Privacy Policies

This Privacy Policy explains in detail how we collect, use and disclose your personal data. Please read this document carefully before submitting any personal data to us.

CRYPTIES PRIVACY POLICY

Last update: 14 May 2021

1. GENERAL INFORMATION

1.1 About the Privacy Policy. This Crypties Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the website https://crypties.ch, the related domain names, software and services (collectively, “Crypties”). The Pri-vacy Policy does not apply to any third-party websites, applications, software, products or services that integrate with Crypties or are linked from Crypties.

1.2 Owner of Crypties. Crypties is owned and operated by Crypties SA having a registered business address at Avenue d'Ouchy 4, 1006 Lausanne, Switzerland, and a registration number CHE-401.672.109 (“we”, “us”, or “our”).

1.3 Your consent. Before you submit any personal data through Crypties, you are encouraged to read this Privacy Policy that is always available on Crypties to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you con-sent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy.

1.4 Children. Crypties is not marketed and should not be used by persons under the age of 18. We do not intentionally collect children’s personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.

1.5 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.6 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

  • Directly from you. For example, if you submit certain personal data directly to us when contacting us;
  • Directly or indirectly through your activity on Crypties. When you use Crypties, we automatically collect technical information about your use of Crypties; and
  • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.

2.2 Types and purposes of personal data. We respect data minimisation principles. This means that we collect only a minimal amount of personal data through Crypties that is necessary to ensure the proper provision of Crypties as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below.

  • Redeeming codes. When you redeem a code, we collect your phone number and crypto wallet information. We use such information to redeem your ticket and transfer the crypto currencies purchased by you to your crypto wallet. The legal basis on which we rely is ‘performing a contract with you’. We keep your phone number for as long as it is necessary for our business records purposes.
  • Inquiries. When you contact us by email on through the contact form, we collect your name, phone number, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We keep your personal data until you stop communicating with us.
  • Cookies. When you use Crypties, we collect your cookie-related data. For more information about the purposes for which we use cookies, please refer to the section ‘Cookies’ below. It also explains how long your cookies are valid. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies).
  • IP address. When you use Crypties, we collect your IP address. We use it in an anonymised form for analytics purposes. The legal basis on which we rely is ‘pursuing our legitimate business interests’ (i.e., to analyse our business).

2.3 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation.

2.4 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to receive our services or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

3. WHAT TECHNICAL (NON-PERSONAL) DATA DO WE COLLECT?

3.1 Analytics data. In order to analyse your use of Crypties and comply with the applicable laws, we col-lect non-personal technical data, such as:

  • Times of login.
  • Usage of page : your usage of the platform is logged with your IP address to understand how you use it and improve user experience

3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommenda-tions, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.

3.3 Purposes of technical (non-personal) data. We use your technical (non-personal) data for the follow-ing purposes:

  • To examine the relevance, popularity, and engagement rate of Crypties;
  • To investigate and help prevent bugs, security issues and abuse; and
  • To develop and provide additional features to Crypties.

3.4 Aggregated and de-identified data. If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data and make sure that we have a legal basis for processing it. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

4. HOW DO WE COMMUNICATE WITH YOU?

4.1 Newsletters. We may, from time to time, send you a newsletter informing you about the latest developments related to Crypties and our special offers via push notifications. You will receive our newsletters in the following instances:

  • If we receive your express (“opt-in”) consent to receive marketing messages; or
  • If you voluntarily subscribe for our newsletter; or
  • If we decide to send you information closely related to services already used by you.

4.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by adjusting the settings of your user account or by contacting us directly.

4.4 Service-related notices. If necessary, we will send you important informational messages, such as confirmation receipts, order updates, payment information, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

5.1 Retention of personal data. We store your personal data in our systems only for as long as such per-sonal data is required for the purposes described in section 2 of this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

5.2 Retention of technical (non-personal) data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demon-strate compliance with) legal obligations, resolve disputes and enforce our agreements.

5.3 Retention as required by law. In certain cases, we are required by law to store your personal data for a certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

6. HOW DO WE SHARE AND DISCLOSE YOUR DATA?

6.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service pro-viders with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

  • Ensuring the proper operation of Crypties;
  • Ensuring the delivery of the services ordered by you;
  • Providing you with the requested information;
  • Pursuing our legitimate business interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations; or
  • If you provide your prior consent to such a disclosure.

6.2 List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are:

  • Our Server, Database service provider AWS located in Frankfurt;
  • Our Ethereum node service provider INFURA located in the US;
  • Our Bitcoin node service provider Blockcypher located in the US and
  • Our independent contractors and consultants.

6.3 Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or re-search purposes, for improving Crypties, responding to lawful requests from public authorities or develop-ing new products and services.

6.4 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law en-forcement.

6.5 Successors. In case Crypties is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller.

6.6 Selling personal data. We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our ‘Cookies’ section.

6.7 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

7.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

  • Access control;
  • Secured networks;
  • Blockchain;
  • Strong passwords;
  • Anonymisation of personal data (when possible); and
  • Carefully selected data processors.

7.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any un-lawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

8.1 The list of your rights. You have the right to control how your personal data is processed by us by ex-ercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our sys-tems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to anoth-er processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal da-ta.

8.2 How to exercise your rights? If you would like to exercise any of your rights, please contact us by email or by post (you can find our contact details at the end of this Privacy Policy) and explain your re-quest in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

8.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the out-come of your complaint, you have the right to lodge a complaint with your local data protection authority.

8.4 Non-discrimination. We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

9. COOKIES

9.1 About cookies. A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, that website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device for some time (cookie expiration date depends on its type). Cookies are used to recognise your device and collect certain information about your use of websites. Thus, over time, cookies allow websites to “remember” your actions and preferences. There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain val-id until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the original website) and (ii) third-party cookies (placed by third-party websites). Cookies are classified into:

  • Essential technical cookies that are strictly necessary to ensure the correct functioning of websites;
  • Marketing cookies that allow website owners to create, implement, and examine their marketing campaigns, and offer you personalised advertisement; and
  • Statistics cookies that allow website owners to track you and generate statistical reports about how you use websites.

9.2 Our cookies We use the following cookies:

  • Essential, marketing and statistic cookies.

9.3 Managing cookies. When you our website, we will ask you to provide us with your consent to our use of all cookies via a cookie consent banner. If you do not provide your opt-in consent, we will not serve you our non-essential cookies. Please note that we may not be able to provide you with the best possible user experience on our website if not all cookies are enabled. When we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device.

9.4 Interest-based advertising. You may encounter targeted interest-based advertising based on your use of Cryties and other websites on the Internet. Where necessary, we will seek your consent. You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide pow-ered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org.

10. OUR CONTACT DETAILS

If you have any questions about this Privacy Policy or our data protection practices, please contact us by using the following contact details: Email: contact@crypties.ch, Postal address: Crypties SA, Avenue d'Ouchy 4, 1006 Lausanne, Switzerland

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