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privacy

Privacy Policy of CoinReview

Last update: 11th of September 2021

CoinReview lending platform (hereinafter, "CoinReview", "we", "us" or "our") are committed to protect and respect your privacy.

This Privacy Policy  governs the collection, processing and use of Users' Personal Information of  CoinReview platform.

Basic Definitions

1. Here are the basic definitions used in this Privacy Policy:

 Personal Information (personal data)

It is  any information which identifies you personally or which may help us to identify you (e.g. your name, address, e-mail address, trades etc.).

 Data subject

It is an identified or identifiable person (our User).

Data controller 

It is a company which determines purposes and means of personal data processing.

 Data processor

It is a company which processes personal data on behalf and upon instructions of the Data controller.

Personal data processing

It is any operation or set of operations performed on personal data (e.g., collection, storage, use, disclosure erasure).

2. Other terms, not defined above, have the meanings as defined in the applicable data protection legislation.

Purpose of this Privacy Policy

 The purpose of this Privacy Policy is done to inform about:

  1.  CoinReview website.
  2.  All kinds of Personal Information which CoinReview may collect about its users, the reasons for collecting this information, how it may be used and for how long CoinReview  will keep it.
  3.  The use of information by CoinReview  regarding IP addresses and use of cookies by users of the platform.
  4.  The disclosure of Personal Information to third parties.
  5.  The information on international data transfer.
  6.  The user’s ability to access, correct, update, restrict use, ask CoinReview platform to transfer and/or delete his/her Personal Information.
  7.  The application of user’s Personal Information by CoinReview.
  8.  The security measures that CoinReview has to prevent the loss, misuse, or alteration of Personal Information under  control of CoinReview.
  9.  The rights of the users to lodge a complaint.

Gathering of Personal Information

CoinReview may collect Personal Information of its user when he/she uses CoinReview website and opens an Account to use CoinReview website or perform any actions on it. This is defined as a collection for the purpose of provision of service(s) of CoinReview. 

Please note that if the user refuses to share his/her Personal Information for these purposes CoinReview can limit the services to the user.

 Types of Personal Information

The types of Personal Information which CoinReview collects may include such data as:

  1.  The name of the user.
  2.  Photographic identification of the user.
  3.  Details from ID documents of the user (driver license, passport), number of the document, date of issue and expiration, photographic identification, address etc.
  4.  Address of the user.
  5.  Phone number of the user.
  6.  Email address of the user.
  7.  User’s IP address, Browser and Operating System information, geolocation details.
  8.  User’s banking details including account numbers and payment card data.
  9.  Date of birth of the user.
  10.  Transactions details.

Use of Personal Information

1. CoinReview will process a user's Personal Information only for the purpose(s) of providing the service(s) that user asks CoinReview to provide, to satisfy the legal obligations stemming from regulatory obligations that arise from providing the service(s) and legitimate interest of CoinReview.

2. Based on legal obligations of CoinReview and legitimate interests, CoinReview may request other documents for identity verification of users and the sources of their funds confirmation for the purposes of money laundering and fraud prevention. 

Purposes of Use of Personal Information 

 CoinReview may use user’s Personal Information for the following purposes:

  1.  To allow users to open and operate an Account on the website.
  2.  To allow users to complete the transactions on the website.
  3.  To reply to a user's queries if he/she contacts CoinReview.
  4.  To analyse the use of the CoinReview website.
  5.  If it is required for regulatory purposes:

         for Taxation, 

         prevention of Money Laundering, 

         prevention of Fraud, 

         adherence to Company statistical reporting obligations etc.;

6. To provide users with information about the products and promotions that may be interesting to users, from CoinReview and third parties. It is done if the user has specifically agreed to receive such information.

7. For market research to determine Users' needs and opinions on issues, such as performance of CoinReview and etc. Unless consented, user’s data for this purpose would be anonymised.

 Use of Children's Personal Data

1. Services of CoinReview are exclusively offered to individuals at least 18 years old. 

2. CoinReview does not process any Personal Information of children under this age.

 Use of IP Addresses

1. CoinReview platform may collect the information about the user's computer, including where available the user's IP address, operating system and browser type, for system administration and to report aggregate information to advertisers. 

2. This is statistical data about users' browsing actions and patterns. This information will not be used to identify any individual.

 Use of Cookies

1. CoinReview uses a browser feature known as a "cookie", which assigns a unique identification to the user's computer. Cookies are typically stored on the computer's hard drive of the user. 

