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© 2023 Cryptobunq Incorporated, LEI code: 8945003NN6TMUCNVXW94, All Rights Reserved. JCS CH GmbH, This company is a member of SRO. Gartenstrasse 6, 6300 Zug, Switzerland 🇨🇭
© 2023 Cryptobunq Incorporated, LEI code: 8945003NN6TMUCNVXW94, All Rights Reserved. JCS CH GmbH, This company is a member of SRO. Gartenstrasse 6, 6300 Zug, Switzerland 🇨🇭
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Last Updated: 30 May 2023
This privacy policy (“Policy”) indicates how JCS CH GmbH, Gartenstrasse 6, 6300 Zug, Switzerland, entered in the Commercial Register of the Canton Zug under number CHE-478.399.078 (“Company, Cryptobunq, we, our, or us”) collects, uses, shares, and stores personal information of users of its website, www.cryptobunq.com/ (the “Website”). This Policy applies to the Website, web-applications, products, and services of us (“Services”) or on which such personal information is posted, shared, linked, used, checked, or referenced. We may process certain personal data about you, depending on the scope of your specific relationship with us.
Therefore, it is our responsibility to collect, process, and use of your personal data in accordance with the law. We take data protection very seriously and are dedicated to the protection of your personal data. As a result, we comply with the applicable data protection laws of Switzerland and the European Union (in particular General Data Protection Regulation, GDPR).
If you have not done so already, please also review our Terms and Conditions. The Terms and Conditions includes provisions and clauses that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. If you do not agree with any part of this Policy or Terms and Conditions, please do not use or purchase any of the Services.
Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the services or that you submit to us offline.
This Privacy Notice applies to the following three circumstances:
When you visit our Website, and navigate your way around, we acquire minimum personal data at this stage. The personal data we collect includes the following:
Providing your data is optional, but it may be necessary for certain services we provide, and other processing activities e.g. to access content, or to qualify your suitability as a new customer. In such cases, if you do not provide your personal data, we may not be able to provide you with the requested services.
As a business, any data solely connected to the legal enterprise is not personal data, however we collect the following personal data on directors and ultimate beneficial owners that you provide to us at onboarding:
We collect this personal data from the directors and ultimate beneficial owners when registering with us.
We collect the following personal data that you provide to us throughout the business relationship:
We collect this personal data from you when:
We collect the following personal data that you provide to us at onboarding:
We collect this personal data from you when registering for an account.
We collect the following personal data that you provide to us throughout the business relationship:
We collect this personal data from you when you:
We do not collect or process personal data from other sources and any personal data we collect, in the context of the Website, is provided by you whether directly or indirectly.
We may automatically record certain information about how you use our Website (we refer to this information as “Log Data”). Log Data may include information such as a user's Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Website to which a user browsed and the time spent on those pages or features, the frequency with which the Website are used by a user, search terms, the links on our Website that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users' needs and preferences. The IP address will be evaluated for clarification and defense purposes only in the event of an attack on the website(s)' network infrastructure or in case of a suspicion of unauthorized or abusive use of the websites. It may further be used for identification purposes in criminal proceedings and in the context of civil and criminal proceedings against the concerned individual, as necessary and required.
We may receive personal data about your directors and ultimate beneficial owners from other sources, where applicable. This information includes:
We will add this information to the personal data we hold about you for the following purposes:
Please note that we will ask for your explicit consent before any credit search is performed.
We may receive personal data about you from other sources, where applicable. This information includes primarily legal and compliance checks.
We will add this information to the personal data we hold about you for the following purposes:
Cookies are small text files that are placed on your computer or device by websites that you visit or HTML-formatted e-mails you open. You can access our Cookies Policy on our Website.
We will never ask your private key or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
We use your personal data mainly to: interact with you; to provide you with support services; to make it easy to navigate our Website; to improve our Website and our products; and to offer you content and services that might interest you.
We use your personal data as follows, where the processing is necessary to establish or administer our agreement with you:
We may also use your personal data where processing is necessary for us to comply with our legal obligations, including responding to legal process or lawful requests. We use your personal information as we believe necessary or appropriate to comply with applicable laws including anti-money laundering (AML) laws, know-your-customer (KYC) requirements, tax law requirements, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
Lastly, we may use your personal data, where required by applicable law.
We collect personal data about your directors and ultimate beneficial owners for the following purposes:
We may monitor and record communications such as emails and telephone calls for the following purposes:
We collect personal data about you for the following purposes:
We may monitor and record communications such as e-mails and telephone calls for the following purposes:
We may use your personal information to run, maintain, and enhance our Services in order to improve your user experience. We may also use your information to address feedback and inquiries you may have about the Services and to generally support both you and other users.
We may use or share your personal information with your consent, such as by publishing your recommendations or testimonials on our Website, or if you provide us explicit instructions on how we may use your personal information. You can get in touch with us at any moment to withdraw your consent.
