Privacy policy Cointobuy.io

This privacy policy ("Privacy Policy") explains how Cointobuy.io website at https://www.cointobuy.io ("Website", "we", "us", "our"), uses and disclose personal data gathered while users surf through our web pages, and the steps we take to ensure that the personal data are well protected.

When you use our Website and the related contents, you, therefore, acknowledge to the terms of this Privacy Policy and we do assume you have exercised your due prerogatives. Please do ensure to read through our Privacy Policy each time there is an update to ensure you fully comprehend and accept the terms of engagement with our Website, as information requested and submitted through our web pages are under the influence of the terms of this Privacy Policy. If you do not accept any part of the terms stated here, please refrain from using any of the services, contents, and business associated with our Website.

1. DATA WE COLLECT ABOUT YOU

To us, Personal Data or Personal Information about users will always include details about an individual that represents the identity of such an individual. We try as much as possible to exclude anonymous data. Therefore, as long as you use our Website and its resources, we reserve the rights to collect, transfer any of the constituents of these data such as Contact data, Profile data, Technical data, Usage Data and Marketing and Communication Data which as a composite represent the unique identity of such a user on our Website.

Other details of the individual parameters of such data collected are as follows:

  1. Contact data: may include such information as email address, residential address or phone numbers;
  2. Profile data: may include such data as username, account number or password;
  3. Technical data: in this category of data to be collected, information regarding user's Internet Protocol (IP) address used in accessing the internet and consequently, our Website, are of vital importance to us, including other details such as user's login details, internet browser details, user's location and time zone, browser plug-in details, operating system of user's device (computer or mobile device), information about user's visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website at https://www.cointobuy.io (to include date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page and any information of yours related to contact our customer service team;
  4. usage data, such as the information you viewed or searched for and information about how you use our Website; and
  5. marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication responses.

Data regarding aggregated information such as statistically and demographic data can also be collected, used and shared for any purpose as dimmed fit by us (https://www.cointobuy.io). These sets of data may be derived from personal data without including details that reveal the identity of the user, as such, this set of data are not considered personal data in law. An example will be to monitor user activities and specific interactions with the features of our website. However, if any specific statistical or demographic data is tied to user's personal data such that it impacts their personal information, the whole data cluster will be treated as personal data and we would abide by the strict guidelines and codes of this privacy notice.

Other details that could be considered personal data that are in a special category and infringes on race, social, political, religious, sexual, medical/general information about your health, philosophical beliefs and biometric data are not collected.

2. METHODS OF DATA COLLECTION

We employ different methods to gather or collect data for users and the following methods detail the process:

  1. Direct interactions. We provide forms through which our users can interact with us and provide the information requested directly by simply filling out the forms to give out details such as your identity, contact and financial data or you may correspond with us via post, phone, email, Skype and other messenger options. This data to be provided include personal data that gets stored on our database when you sign up on our Website, subscribe to our publications, request marketing to be sent to you, enter a competition, promotion or survey, or give us some feedback, including report a problem with our Website;
  2. Automated technologies or interactions. Our website operates using certain automated technologies called cookies, server logs and other similar technologies, and you may come across a few of them while interacting with the website interface. These programs are tasked with the responsibilities of collecting technical data regarding your equipment, browsing actions and patterns. Therefore, as you use our Website, be sure to know that we operate this cookie even outside our own web environment on websites who also use our cookies to obtain technical data.
  3. Third parties or publicly available sources. Other sources of user's personal data we may have access to may come from the public domain, or third parties (such as analytics providers, advertising networks, search information providers and providers of technical, payment and delivery services) or other websites we operate or the other services we provide.

Where it may be required of us to collect user's personal data by law, or through the agreement we must have established with the user, and the user refuses to cooperate with the terms of the agreement, thereby limiting us, we have the reserved rights to discontinue our offer of services to such users at any given time with prior notice should this be the case.

3. USE OF YOUR PERSONAL DATA

We can only use your personal data as the law deems it fit for us too. This implies that we are liable outside the juristic validity of usage of such data. In this regards, we will use the data for the following:

  1. when/where we are obligated to perform the agreement, we are about to enter into or have entered into with you;
  2. when/where it is indeed required for our legitimate interests or those of a third party, affiliated to us and your interests and inclusive of instances where fundamental rights do not override those interests;
  3. when/where we need to oblige to a legal or regulatory sanction.

Our business interest and how we conduct or manage the activities of our business services constitute our Legitimate interest. Our duty to you is to ensure that there is a balance on the impact this has on you in both positive and negative ways to ensure that your rights are not infringed upon as we conduct our business using personal data we collect for our legitimate interest. 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).

