Privacy Policy

This is the Privacy Policy of Coinmerce B.V., having its place of business at Startbaan 8, 1185 XR Amstelveen, the Netherlands (“Coinmerce”, “we” or “us”), which describes how we handle your personal data.

This Privacy Policy applies to the processing of all personal data that Coinmerce collects about you and uses when you purchase cryptocoins or other products from us, visit our website or applications, register with us, or use other services we offer (the “Services”).

1. Personal data we process about you

Depending on the products you purchase or the Services you use, the personal data we collect and process about you include the following:

1. Your contact details, such as your name, email address, date of birth, full address and telephone number (mobile and/or landline);
2. Identification information: for purchases exceeding a certain amount – as set out in our General Terms and Conditions – we ask you to provide your identification information (copy of passport or driving licence);
3. Financial information, such as bank details;
4. Information concerning your transactions, such as the number of cryptocoins you buy or sell and their value;
5. Information that is automatically collected by websites and applications, such as the behaviour (including surfing behaviour) of visitors to our websites and applications;
6. Communication information, such as questions, complaints and other customer data received by email or online;
7. Your (electronic) identification information, such as your account, electronic identification information such as your IP or MAC address, including the data that you yourself add to your account.

2. The purposes and legal basis for the processing of your personal data

Coinmerce collects and uses your personal data for the purposes set out below, which have a legal basis.

This is necessary for the performance of an agreement
This is necessary for the promotion of Coinmerce’s legitimate interest

Your personal data are collected and processed to comply with requests to buy or sell cryptocoins or other products or to provide our Services. In addition, we process your personal data to create a user account. We also process your personal data to handle any requests, complaints or questions you may have.

We may use the aforementioned personal data to provide our Services. For instance, we may analyse the use of our websites and applications for statistical purposes by using Google Analytics. We may also use the aforementioned personal data to improve our Services, to enhance our understanding of our customers at an aggregated as well as an individual level and to be able to adopt a more targeted approach towards our customers. This means that we analyse your use of our Services and that we use this information to improve our Services and to offer you a better user experience (for example, we analyse which web pages you visit on our website and which Services you use, allowing us to create personal profiles and to assess what might be of interest to you and which recommendations we may make to you when you use our Services). We may also send you newsletters and inform you of our marketing activities.

- On the basis of consent
- This is necessary to comply with a legal obligation

To the extent necessary, we will ask for your consent to keep you up to date of news or special offers with regard to our Services. You may withdraw your consent at any time. Below, you will find an explanation of how to do this.

We may use your personal data to comply with applicable laws, to meet requests from public authorities and government bodies, or to cooperate in law enforcement. For instance, we may ask you to provide your identification information for purchases exceeding a certain amount, as described in our General Terms and Conditions.

3. Use of cookies

Our websites and applications use cookies and similar technologies to increase usability, effectiveness and safety, as well as for advertising purposes. Cookies are small text files on your computer that are stored by your browser. Please refer to the Cookie Policy for more information and the use of cookies by Coinmerce.

4. Who has access to your personal data?

Only authorised Coinmerce employees have access to your personal data, to the extent that this is necessary within the context of the performance of their work at Coinmerce.

We share your personal data with a number of third parties, such as IT suppliers, in the event that this is necessary for the provision of our Services. In addition, we may disclose your personal data to public authorities to comply with any applicable legal obligations.

5. Transfer of your personal data

We process and retain your personal data in the European Union, unless stated otherwise. Our service providers may transfer your personal data outside the European Economic Area (‘EEA’) to a country that does not offer the same level of protection under European laws as the country where you normally use your products and/or services. At such time, we will take the necessary steps to guarantee that your personal data are sufficiently protected, such as concluding EU standard contracts with parties located outside the EEA.

6. How are your personal data secured?

We implement appropriate and reasonable security measures to protect your personal data from unlawful access, modification, disclosure, loss or improper use, and to protect the accuracy and integrity of your personal data. In order to ensure a level of security appropriate to the risk, we implement technical and organisational measures, including security concerning access to our systems.

7. How long do we retain your personal data?

We retain your personal data for as long as this is necessary or permitted in light of the purposes for which they were acquired and as set out in this Privacy Policy. The criteria used to determine our retention periods include: (i) the period during which we have an ongoing relationship with you; (ii) whether we are subject to any legal obligation; and (iii) whether retention is desirable in light of our legal position (for example in connection with the enforcement of general terms and conditions, legal proceedings or legal investigations).

8. What rights do you have in respect of your personal data and how can you exercise these rights?

Based on applicable laws and regulations, you have several rights in respect of your personal data. At your request, we will provide information regarding the personal data we process about you. This will be free of charge.

- Right to rectification. At your request, we will correct, supplement, block or remove your personal data in the event that they are factually incorrect, incomplete or irrelevant for the purpose or purposes of the processing, or if they are processed in any other manner that breaches a statutory provision.
- Withdrawing your consent. You may withdraw your consent to our future processing of your personal data at any time.
- Right of opposition. You have the right to oppose the processing of personal data concerning you for marketing purposes.
- Right to restriction. If applicable, you have the right to ask Coinmerce to restrict the processing of your personal data. This means that your personal data (temporarily) cannot be processed or changed.
- Right to erasure. If applicable, we will erase your personal data without undue delay (the ‘right to be forgotten’).
< - Right to object. If applicable, you have the right to object to the processing of personal data concerning you based on Coinmerce’s legitimate interest and other bases.
- Right to data portability. If applicable, we will provide you with an overview of the personal data you have provided to us, enabling the transfer of these data to another controller, all to the extent that this is technically feasible (data portability).
- Right to lodge a complaint. Finally, you have the right to lodge a complaint with the supervisory authority if you believe that your personal data are being processed contrary to this privacy statement.

If you wish to exercise any of your rights, you may do so by contacting us using the contact details provided below. We will handle your request with due observance of applicable laws and regulations.

9. Contact details

Should you have any questions about this Privacy Policy or how we process your personal data, or if you wish to exercise any of your rights stated above, please contact Coinmerce by sending an email to [email protected]

This Privacy Policy is updated from time to time.