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CoolBitX Privacy Policy

Please note that this Privacy Policy will regularly be updated to reflect any change in the way we handle your personal information or any changes in applicable laws.

This Privacy Policy governs how CoolBitX Ltd., (“CoolBitX”, “we,” “our,” or “us”) collect, use, process, or store disclose pertaining to any user who access or uses the Products, Services, or the Site (hereinafter “you”, “your”, or “user”). Terms not defined in this Privacy Policy shall have the same meaning as defined in the Terms and Conditions of the Site (available at https://www.coolwallet.io/termsandconditions/).

OVERVIEW

Your right to privacy and the protection of your personal information is important to us. The following sections provide further details as to how we process your personal information through our Site, Products and Services. We don’t share your information with third parties except to deliver you our Products and Services, facilitate your purchase, use and enjoyment of the Site, Products and Services and/or your other interaction with CoolBitX, comply with the law, make the Site, Services and Products better, or protect our rights. If you have any questions or concerns about this policy, please reach out to us at [email protected]. You may decide whether to provide your personal information to us, and you may decide whether to exercise your right as stipulated herein.

HOW DO YOU ACCEPT THIS POLICY?

By using the Services and Products (including via downloading one of our mobile applications) or visiting our Site, you hereby agree to the terms and conditions outlined in this Privacy Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT FROM OUR USERS?

We do our best to minimize the amount of personal information that we collect from the  users of the Site, Products and Services. Your contact information, such as your phone number, or email/physical address (depending on how you contact us), may be collected when you communicate with us for support, purchase our Products at the Site, register an account with us, report a bug or other error related to the Site, Products and Services or interact with us through social media. When you use our Products/Services, we may also process PUBLIC wallet addresses that you generate through our Products/Services.

Category of personal informationTypes of personal information captured PurposeLegal Basis (UK & GDPR)
Personal details, contact details, and identifiers.Name, contact details (such as e-mail, phone numbers, delivery address) and credit card information when you voluntarily have shared this information with us in order to be contacted and/or to purchase Products at the Site)Facilitating (1) communication with you for customer support purposes, (2) your purchase of the Products and/or (3) your registration of an account  at the SiteOur legitimate interests in ensuring proper communication with you and handling of your orderYour consent when we ask for it to process your personal information for a specific purpose that we communicate to you (when you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose)
System and application access data and internet and electronic network activity informationThe Internet protocol (IP) address used to connect your mobile device to the Internet and the information of such  device (e.g., identifier, device name and type, operating system, location, and mobile network information); our Site, Products and Services metrics (e.g., the occurrences of technical errors, your interactions with the Site, Products/Services and your setting preferences); records of any contractual agreements between yourself and CoolBitX; your username and password of your account. Providing troubleshooting; analyzing performance; fixing errors; improving the performance, usability and effectiveness of the Site, Products and Services;  performing a contract to which you are a partyOur legitimate interests and the interests of our users in, for example, detecting and preventing fraud and abuse in order to protect the security of our users, ourselves, or othersOur legitimate interests in keeping records necessary for the provision of the Products and Services to you  and the performance of your contract

WILL WE SHARE YOUR PERSONAL INFORMATION  WITH THIRD PARTIES?

Information about our users is an important part of our business and we are not in the business of selling our users’ personal information to others. We may, however, transfer personal data to our service providers or third parties in connection with CoolBitX’s operation of its business, as certain features on the Site, Products and/or Services rely on various third-party products and services (collectively “Third Party Services”). These Third Party Services providers only have access to certain personal information, such as your PUBLIC wallet addresses, to perform their functions AFTER getting your consent and may not use it for other purposes. Furthermore, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protections laws. In addition to the Third Party Services providers, you acknowledge and agree that we have the right, without liability to you, to disclose any part of your personal information to the law enforcement, authorities, government officials and/or other third parties that we reasonably believe to be necessary for the legal and compliance requirements.  Also, in the unlikely event that CoolBitX or substantially all of its assets are acquired, users’ information will be one of the transferred assets.

