Notice on data processing
Data Controller We inform you that, pursuant to art. 13 of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”), we, Coinfirm Limited, a company incorporated and operating under the laws of England and Wales, with company number 10027965 whose registered office is at Lansdowne House 5th Floor, 57 Berkeley Square, W1J 6ER, London, United Kingdom process your personal data.
You may contact us via e-mail address: firstname.lastname@example.org or just call us: +44 203 608 6249.
Purpose and legal basis of the processing
We will use your personal data to take steps into entering a contract with you and if it successes, we will further process your data to perform a concluded contract.
Furthermore, we may use your personal data if it is necessary for the establishment, exercise or defence of potential legal claims, whether in court proceedings or in an administrative or out-of-court procedure, which is our legitimate interest.
The legal basis of processing of your personal data processing is necessary in order to take steps at the request of the data subject prior to entering into a contract or for further performance of concluded contract is article 6.1.b) GDPR.
In case of the need of the establishment, exercise or defence of potential legal claims, whether in court proceedings or in an administrative or out-of-court procedure, the legal basis is article 6.1.f) GDPR.
Recipients and transfer of personal data Your data may be shared with the entitled personnel within the Coinfirm group, which includes:
• Coinfirm Blockchain Lab sp. z o. o., a company incorporated and operating under laws of Poland, whose registered office is at ul. Warszawska 4/4, 87-100 Toruń, Poland, registered with the National Court Register maintained by the District Court of Toruń, Commercial Court VII Commercial Division under the entry KRS number 0000653593, Contact: email@example.com or +44 203 608 6249;
• AMLT Limited, a company operating under laws of Gibraltar with its registered address at Suite 23 Portland House, Glacis Road, Gibraltar GX11 1AA, Gibraltar, company no. 116373, Contact: firstname.lastname@example.org or +44 203 608 6249.
• Graph Tech sp. z o. o., a company incorporated and operating under laws of Poland, whose registered office is at ul. Szafarnia 11F/8, 80-755 Gdańsk, Poland, registered with the National
Court Register maintained by the District Court Gdańsk-Północ of Gdańsk, Commercial Court VII Commercial Division under the entry KRS number 0000810595, Contact: email@example.com or +44 203 608 6249.
We also may share your personal information with third parties 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 agreements with you, or;
• to protect the rights, property, or safety of us, our customers, or others or;
• where we have another legitimate interest in doing so- this may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We also may need to share your personal information for third-party service providers (including contractors and designated agents) so that they can carry out their services.
Transfer of data outside the EU
The data that we collect from you are stored within the European Economic Area (“EEA”). We do not transfer data you have shared with us to Third Countries located outside the EEA.
How long do we store your data? We will retain your data until:
• in case of not entering successfully into a contract with you – for 6 years from the moment of failure entering into an agreement, or
• in case of successfully entering into a contract with you – for 6 years from the moment of expiration of a contract, which performance was the basis of the processing
After those time periods your personal data will be deleted.
Data protection law gives you a number of rights when it comes to personal information, we hold about you. The key rights are set out below. Under certain circumstances, by law you have the right to:
Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means. Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so. Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO). If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.
Do you have to provide your personal data?
We require you to provide your personal data in order to enable you to conclude the contract with you.
If you do not provide your personal data, we will not be able to conclude a contract with you.
We do not use automated decision-making, including profiling, referred to in article 22 GDPR.
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