We generally do not have to rely on user's consent as a basis before data collected as personal data are processed, except in cases related to sending third-party direct marketing communications to you through email or text. However, you have the right to withdraw consent to marketing at any given time by contacting us.

Our use of your personal data covering your identity, contact, profile, technical and usage data as a yardstick to determine what kind of service you require of us is a part of our marketing service system to decide how to streamline our services to suit you better. For time to time, you may receive communications from us requesting for this information unless you have opted out of this service section.

You are in total control of marketing messages and can opt out at any given time by using the opt-out link accompanying the marketing message that may be sent to you, or by contacting us directly.

Our collection of your personal data can only be used for the purposes that align with our original intentions, if you do need further clarifications of these intentions, it would be your prerogative to contact us.

4. COOKIES AND SIMILAR TECHNOLOGIES

Our use of cookies and other tracking technologies like many other websites is strictly to facilitate your user experience each time you visit our Website, by providing you with streamlined and customized features suited to your browsing preferences. You are at liberty to instruct your browser to reject all or certain types of browser cookies. Do note that when you disable or refuse to accept cookies from our Website, it may limit your accessibility features on our Website and hence affect the overall performance and give you a poor experience. For more information about the cookies we use, please see our Cookie Policy.

5. DISCLOSURE OF YOUR PERSONAL DATA

The exposure or disclosure of your personal data is strictly in coherence with the outline specifications of this Privacy Policy, hence your personal data will not be sold or disclosed with other companies for commercial purposes.

We are obliged to disclose any personal data we have collected; (a) when we are permitted or required by law to do so; or, (b) when trying to protect against, prevent, investigate illegal activities such as actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) when we are trying to enforce the applicable terms of service or other agreements; or (d) when we are protecting against any sort of violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) when you have given us your consent to do so. Finally, other instances where your personal data may be transferred may include the presence of a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.

Other instances where your personal data may be disclosed include the involvement of our contractors (who may be located outside of the European Area ("EEA"), their responsibilities are to further process these data for the sole purpose of processing transactions or collecting fees or identifying you, and all in the bid to improve your user experience while using our Services. A further benefit of this disclosure may include improving business support functions in compliance with this Privacy Policy while ensuring utmost confidentiality and security. Moreover, these transfers to our contractors are covered by the service agreements with such contractors.

Anytime such a data transfer transaction occurs outside of the EEA, the following measures are taken to ensure equivalent protection status:

  1. 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
  3. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

6. DATA SECURITY

We are obliged to adhere strictly to the accepted industry standards in order to ensure the protection of your personal data from being missing/stolen/lost or access/disclosed either by accident or through unauthorized access. We guarantee that only our authorized employees, agents and contractors (who are in compliance to the terms of our service agreements) have access to the personal data we collect and store.

Ours and our third party systems enable us to store and process personal data including those outside the jurisdiction of the EEA in other countries. Each time you access our Website, and submit data or when we collect the technical data from your browsing habits, we take it that you (and representative authority) have consented to make the transfers and the processing of these relevant data both within your jurisdiction and those of other countries which may have different privacy laws. We, therefore, will take necessary steps to ensure that your private and personal data are kept as securely as possible in accordance with the terms of this Privacy Policy.

All payment transactions are to be kept encrypted to prevent leakage of transaction data to unauthorized personnel or third-parties. In a situation where a password is being provided by our Website, or you chose one for yourself, you are liable to the breach in your account should you not keep it safe from others. To reiterate further, you are to keep your password, pin codes and all security access files safe and not share with anyone at any time.

The internet as vast, has different people with ulterior motives and often times malicious, which makes it subject to security breaches and data leakages, we, therefore, want to warn you that data submission or transfer over the internet may not be secure and can also be intercepted in cases where your connection is being monitored by other parties. As much as possible, we are working to ensure that the data submitted to us at any given time, stay secure, and do commit ourselves to try as much as possible to avoid any breach from our end.

7. DATA RETENTION

Data stored on our servers and databases are only held for as long as they are required for the purpose which they are collected. While in some cases and depending on data categories, this period may last for as long as we have a business relationship with you. It may also last beyond that period, as long as the relevance of the data does not exceed the pursuit of a legitimate business interest such as in the case of an audit and in compliance with other legal obligations and conflict resolution purposes that would not infringe on the personal data submitted or the terms of this Privacy Policy.

In order to determine the appropriate length of time needed to hold on to your personal data, we take few things into consideration:

  • Amount of data disclosed
  • The purpose of collection of the personal data set
  • The sensitivity of the data disclosed
  • The potential risks of hard to the user from unauthorized access, use or disclosure of such data
  • The legal constraints attached to such data sets

When we no longer need the data we collected from you, we are most certain to destroy them, or convert them into an anonymous state such as pure statistics with nothing linking back to you as an individual.

