For the purposes of EU data protection laws (“Data Protection Law“), Cointopia is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).
- WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
The categories of information we collect can include:
- Information you provide to us directly. We may collect personal information when you register as an investor, such as your name, phone number, address, birthdate, identification information (e.g., photo of government-issued identification), photo of yourself, proof of address, Social Security Number, username and password, investment experience and objectives, and email address. We may also collect information when you sign up for our mailing list, fill out a contact form on the Service, or otherwise communicate with us. We may also collect any communications between you and Cointopia and any other information you provide to Cointopia.
- Information we receive from third parties. From time to time, we may receive information about you from third parties and other users, such as our business partners. We may also collect information about you that is publicly available.
We use this information to operate, maintain, and provide to you the features and functionality of the Service, to process your registration, to verify your identity or status as an accredited investor, to prevent fraud or other unauthorized or illegal activity, to diagnose or fix technology problems, as well as to communicate directly with you, such as to send you email messages and push notifications. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.
We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to uniquely identify your browser, mobile device, or your account), and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
- SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
- We may share your personal information with:
- Third party service providers that perform services on both our behalf and on your behalf, as needed, which may include preventing fraud or other illegal activity, such as anti-money laundering services, verifying your identity and status as an accredited investor, identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, web hosting, or providing analytic services. When we provide your information to service providers who provide services on your behalf to prevent fraud or other illegal activity, such as anti-money laundering services, or to verify your status as an accredited investor, we put contractual protections in place to limit their use and disclosure of your information, and they will possess the information for a limited time to perform the services;
- Other companies and brands owned or controlled by Cointopia and other companies owned by or under common ownership as Cointopia, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy;
- Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
- Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Cointopia, our visitors, or others.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
- LEGAL BASIS FOR PROCESSING IN THE EU
In the EU, the purposes for which we process your personal data are:
- the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
- where it is necessary for compliance with our legal obligations laid down by EU law;
- where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
- to contact you and respond to your requests and enquiries;
- for business administration, including statistical analysis;
- to provide the Services to you;
- for fraud prevention and detection; and
- to comply with applicable laws, regulations or codes of practices.
We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under Data Protection Law to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.
- CONTROL OVER YOUR INFORMATION
Profile and Data Sharing Settings. You may update your profile information and may change some of your data sharing preferences by visiting your “Profile” page or by contacting us at firstname.lastname@example.org.
How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
- THIRD-PARTY TRACKING AND ONLINE ADVERTISING
Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share or we may permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
Social Media Widgets and Advertising. Our Service may include social media features, such as the Facebook Like button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter, or other widgets. These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.
- Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
- Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
- Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
- Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
- HOW WE STORE AND PROTECT YOUR INFORMATION
Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. For example, we use Security Sockets Layer (SSL) encryption technology to encrypt sensitive personal information we collect. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above “WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?“), except if required otherwise by law.
- FOR RESIDENTS IN THE EU AND SWITZERLAND
If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:
- Right of access. The right to obtain access to your personal data.
- Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
- Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- CHILDREN’S PRIVACY
Cointopia does not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
- LINKS TO OTHER WEB SITES AND SERVICES
The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
- HOW TO CONTACT US