2. The information collected from cookies is used by CoinReview to evaluate the effectiveness of the website of CoinReview, to analyse the trends, and to administer the website. 

3. The information collected from cookies allows CoinReview website to determine what pages of CoinReview website are the most visited. The difficulties visitors of CoinReview may experience in accessing the website. With this knowledge CoinReview can improve the quality of the website services by recognising and delivering more of the most desired features and information, as well as by resolving the access difficulties. 

4. CoinReview also uses cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm the user’s receipt of, and response to, our emails and to provide the users with a more personalised experience using  the CoinReview website.

5. CoinReview uses the services of a third party service provider(s), to assist us in better understanding the use of our website. Our service provider(s) will place cookies on the hard drive of the user's computer and will receive information that CoinReview selects that will educate CoinReview about how visitors navigate around the site, what products are browsed, and general information. 

6. The service provider(s) of CoinReview analyses this information and provides CoinReview with aggregate reports. The information and analysis provided by the service provider(s) will be used to assist CoinReview in better understanding of visitors' interests in the CoinReview website and how to better serve those interests. 

7. The information collected by service provider(s) of CoinReview may be linked to and combined with information that CoinReview platform collects about the users while they are using the Platform. 

8. Service provider(s) is/are contractually restricted from using the information they receive from CoinReview website other than to assist us.

9. By using the CoinReview website the users are agreeing that the CoinReview website may use cookies for the purposes set out above.

10. The company will keep records of all transfers of Personal Information to third parties and this information, if it is possible, can be provided to the user.

 Disclosure of Personal Information

1. CoinReview website uses the Personal Information for the purposes indicated at the time when the user provides CoinReview with such information, and/or for the purposes set out in this Privacy Policy and/or permitted by the law.

2. CoinReview may make available the Personal Information that the user provides to us for limited purposes and for the provision of the service that the user would have requested such as:

 1) Payment service providers and financial institutions.

 2) Customer communications platforms.

 3) For contractors of CoinReview providing software for identity verification purposes.

 4) For contractors of CoinReview providing us information on sanctions lists from publicly accessible sources.

3. CoinReview 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-organisation and notify the user of such sharing of user’s information to be able to exercise any of the user's rights where applicable.

4. CoinReview may also share Users' Personal Information with the law enforcement or regulatory agencies, as may be required by the law. In certain cases, CoinReview may not be able to inform the user of such sharing of data due to the legal restrictions.

5. Any third party which receives or has access to Personal Information shall be required by CoinReview to protect such Personal Information and to use it only to carry out the services they are performing for users or for CoinReview, unless otherwise required or permitted by law. Such a third party, except for regulatory authorities, would be contractually bound to adhere to the same security and confidentiality policies as CoinReview  and assume the same responsibilities as CoinReview.

6. The legitimate exercise of any of the user's rights with CoinReview will also be notified to be applied by any third parties having been given access to your Personal Information.

7. CoinReview will ensure that any third party is aware of our obligations under this Privacy Policy. 

8. CoinReview will enter into contracts with third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations that CoinReview undertakes to the users under this Privacy Policy or which are imposed on CoinReview under the applicable data protection laws.

 International Data Transfers

1. Contractors of CoinReview platform are situated at different locations and countries and CoinReview sometimes needs to transfer user’s personal data to third countries to provide our services to the users. 

2. CoinReview strives to ensure an adequate level of user’s personal data protection wherever our contractor is located. 

3. CoinReview  may transfer user’s Personal Information only in the following cases:

  •  If the country where CoinReview transfers user’s Personal Information provides the adequate level of personal data protection.
  •  If CoinReview takes appropriate safeguards to ensure that user’s rights as data subjects are protected.
  •  If any derogations for specific situations apply (for instance, if such transfer is necessary for the establishment, exercise or defence of legal claims or for important reasons of public interest).

 User’s Rights

1. Users have the right to access user’s Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to CoinReview or where it is possible, users can do these actions in the user's account profile page by themselves.

2. Upon a user's written request at support service, CoinReview will inform the user of the Personal Information relating to him/her that CoinReview holds and the use and general disclosure of the user's Personal Information. 

3. CoinReview will also give the user a copy of the Personal Information that CoinReview has retained. There may be a minimal charge for providing the user the additional copies of user’s Personal Information to cover the administrative costs.

4. The user may also request the deletion or destruction of both the Account and Personal Information by sending an email to the support service. CoinReview will action the user's request immediately, except, if this is not consistent with its legal and regulatory obligations.