8. THIRD-PARTY LINKS

The structure of this Privacy Policy applies only to the contents of our Website to include products and services offered only. However, if you were to navigate from our website to another website that offers or promotes our services, you do well to review the privacy policy provided by those service providers to avoid conflict of interest.

9. AGE LIMITATIONS

Our services and the general use of our Website are exclusive to those who are of the legal age specifications, that is 18 years and above. If you are aware of anyone who provides their personal information on our website and is under the age of 18, please do let us know through our contact information so as to take necessary steps towards that action.

10. YOUR RIGHTS

The following rights have been reserved for you – our clients and visitors to our Website, and are only conditional under the data protection laws that are related to your personal data:

  1. right to request access to your personal data. This right grants you access to copies of your personal data submitted to us and also to check if we are following due legal procedures in processing or handling the data;
  2. right to request correction of the personal data that we have stored about you. This particular right gives you the opportunity to make corrections on whatever data or information we have about you that may be inconsistent, incorrect or out-of-date. However, this does not overrule our verification system;
  3. right to request erasure of your personal data. The right to erase any form of data stored about you is exclusive and affords you the opportunity to tell us to delete, remove or permanently destroy any stored personal data about you when you have successfully exercised your right to object to the processing of your data if the unlawful processing of your data has been detected. However, under such circumstances where the law prevents us from obliging to your request, we will notify you and proper actions to be taken;
  4. right to object to the processing of your personal data. When a third party is involved in the processing of your personal data, and we rely on such entities for legitimate interests, which may invariable in one way or the other impact your human rights, you have the liberty to object to the processing of such data category or of its entirety. More so, in the case where your personal data is being processed by us for marketing purposes and you feel the need to object, you are at liberty to do so as it is within your privileges. However, there are instances that may override your rights and freedom of which the processing of your data are pertinent under legal frameworks;
  5. the right to request restriction of processing of your personal data. Under this privilege, you are entitled to request a suspension on processing your personal data for the following reasons: (a) if there is a need to reestablish data facts or accuracy; (b) in the event you feel we are using your data unlawfully and still want us to retain the data but however, stop processing it; (c) in a situation where we would be required to hold back your data per your request even if we no longer require the data structure, for the sakes of establishing, exercising or defending legal claims that may surface; or (d) if you have outrightly objected to our use of your personal data but however, if we need to verify whether we have any established overriding legal grounds to use it;
  6. the right to request the transfer of your personal data to you or to a third party. As per your request, you have the reserved right to request that we provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. You should, however, be aware that this right applies only to automated information of which you had provided consent for us to use or where we used the information to perform an agreement with you; and
  7. right to withdraw consent at any time where we may be relying on your consent before we process your personal data. However, this will not override the processing of any personal data done within the confines of the law before you withdraw your consent. Moreover, when you do withdraw your consent it becomes imperative that we withdraw certain privileges to services on our Website. Notwithstanding, we will provide advisory support if this is the case at the time you withdraw your consent.

Access to your personal data or exercising your rights according to this Privacy Policy or binding legal standards does not require you paying any fee. However, a fee may be levied if the circumstance surrounding your request is unfounded, repetitive or excessive. More so, if we feel the need to, we reserve the right to decline your request under these circumstances.

Where/when necessary we would place a request across to you to provide us some specific information that will be used to confirm your identity to make sure you have the right to access your personal information/data when a request is made. We have set this measure up to prevent illegal access to your personal data and prevent disclosing your data to impersonators.

We will ensure that response to your request for your personal data at any given time is prompt and this is usually within the time frame of a month. While it may take longer time in rare cases depending on the complexity of the request, we still do our best to ensure that you are served promptly. If there is a need for unusual delay whatsoever with your request, we will keep you informed.

11. CHANGES TO THIS PRIVACY POLICY

Changes that may be made to this Privacy Policy are exclusive rights of https://www.cointobuy.io administrators and therefore will update this Privacy Policy unilaterally and without prior notice. However, in the event that there is an updated version of this Privacy Policy, the general public will be informed by posting relevant changes made on our Website. More so, if the changes made in any way have an impact on your privacy rights, we will ensure to update you via emails. If at any point in time you disagree to the changes made or with the overall context of this Privacy Policy, you should stop using the Website and any related service provided. We would take any further use of the website as an agreement to the set terms or future changes made to this Privacy Policy.

This version was last updated on 25.05.2018 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 [email protected]