necessary for the establishment, exercise or defence,of legal claims or whenever courts are acting in their judicial ,capacity.,For what purposes do we use your personal data and what legal bases do we use to justify such ,use? We may use your personal data in the following ways.
For each use, we note the legal ,bases we use to justify each use of your personal data.
,(a)We require your personal data to be able to provide our cryptocurrency exchange and ,wallet provider services to you.
This includes the use of your personal data to allow you ,to use our BUX Crypto app, including for the execution of transactions upon your request ,when using the investment platform in our app, and to manage our relationship with you ,and all communications related thereto.,Use justification: ,(1) performance of our contract with you.
and ,(2) compliance with a legal obligation.,(b)For security purposes and to analyse and continuously improve our apps we may use ,your personal data for testing and improving our apps, the security thereof and for ,further tailoring our apps to our user’s needs (including by estimating and measuring ,usage patterns).
Only in very exceptional circumstances will we use personal data for ,testing purposes and if this is necessary, always in a closed and secured environment.
,We will also use your personal data to inform you when updates of our apps are ,available.
,Use justification: ,(1) performance of our contract with you.
and ,(3) for our legitimate business interests (to enable us to ensure the security of our ,systems and further improve our mobile apps).,(c)For regulatory compliance purposes (Wet ter voorkoming van witwassen en financieren ,van terrorisme, “Wwft”) we require personal data for the onboarding of you as a new ,client.
,Use justification: ,(1) performance of our contract performance.
and ,(2) compliance with a legal obligation.
,(d)To provide payment services providers (i.e.
Adyen) data about you to enable you to ,deposit money on your BUX Crypto account.
,Use justification: ,(1) performance of our contract performance.
and ,(2) compliance with a legal obligation.,(e)For marketing our products and services we may use personal data to contact you by ,email and send you push notifications in our apps.
We may also send you marketing ,communications through social media platforms, provided that you have given these ,platforms your consent to receive personalised advertisements.
During the registration ,process you have been offered a possibility to indicate that you would prefer not to ,receive such marketing.
In addition, you may opt-out at any time from any of these ,marketing communications through the user settings of our apps or by following ,instructions that we include in, for example, our newsletters.
We will only market our own ,products and services to you and will not provide your contact details to any third party ,for marketing purposes (with the exception of third parties processing personal data on ,our behalf (as our data processor), such as Facebook, Snapchat, Google and Twitter).,Use justification: ,(3) for our legitimate business interests (to enable us to promote our services and ,products).,(f)For marketing our products and services to potential new users we may disclose your ,email address or device ID (and no other personal data) to the social media platforms as ,mentioned on: www.getbux.com/gdprlistto enable these platforms to approach potential ,new users by creating a profile based on the personal data those platforms have ,collected from you.
Theseplatforms will act as a data controller and will only be able to ,use the personal data included in your social media profile and the profiles of the ,potential new users based on explicit consent given by you to the social media ,platforms.
Please be aware that the social media platforms mentioned on the above ,mentioned list may change from time to time.,Use justification: ,(3) for our legitimate business interests (to enable us to promote our services and ,products).,(g)To defend our legitimate interests and to change our business structure we may disclose ,personal data in connection with legal proceedings or investigations anywhere in the ,world to third parties, such as public authorities, law enforcement agencies, regulators ,and third party litigants (these third parties are not data processors on behalf of BUX ,Crypto and will process personal data for their own purposes).
We may also provide ,your personal data to any potential acquirer of or investor in any part of our business for ,the purpose of that acquisition or investment.,Use justification: ,(1) performance of our contract with you contract performance.
,(3) legitimate interests (to enable us to cooperate with law enforcement and regulators ,and to allow us to change our business).
and ,(5) for legal claims.,(h)To conduct certain checks on you, such as checks required for customer due diligence ,purposes and anti-fraud checks before we establish a relationship, and where required, ,during our relationship with you ► we and other organisations engaged by usfor this ,purpose may access and use your personal data to conduct credit checks and checks to ,prevent fraud, money laundering, terrorist financing and to establish whether you are a ,politically exposed person (PEP).
If false or inaccurate information is provided and fraud ,is identified or suspected, details may be passed to the relevant authorities including ,credit reference agencies and fraud prevention agencies.
We will record this.
Law ,enforcement agencies may access and use this information.
We, and other ,organisations that may access and use information recorded by such agencies, may do ,so from other countries.,Use justification:,(2) compliance with a legal obligation.
,(3) for our legitimate business interests (to assist with the prevention of crime and ,fraud).,Do we disclose your personal data to others and where is data being stored?,BUX Crypto stores your personal data on our IT systems located in the European Economic ,Area (EEA).
BUX Crypto engages various data processors for the processing of your personal ,data on our behalf, including IT service providers and other business service providers.,We have contracts in place with our data processors, which means that they cannot do anything ,with your personal data unless we have instructed them to do so.