We may share your personal data with:
This data is never sold or passed on to other companies in order to market services not offered by us. With the exception of the circumstances stated in this Policy and taking into account the principle of proportionality (need-to-know), we do not disclose the personal information you give us with to other organisations without your express agreement.
We collect and use personal data to provide you with Services that you have requested, or where necessary, to comply with a legal obligation. We may also collect and use personal data pursuant to our legitimate interest as long as these interests are not overridden by your data protections rights. Additionally, we may collect and use certain personal data where you have given consent. Where we ask for consent, you are free to withhold or revoke your consent by opting out.
We rely on the legal basis of legitimate interest and consent in order to market to you, with considerations to the e-Privacy Directive and its requirements under consent.
We will maintain your personal data throughout the lifecycle of the contract. We may need to keep your data for a longer period where we need to retain personal data to comply with legal or regulatory requirements, such as to help us respond to complaints or preventing fraud and financial crime. If we are not required to retain the personal data, we will destroy, delete, or anonymise it at the point it is no longer required.
We store your personal data in a secure environment. We have appropriate security measures in place to prevent personal data from being lost, accessed, or used in an unauthorised way, including encryption and other forms of security. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Whilst we will use all reasonable efforts to secure your personal data, in using the Website you acknowledge the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of personal data that is transferred from you.
Your personal data may be transferred to and stored in locations outside the UK or EEA. When we do this, we will ensure the recipient entity has an appropriate level of protection and that the transfer is lawful through controls, such as Standard Contractual Clauses. We may need to transfer your data in this way to carry out our contractual obligations to you, to fulfil a legal obligation and/or for our legitimate interests. In such instances, we will only share the personal data with those who have the right to see the personal data.
Only Switzerland serves as the company's headquarters, but it uses service providers in other EU nations as well. Your personal data may be transmitted to or from Switzerland/EU to other countries or governmental jurisdictions outside of your state, province, or nation, where privacy regulations might not be as protective as those in your jurisdiction.
More essential information concerning the transfer of personal information outside of the European Economic Area (EEA) is provided below (section 10 f.), which also applies to situations in which Swiss law is applicable.
Please be aware that your personal data will be transferred to, processed, and stored in Switzerland and the EU. Data protection laws may be different from those in your country of residence. Such third-party companies are obliged to protect the privacy of individuals to the same extent as we do. If the level of data protection in a country does not correspond to the Swiss or European level, we contractually ensure that the protection of your personal data corresponds to that in Switzerland or the EU at all times.
Please contact us at info@cryptobunq.com, if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
We would like to send agents and third parties' information about products, services, and our business, which may be of interest to agents. Such information could be sent by post, email, or telephone.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on signing up with us). If you do opt in to receive such marketing from us, you can opt out at any time (see Section 12. What rights do you have? below for further information). If you have any queries about how to opt out, or if you are receiving messages, you do not want to, you can contact us using the details provided below.
The right to access: You have the right to request us for copies of your personal data and how we process the data.
The right to rectification: You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request we complete personal data you believe is incomplete.
The right to erasure: You have the right to request that we erase your personal data, under certain conditions. If you enforce this right at the same time as you object to the processing, we will have to maintain basic identification data to ensure we do not contact you again.
The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal data, this means if you do not want to be contacted for the purposes set out in this notice then we will stop processing your data.
The right to lodge a complaint with a supervisory authority: if you are a resident of an EU or EEA Member State, you have the right to lodge a complaint with a competent supervisory authority about the way, in which your personal data is processed.
The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right of withdrawal: in principle, you have the right to withdraw your consent at any time. However, processing activities based on your consent in the past do not become unlawful as a result of your revocation.
Due to the nature of the Services, certain rights may be limited. However, we will do our best to grant you the rights by also taking into account all technical possibilities.
You can submit these requests by email to our data protection team at inquiry@cryptobunq.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or respond to your requests regarding your personal information, you may contact us at info@cryptobunq.com or submit a complaint to the data protection regulator in your jurisdiction. If you make a request, we have one month to respond to you.
From time to time we may have other methods to unsubscribe (opt-out) from any direct marketing including, for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
We may update or amend this Privacy Notice from time to time. You should check this Privacy Notice frequently to ensure you are aware of the most recent version that will apply each time you Access this Website. We will also attempt to notify users of any changes by:
If you have any questions about this Privacy Policy or the personal data, we hold about you, please contact us by:
E-mail: info@cryptobunq.com
Address: Gartenstrasse 6, 6300, Zug, Switzerland
If you have any complaints about this Privacy Policy or the personal data, we hold about you, please contact us by reaching out to the above contact information.
If you are unsatisfied by our response you can contact the Information Commissioners Office (ICO) by contacting:
E-mail: info@cryptobunq.com
Website: www.cryptobunq.com/