5. The user may also ask CoinReview to transfer his/her Personal Information to another controller of his/her choice.

6. To ensure the confidentiality, integrity and availability of user’s information,  CoinReview may request the user to confirm his/her identity by providing the identification documentation and/or other methods prior to assisting the user in exercising any of his/her rights.

7. If the user refuses to prove his/her identity, CoinReview may decline to take actions in respect of the user's data, save restricting processing, until CoinReview can ensure that such actions are the true wish of the data subject.

8. In the carrying out of our services CoinReview may use the automated processing and profiling to reduce the risks of fraud, money laundering and abuse of services ofCoinReview. Through this automated processing,  CoinReview carries out an analysis of user’s identification, transactional and behavioural patterns.

9. CoinReview may not be able to provide the user with some or all our services if the user does not wish this automated processing to be carried out. If the user feels that this processing might be detrimental to him/her, the user may contact the support service, and  CoinReview will review this application.

 Security

1. CoinReview has implemented technical and organisational security measures to ensure the confidentiality, integrity and accountability of user’s Personal Information and to protect user’s Personal Information from loss, misuse, alteration or destruction. 

2. Such measures include:

  • The encryption of personal data.
  •  The access control.
  •  The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services of CoinReview.
  •  The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

3. Only authorised personnel of CoinReview have access to the user's Personal Information, and these personnel are required to treat the information as confidential.

4. Where the user has consented to, or CoinReview is obliged to pass on Personal Information to third parties to provide the user with a requested service or in the carrying out of a regulatory or legal obligation, CoinReview will request that the same levels of technical and organisational security measure be applied through the contractual arrangements, where possible.

5. CoinReview conducts testing, assessment and evaluation of our technical and organisational measures effectiveness on a regular basis. Technical and organisational security measures will, from time to time, be reviewed in line with the legal and technical developments.

6. In the event of a personal data breach or the failure of the measures of protection of such information CoinReview will immediately notify the user without undue delay.

 Links

1. There may be links from the CoinReview website to other sites and resources provided by third parties. This Privacy Policy applies only to the CoinReview website. Accessing those third-party sites or sources requires the user to leave the CoinReview website.

2. CoinReview does not control those third party sites or any of the content contained therein and the user agrees that CoinReview is in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or any problems related to or arising from those sites. 

3. CoinReview encourages the user to review all policies, rules, terms and regulations, including the privacy policies, of each site that he/she visits.

 Retention of Personal Information

1. User’s information is held on the servers of CoinReview located in different countries. Access to this information is provided to employees of CoinReview who adhere to the same principles of data security.

2. CoinReview will hold user’s Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and legal and regulatory requirements.

3. In accordance with the record keeping activities for Anti-Money Laundering, Tax and Company legal obligations and considering the period during which the user may bring the legal claims against CoinReview under the law. 

4. Data stored for regulatory purposes will be protected from the 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

1. CoinReview does not have any obligation to providing the user with a service he/she requested, nor an obligation to hold the Personal Information for regulatory or legal purpose, CoinReview will anonymise or dispose of user’s Personal Information in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated to user.

2. Where CoinReview cannot directly remove such records, such as archived backups, CoinReview will retain a log of which Personal Information should be removed if ever the backup data is restored.

 Marketing

1. CoinReview will ask for the user’s consent on registration or post-registration, by providing him/her the ability to check the marketing preferences check boxes located within the user’s account profile page to allow us to contact the user or use the user's Personal Information for marketing purposes. 

2. CoinReview platform may also notify the existing Users on our own products or services similar to those CoinReview has already provided based on our legitimate interest.

3. Users have the right to retract the consent for CoinReview to process the user's Personal Information for marketing purposes. 

4. Users can exercise his/her right to prevent such processing by unchecking marketing preferences check boxes on his/her account profile or by contacting CoinReview  at any time on support service.

 Changes

1. CoinReview 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 CoinReview.

2. If CoinReview  changes this Privacy Policy, it will take the steps to notify all users by a notice on the CoinReview website and will post the amended Privacy Policy on the website.

3. If CoinReview considers that a user's rights may be affected by any such changes, CoinReview will request the user to confirm his/her consideration and acceptance prior continuing our relationship with the user.

 Fraud, Phishing and Email Scams Disclaimer

1. Please be notified that CoinReview is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and promising to help to solve user’s  issues for money. 

2. Remember - customer support is provided only via the CoinReview website and is always provided free of charge.

3. If the user discovers what he/she believes is a fraud, phishing, or scam which impersonates CoinReview he/she can email CoinReview at support service.