Privacy Policy
Introduction
At Cryptonis, we respect and protect the privacy of our visitors and users (collectively “Data Subjects”). This Privacy Policy ("Policy") of UAB Cryptonis (“Cryptonis”) informs and explains how Cryptonis processes the Personal Data of the Data Subject.
All definitions used in this Policy, and all circumstances not covered by it, shall be regulated by the Terms of Service of Cryptonis and/or Regulation (EU) 2016/679 (GDPR).
Agreement to Policy
By using the Website and/or Services, the Data Subject agrees to the processing of Personal Data in accordance with this Policy. If the Data Subject does not agree with this Policy, either partially or fully, they must stop using the Services.
Cryptonis encourages the Data Subject to read this Policy carefully as it forms a relevant part of the Agreement between the Data Subject and Cryptonis.
Personal Data and Its Processing
Definition of Personal Data
Personal Data refers to any information relating to an identified or identifiable natural person (“Personal Data”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to:
- An identifier such as a name
- An identification number
- Location data
- An online identifier
- One or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Definition of Processing
Processing refers to any operation or set of operations performed on Personal Data or sets of Personal Data, including:
- Collection
- Recording
- Organisation
- Structuring
- Storage
- Adaptation or alteration
- Retrieval
- Consultation
- Use
- Disclosure by transmission
- Dissemination or otherwise making available
- Alignment or combination
- Restriction
- Erasure or destruction
Legal Grounds for Processing
Cryptonis acts as a data controller when determining the purposes and means of any operation or set of operations performed on the Data Subject’s Personal Data. The legal grounds necessary for the processing of Personal Data include:
- Consent: Freely given, written, or verbal permission for Processing of Personal Data for a specific purpose.
- Contractual Obligation: A contract between Cryptonis and the Data Subject.
- Legal Obligations: Requirements imposed by related agencies for compliance with relevant applicable laws, including anti-money laundering and privacy laws.
- Legitimate Interests: A legal ground allowing the Processing of Personal Data without the Data Subject’s consent, primarily for ensuring continuity of business or services.
Cryptonis guarantees that legitimate interest is only used when absolutely necessary, ensuring that personal rights are upheld.
Collection Purposes of Personal Data
Cryptonis collects Personal Data about Data Subjects for the following purposes:
- To provide the Services
- To contact or reply to Data Subject’s requests
- To improve the Website and/or Services
- To fulfill our legal and regulatory requirements
- To assist in criminal investigations and regulatory actions
- To protect Data Subject’s assets from unauthorized access
- To detect, investigate, and prevent fraudulent transactions or unauthorized or illegal activities
- To provide Data Subject with information on our Services, news, and updates
- To resolve disputes and protect the Data Subject’s interests or the interests of other users
- Based on the Data Subject’s consent
Personal Data Cryptonis Collects
Information Provided by the Data Subject
This information is either required by law or necessary for us to provide the requested Services. The nature of the Services requested determines the kind of Personal Data we might ask for, which may include:
- Identification Data: Information for conducting KYC and KYT processes, such as full name, date of birth, address, contact details, photo of an ID document, proof of address, proof of legal formation, and/or any other information deemed necessary to comply with our legal obligations.
- Financial Data: Including cryptocurrency wallet addresses, bank account information.
- Transaction Data: Information about transactions made using the Services, such as the name of the cryptocurrency, the amount, and/or timestamp.
- Correspondence Data: Including survey responses and information provided to our support or customer research team.
Information Collected Automatically
This information is collected automatically when the Data Subject accesses and/or uses the Website and/or Services and helps us to:
- Improve the Website and Services
- Address any customer support issues
- Provide the Data Subject with a streamlined and personalized experience
- Protect the Data Subject from fraud by detecting unauthorized access
This information may include:
- Identifiers: Geo-location/tracking details, operating system, browser type, and/or personal IP addresses.
- Usage Data: Information about how the Data Subject uses the Website and/or Services, such as web requests, pages viewed, authentication data, and other data collected via cookies and similar technologies. (Please read our Cookies Policy for more information.)