They will not share your ,personal data with any organisation (unless legally required to do so) apart from us.
They will ,hold it securely and retain it for the period that we instruct.,BUX Crypto may be legally required to disclose your personal data in response to requests from ,regulators and law enforcement or security agencies, in which case these regulators and law ,enforcement or security agencies will be acting as a data controller as well.
BUX Crypto will ,always assess the legitimacy of such requests before disclosing any personal data and will only ,disclose the personal data required to comply with such a request.,We also disclose your email address or device ID to the social media platforms as mentioned ,on: www.getbux.com/gdprlistto allow them to market our mobile apps to potentially interested ,social media users, as described under (e) above.,From what sources do we collect your personal data?,We may obtain personal data from various sources, including:,●you directly through our BUX Crypto application.
,●Onfidoas our KYC provider, who we engage with for performing background checks that ,form part of our acceptance process.
and,●Chainalysis as our Cryptocurrency Transaction Monitoring provider, who we engage with ,for performing monitoring on all incoming and outgoing cryptocurrency transactions.,Do We use ‘cookies’?,Yes, we use cookies.
Cookies are small files that a site or its service provider transfers to your ,computer’s hard drive through your web browser (if you allow it) that enables the site’s or ,service provider’s systems to recognize your browser and capture and remember certain ,information.,You can find an overview of the cookies that We use in the table below:,CookiesPurpose,Functional cookiesWe use these functional cookies to help us remember certain actions ,you undertake on our website and platform.
We also use these ,cookies to help us compile aggregate data about site traffic and site ,interaction so that we can offer better site experiences and tools in ,the future.
We may also use trusted third-party services that track this ,information on our behalf.
,Analytic cookiesThese cookies help us understand your preferences based on ,previous or current site activity, which enables us to provide you with ,improved services.
,Third party cookiesWe use the Demographics Interests Reporting of Google.
We, along ,with third-party vendors such as Google use first-party cookies (such ,as the Google Analytics cookies) and third-party cookies (such as the ,DoubleClick cookie) or other third-party identifiers together to compile ,data regarding user interactions with ad impressions and other ,service functions as they relate to our website, but only if you have ,consented to these third-party cookies.
Please take a look at the ,Google advertising requirements on ,https://support.google.com/adwordspolicy/answer/1316548?hl=en,You can choose to disable all cookies.
You can do this through your browser settings.
Since ,every browser is alittle different, look at your browser’s Help Menu to learn the correct way to ,modify your cookies.
You can further set preferences for how Google advertises to you using ,the Google Ad Settings page.
Alternatively, you can opt out by visiting the Network Advertising ,Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.,If you do not consent to the use of cookies or turn cookies off, some of the features that make ,your site experience more efficient may not function properly.
,We honor Do Not Track signals and do not track, deploy or use cookies, or use advertising ,when a Do Not Track (DNT) browser mechanism is in place.
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Protection of your personal data,BUX Crypto has implemented appropriate technical and organisational measures to secure the ,processing of personal data.
These safeguards will vary depending on the sensitivity, format, ,location, amount, distribution, and storage of the personal data, and include measures designed ,to keep personal data protected from unauthorized access.
If appropriate, these safeguards ,include the encryption of communications via SSL, firewalls, access controls, separation of ,duties, and similar security protocols.,We restrict access to personal data to personnel and third parties that require access to such ,information for legitimate, relevant business purposes.,All our staff members, contractors and third parties who will have access to personal data on ,our instructions will be bound to confidentiality and we use access controls to limit access to ,individuals that require such access for the performance of their responsibilities and tasks.,We have information security policies in place and its security policies and systems are ,frequently audited.
We take the security of our IT infrastructure very seriously.
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Limiting collection and retention,We collect, use, disclose and otherwise process your personal data that is necessary for the ,purposes identified in this Privacy Notice or as permitted by the Data Protection Rules.
If we ,require personal data for a purpose inconsistent with the purposes we identified in this Privacy ,Notice, we will notify you of the new purpose and, where required, ask for your consentto ,process personal data for the new purposes.,We retain your personal data as long as you access and make use of our apps.
In any case we ,will retain your personal data and keep your profile active until you, or under exceptional ,circumstances, we, end our customer relationship with you.
After our customer relationship with ,you has ended, we will retain your personal data for a limited period of time.,Our retention periods for personal data are based on business needs and legal requirements.
,We retain personal data for as long as is necessary for the processing purpose(s) for which the ,personal data was collected, and any other permissible, related purpose.
For example, we ,retain your personal data after you have closed your account where necessary to comply with ,our legal obligations (including law enforcement requests), meet regulatory requirements, ,resolve disputes, maintain security, prevent fraud and abuse, or fulfil your request to ,“unsubscribe” from further messages from us.,We will retain de-personalized (aggregated) information after your account has been closed, but ,such information will no longer allow us to identify you.,Information that you have shared with other uses of our apps (e.g., updates or group posts) will ,remain visible for others after you have ceased using our apps.