HOW WE USE THE PERSONAL INFORMATION WE GATHER

  1. We primarily use the limited information that we collect to enhance the Site, Products and Services and to provide the Site, Products and Services to you. Except if we sell all or a portion of our business, or as otherwise described below, we do not rent, trade, or sell your personal information. Some ways we may use your personal information are to: contact you when necessary (only applicable for purchase related matters happens on the Site); respond to your comments, questions, or issues related to bugs or errors with our Site, Products and Services; provide you with additional information; send you information and marketing materials about Services and Products, using push notifications or other means; train our team members; and/or accomplish other internal business purposes. 
  2. From time to time we may share or disclose aggregated information (which may or may not include certain personal information) with Third Party Services providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the company. These service providers and other persons may also share with us aggregated information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, and web beacons, with similar data we collect from other visitors to help us improve our Site, Products and Services. When doing so, we do our best to ensure that aggregated information cannot be linked back to you. 
  3. We may also provide your personal information to our employees, contractors, agents, service providers, and designees to enable them to perform certain services for us, including improvement of website-related services and features, and performance of maintenance services. 
  4. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your Personal Information could be one of the assets transferred to or acquired by a third party. By accepting this Privacy Policy, as outlined above, you consent to any such transfer. 
  5. We will share personal information outside of CoolBitX if we have a reasonable belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to cooperate with law enforcement; to enforce or apply our Terms and Conditions of the Site/Products/Services  and other agreements; or to protect the rights, property, or safety of CoolBitX, our employees, our users, or others.

YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF PERSONAL INFORMATION

You are entitled (under the conditions, and subject to the exceptions, set out in applicable law), via contacting us at [email protected], to: 

  1. Request Access to the personal information we process about you: You can request access or make duplications to the information we have collected from you. To comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically. For any subsequent access request, we may charge you an administrative fee.
  2. Request a rectification of your personal information: If you believe that the information we have collected is incorrect or incomplete, you may contact us so we can update it and keep your data accurate. 
  3. Object to the processing of your personal information: You may request that we no longer process your personal information. 
  4. Replenish/rectify your personal information: You may request to replenish or rectify certain personal information you provided to us. 
  5. Request to erase your personal information: You may request the erasure of your personal information, including where such personal information would no longer be necessary to achieve the purposes for which it was collected. Notwithstanding the foregoing, wallet addresses created through our mobile application cannot be deleted from the blockchain, therefore we are unable to delete this personal information. 
  6. Request the restriction of the processing of your personal information: You may request that CoolBitX only processes your personal information in limited circumstances, including with your consent. 

Please note that we do not sell your personal information and you will not be discriminated against because of the exercise of your rights specified above.

DATA RETENTION

Please note that even if you delete your wallet or wallet addresses from our Products/Services (including the mobile application), or uninstall such Products/Services from your device, or request that your information be deleted, we still may retain some information that you have provided to us to maintain the Site, Products and Services  or to comply with the laws and regulations to which CoolBitXis subject. If you have any question or objection as to how we collect and process your personal information, please contact [email protected].

DATA SECURITY

We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. We have carefully selected Third Party Services providers, including but not limited to ChangeHero,  Changelly, Everstake. Unfortunately, we do not control these third parties and therefore cannot guarantee complete security. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information and secure all connections with industry standard transport layer security. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use (such as any attacks from hackers or any skilled computer experts). Any information that you provide to us is done so entirely at your own risk.

CHILDREN

We are especially sensitive about children’s information. Our Products/Services are not targeted towards children, and our users must be at least eighteen (18) years old to use our Products/Services. We don’t knowingly collect information from children under the age of 13. If you are a parent or legal guardian of a minor child, we will treat any information that you provide us while using our Products/Services on behalf of your minor child as personal information as otherwise provided in this Privacy Policy. If you have questions concerning our information practices with respect to children, or if you learn that a child under the age of 13 has used our Products/Services, created a user account, or provided us with any personal information, please email us at [email protected]

CONDITIONS OF USE, NOTICES, CHANGES AND UPDATES TO PRIVACY POLICY

If you choose to use our Site, Products and/or Services, your use and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions applicable to such use of the Site, Products and/or Services. If you have any concerns about your privacy with respect to our Site, Products and/or Services, please contact us with a complete description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. If we do revise this Privacy Policy, we will update the “Effective Date” at the bottom of this page so that you can tell if it has changed since your last visit and will do our best to notify you. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of our Site, Products, and/or Services after an amendment to our Privacy Policy constitutes your acceptance to the revised or amended terms.

QUESTIONS

If you have any questions about this Privacy Policy, please shoot us an email or send us a note:

Email: [email protected]

Business Address:
CoolBitX Ltd.
Attn: Legal Department
Suite 102, Cannon Place, P.O. Box 712, North Sound Rd, George Town, KY1-9006, Grand Cayman


Last Updated: January 19, 2023

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