- Device Data: IP address, language, browser type and version, time zone setting, browser plug-in types, some location information, operating system and version.
Information Collected from Third Parties
Cryptonis may obtain information about the Data Subject from third-party sources. These third parties include:
- Business partners
- Sub-contractors in technical, payment, and delivery services
- Advertising networks
- Analytics providers
- Search information providers
- Credit reference agencies
- Fraud prevention agencies
- Customer service providers
- Developers
This information helps us verify the Data Subject’s identity or relates to their transactions.
Disclosing Personal Data
Cryptonis will not rent or sell the Data Subject’s Personal Data to anyone. We only share Personal Data when we have a valid reason for it, namely, to provide Services to the Data Subject and when legally permitted to do so. We may share Personal Data with:
- Subsidiaries and affiliated companies for KYC and KYT processes, fraud detection, decision-making, customer support, and other business purposes.
- Third-party providers who have been rigorously assessed and offer compliance with applicable legislation on the Processing of Personal Data.
Cryptonis may also disclose Personal Data to:
- Financial institutions and/or enforcement or court authorities to comply with applicable laws, prevent fraud, enforce agreements, or protect rights, property, or safety.
- Third parties when requested or authorized by the Data Subject with explicit written consent.
- Professional advisors during the provision of banking, legal, compliance, and other consulting services.
Rights of the Data Subject
Data Subjects have the following rights regarding their Personal Data:
- Request access to their Personal Data
- Request to receive their Personal Data
- Request changes or corrections in their Personal Data
- Request erasure of their Personal Data
- Request that we restrict our processing of their Personal Data
- Withdraw consent to the Processing of Personal Data collected on the basis of their consent
- Request the transmission of Personal Data directly to another data controller (portability)
- Submit objections to their Personal Data processing on any grounds
Limitations to Privacy Rights
We may limit these privacy rights requests:
- When denial of access is required or authorized by law
- When granting access would negatively impact another’s privacy
- To protect Cryptonis’ rights and properties
- When the request is frivolous or burdensome
Personal Data Retention
The retention period for Personal Data is determined by:
- The business purpose for which we are using the Personal Data
- Legal obligations requiring a minimum retention period
We will cease to retain Personal Data, or remove the means by which it can be associated with the Data Subject, as soon as it is no longer necessary for legal or business purposes.
Security
Cryptonis takes all necessary measures to protect data against unauthorized access, modification, disclosure, or destruction. We have implemented various technical and organizational measures to ensure compliance with applicable Personal Data, privacy, and data security legislation.
International Transfers
Cryptonis does not transfer any Personal Data outside of the EEA. In cases where Personal Data must be sent outside of the EEA, Cryptonis will:
- Contact the Data Subject and acquire the necessary consent before the international data transfer.
- Ensure that the Personal Data is protected at the same level as within the EEA by adequate safeguards, such as contracts containing standard data protection clauses approved by the European Commission.
Third Parties Cryptonis Shares Personal Data With
Cryptonis relies on certain third parties to provide necessary solutions for delivering the Services. Considering that each third party has different privacy procedures, we encourage Data Subjects to check their privacy policies.
Some third-party providers include:
Third-Party Links
The Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about the Data Subject. Cryptonis does not control these third-party websites and is not responsible for their privacy policies.
Complaints
If the Data Subject is concerned about the way Cryptonis is managing their Personal Data and believes we may have breached any applicable privacy laws or obligations, they can contact us using the details provided below. We will investigate the matter and keep the Data Subject informed of our progress.
Policy Changes
Cryptonis reserves the right to change this Policy at any time to meet business needs or accommodate changes in Personal Data Processing procedures, comply with changes in law, or under the instruction of supervisory authorities.
Governing Law
Personal Data shall be governed by the laws of the Republic of Lithuania and the EU, namely by the GDPR.
Contact Details and Questions
For any questions about this Policy, the processing of Personal Data, or to submit requests, please contact Cryptonis via email at office@cryptonix.com.
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