Groups content associated with ,closed accounts will show the user at the source.
Your profile may continue to be displayed in ,the services of others (e.g., search engine results).,7.
Cross-border transfer of personal data,BUX Crypto may transfer personal data to, or permits access to personal data from, countries ,outside the European Economic Area (EEA).
These countries’ data protection laws do not ,always offer the same level of protection for personal data as offered in the EEA.
We will, in all ,circumstances, safeguard personal data asset out in this Privacy Notice.,Certain countries outside the EEA have been approved by the European Commission as ,providing essentially equivalent protections as EEA data protection laws.
The Data Protection ,Rules allow BUX Crypto to freely transfer personal data to such countries.,If we transfer personal data to other countries outside the EEA, we will establish legal grounds ,justifying such transfer, such as model contractual clauses, individuals’ consent, or other legal ,grounds permitted by applicable legal requirements.,You can request additional information about the specific safeguards applied to the export of ,personal data from our data protection officer.,8.
Your rights and complaints,We strive to maintain personal data that is accurate, complete and current.
You should contact ,our data protection officer using the contact details set out in section 2 of this Privacy Notice.,Under the GDPR, you have certain rights in relation to your personal data.
These rights are ,described below.
If you wish to exercise one of these rights, please contact our data protection ,officer using the contact details set out in section 2 of this Privacy Notice in case of any ,questions.
To ensure an efficient follow-up, we kindly ask you to specify your request and to ,indicate to which personal data your request relates.,You have the following rights (please be aware that certain exceptions apply to the exercise of ,these rights and so you may not be able to exercise these in all situations):,(a)Right of access: you have the right to obtain confirmation as to whether or not personal ,data concerning you is being processed, and, where that is the case, to obtain a copy of ,the personal data we maintain about you.,(b)Rectification:you may ask us torectify any inaccurate personal data that we process.,(c)Erasure:you may ask us to delete personal data that we no longer have a legal ground ,to process.,(d)Restriction:you may ask us to mark certain personal data as restricted whilst ,complaints are resolved and also ask for restriction of processing under certain other ,circumstances.,(e)Portability:You can ask us to transmit the personal data that you have provided to us ,and we still hold about you to a third party electronically.,In addition, under certain conditions, you have the right to:,●where processing is based on consent, withdraw the consent;,●object to any processing of personal data that BUX Crypto justifies on the “legitimate ,interests” legal ground, unless our reasons for undertaking that processing outweigh any ,prejudice to the individual’s privacy rights.
and,●object to direct marketing (including any profiling for such purposes) at any time.,These rights are subject to certain exemptions to safeguard the public interest (e.g., the ,prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).
We ,will respond to most requests within one month.,If you are not satisfied with our use of your personal data or our response to any exercise of ,these rights, we kindly ask you to first contact our data protection officer using the contact ,details set out in section 2 of this Privacy Notice.
In addition, you always have the right to ,complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, hereafter named ,as “AP”).
,The AP can be contacted at:,Postal address:,Autoriteit Persoonsgegevens,P.O.
BOX 93374,2509 AJ The Hague,The Netherlands ,Telephone:,(+31) -(0)70 -888 85 00,The AP’s up-to-date contact details can also always be found on the AP’s website through the ,following link: https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us,9.
Changes to the privacy notice,This Privacy Notice is subject to change at any time.
It was last changed on 24 June 2019.
If ,this Privacy Notice changes, we will update the date it was last changed and published the ,revised Privacy Notice on our website and in our mobile applications.
BUX Crypto advises all ,users to regularly check for updates.,10.
Terminology,Under the Data Protection Rules (including, but not limited to, the GDPR), the below terms have ,a defined meaning as set out inthe table below:,GDPRThe European General Data Protection Regulation (EU) 2016/679.
The ,GDPR is applicable in all EU member states as of 25 May 2018.,personal dataAny information relating to an identified or identifiable natural person (e.g.
a ,person whose identity can be established reasonably without ,disproportionate effort by means of name, address and date of birth).
By way ,of example but not limitation, any contact information, emails, IP addresses, ,user profiles, and transaction details.,processing (of Any operation or any set of operations concerning personal data, including ,personal data)in any case the collection, recording, organisation, storage, updating or ,modification, retrieval, consultation, use, dissemination by means of ,transmission, distribution or making available in any other form, merging, ,linking, as well as blocking, erasure or destruction of personal data.,data controllerThe legal person, administrative body or any other entity which, alone or in ,conjunction with others, determines the purpose of and means for ,processing of personal data.,data processorThe person or body which processes personal data on behalf of the data ,controller, without being subject to the data controller’s direct control.,special Any personal data that provides information on persons’ religious or ,categories of philosophical beliefs, race, political opinions, health, sexual life or ,personal datamembership of trade unions, or, for the purpose of this privacy statement, ,criminal convictions or offences.