Notice on data processing

Last updated: 6th February 2020

Data Controller

We inform you that, pursuant to art. 13 of 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 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.

Contact Details
You may contact us via e-mail address: contact@coinfirm.com or just call us: +44 203 608

6249.
Purpose and legal basis of the processing

We may 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. 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 (article 6.1.b) GDPR.

Furthermore, we may use your personal data to send you our marketing materials, if you agree to it on the grounds of The Privacy and Electronic Communications Regulations (PECR). The legal basis of processing of your personal data: processing is necessary for the purposes of the legitimate interests pursued by the controller (article 6.1.f) GDPR.

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.

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 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: contact@coinfirm.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: amlt@coinfirm.com.

  • 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: contact@coinfirm.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, which includes:

  • Atlassian Pty Ltd.,

  • Atlassian, Inc.,

  • Dogwood Labs, Inc.,

  • Trello, Inc.,

  • OpsGenie, Inc.,

  • Agile Craft LLC,

  • Kroll Associates U.K. Limited.

    We will exercise appropriate due diligence in the selection of our third-party service providers and require that such providers maintain adequate technical and organizational security

measures to safeguard your data, and to process your data only as instructed by us and for no other purposes.

How long do we store your data?

We will retain your data until:

  • you object to processing, or;

  • in case of not entering successfully entering 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.

    Transfer of data outside the EU

    Some of recipients of your data may be located in countries (including the United States) that do not provide a level of data protection equivalent to that set forth by the law in your home country. We will take appropriate steps to make sure that such recipients act in accordance with applicable law. To the extent that we transfer your data to the recipients which are located outside the European Union or the European Economic Area, we will provide an adequate level of protection of your data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law. The Company uses standard contractual clauses in the form approved by the European Commission.

    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.

    YOUR RIGHTS

    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. Therefore, we are providing you with the information in this notice. If you require any further information about how we use your personal information, please contact us.

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 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.

If you want to obtain more details about processing information you have provided to us or you have a question connected with this processing, please visit our website and read the Privacy Policy placed in the footer or contact us directly via e-mail indicated above.

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 and you must provide this in order to enter into a contract with us (or as required under that contract).

If you do not provide your personal data, we will not be able to conclude a contract with you.

Automated decision-making

We do not use automated decision-making, including profiling, referred to in article 22 GDPR.

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