What information do we collect?

Information you give us. We collect information about you when you:

• Use the Support Centre on the Site; or
• Correspond with us by phone, e-mail or otherwise. The Personal Information most often collected and maintained in a customer file includes customer identification, transaction history including records of payments made.
• Information we collect about you. Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:
• Technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.
• Special categories of data. We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Purposes for which we collect your Personal Information.

If you wish to transact on and use the Site or use the Services, Coded Solution will collect information about you for the purposes set out below. Information you provide to Coded Solution may be used to:

• Use the Support Centre on the Site; or
• Correspond with us by phone, e-mail or otherwise. The Personal Information most often collected and maintained in a customer file includes customer identification, transaction history including records of payments made.
• Information we collect about you. Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:
• Technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.
• Special categories of data. We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

We use IP addresses to analyze trends, administer the Site, track customer movements, and gather broad demographic information for aggregate use. For systems administration and detecting usage patterns and troubleshooting purposes, our web servers also automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within Coded Solution and their affiliates on a need-to-know basis. We reserve the right to block access for any customer accessing the Site via a proxy service intending to conceal originating identity. This includes access via the Tor anonymity network.

Legal bases on which we process your Personal Information

We will process your Personal Information on the following grounds:

• Use the Support Centre on the Site; or
• where it is necessary for us to perform pursuant to your contract with Coded Solution or in your interests; and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interest of our organization to conduct and manage our business to enable us to better serve you and provide you with a secure experience on the Site.
• We ensure that we balance any potential impact on you and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally we do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies (please refer to our Cookies Policy) or when we send third party direct marketing communications to you via email or text message.

Security and confidentiality

• We are committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.
• The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Disclosures

You agree that we have the right to share your Personal Information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries including their respective contractors, affiliates, employees or representatives.
• Our service providers, to the extent necessary to supply the Services to you.
• Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services
• Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us (please refer to our Law Enforcement Requests Policy).

We will also disclose your Personal Information to third parties:

• If Coded Solution or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Sale and Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others.
• We reserve the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital tokens purchased or redeemed on the Site.

Transfers

Your Personal Information will be stored in Ireland and/ or Switzerland and may be transferred worldwide.

Personal Information and other data may therefore be exported outside of the jurisdiction in which you reside.Your Personal Information may be processed and stored in a foreign country or countries.Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws.You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

Unfortunately, the transmission of information via the Internet is not completely secure.While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us over email or through the Site; any transmission is at your own risk.Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

Your rights

All Customers. You may access and verify your Personal Information held by Coded Solution Limited by submitting a written request to: [email protected]

No fee Usually Required

You will not have to pay a fee to access your Personal Information or to exercise any of your other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Other Sites and protecting your Personal Information

This Privacy Policy and the use of your Personal Information only applies to the information we collect. You are cautioned that if you disclose Personal Information or personally sensitive data through use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which we have no control. It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. We are not responsible for the privacy statements, policies, terms, conditions, or other content of any Site not owned or managed by Coded Solution.

We take all reasonable endeavors to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.

Changes to Our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to [email protected]

• The Site may use “cookies”. A cookie is a small text file containing a unique identification number that identifies a customer’s browser each time that customer visits a website. The use of cookies is industry standard practice and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Site.
• You choose to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the ‘Help’ menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit Home or Your Online Choices | EDAA for comprehensive information on how to manage cookies.
• We set cookies (first party cookies) on web pages, however, where we require additional information, we may also allow other companies to host cookies on our Site (third party cookies). These companies have been carefully selected by us and are required to meet contractual obligations they have with us.

The cookies on the Site may be from any of the following categories:

• Strictly Necessary cookies – these are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.
• Functionality cookies – these are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat user of the Site and help us remember your preferences (for example, your choice of language or region).
• Analytical – these record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

How do we share cookies?

We may share information that we collect through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies.

Contact Us

If you have questions, comments or concerns about the Privacy Policy, please send us an email [email protected]