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Privacy Policy
Effective 12 December 2024
Privacy Policy Scope
CoinJar Europe Limited (“CoinJar”) respects your privacy and is committed to protecting your Personal Data and being transparent about how we collect, use, and share your Personal Data. This Privacy Policy applies to this website or to any website that includes a link or reference to this Notice (together, the “Website”) and describes how we handle Personal Data (as defined below) and the choices available to you regarding collection, use, access and how to update and correct your Personal Data.
CoinJar Privacy Practices At A Glance
| Processing | Personal Data Collected and Processed | Legal Basis and Retention Time Period |
|---|---|---|
Setting up your account and enabling you to use the services | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. | Legal Basis: Necessary to fulfil our contractual obligations to you. Retention Time Period: Up to five years after the end of the customer relationship. |
To process your payments | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. Profile Data: this includes data regarding your deposits, withdrawals and trades on the Website and any cryptocurrency wallet addresses. Financial Data: this includes your Bank Identifier Code (BIC), IBAN (International Bank Account Number) and account name. | Legal Basis: Necessary to fulfil our contractual obligations to you. Retention Time Period: Up to five years after the end of the customer relationship. |
To allow you to buy and sell digital currency | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. Financial Data: this includes your Bank Identifier Code (BIC), IBAN (International Bank Account Number) and account name | Legal Basis: Necessary to fulfil our contractual obligations to you. Retention Time Period: Up to five years after the end of the customer relationship. |
To inform you of any changes we make to any of the services, the terms that govern them or this Privacy Policy | Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. | Legal Basis: Necessary to fulfil our contractual obligations to you. Retention Time Period: Until the end of the customer relationship. |
To comply with our anti-money laundering and know your customer obligations | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. Profile Data: this includes data regarding your deposits, withdrawals and trades on the Website and any cryptocurrency wallet addresses. Financial Data: this includes your Bank Identifier Code (BIC), IBAN (International Bank Account Number) and account name. | Legal Basis: Necessary to fulfil our contractual obligations to you. Retention Time Period: Up to five years after the end of the customer relationship. |
To contact you if you have any problems or queries | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. | Legal Basis:
Retention Time Period: Up to five years after the end of the customer relationship. |
Promoting and marketing our products and services, in particular but not limited to: via promotional emails, newsletters or other materials (e.g. to inform you of any new features or products, or updates to existing services we may make available from time to time) | Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. | Legal Basis:
Retention Time Period: Until the end of the customer relationship or up to four years after the last customer interaction with our promotional or marketing material. |
To manage and operate our services | Profile Data: this includes data regarding your deposits, withdrawals and trades on the Website and any cryptocurrency wallet addresses. | Legal Basis: Our legitimate interests to operate our services. Retention Time Period: Up to five years after the end of the customer relationship. |
To analyse and improve our existing services and identify and develop new services | Profile Data: this includes data regarding your deposits, withdrawals and trades on the Website and any cryptocurrency wallet addresses. | Legal Basis: Our legitimate interest of better understanding its customers’ needs, habits and preferences in order to improve its products and their experience. Retention Time Period: Up to five years after the end of the customer relationship. |
Defending in, initiating or resolving disputes or legal proceedings and performing or enforcing the agreements to which CoinJar is a party | Identity Data: this includes your first name, middle name, surname, date of birth, identity documentation, nationality, country of residence. Contact Data: this includes your address (business and/or residential), phone number(s), email address and any other contact details you may provide. Profile Data: this includes data regarding your deposits, withdrawals and trades on the Website and any cryptocurrency wallet addresses. Financial Data: this includes your Bank Identifier Code (BIC), IBAN (International Bank Account Number) and account name. | Legal Basis: Our legitimate interest to enforce or defend our rights. Retention Time Period: Up to five years after the end of the customer relationship. |
Personal Data We Collect
We collect data, including Personal Data that you provide on our Website and as you use the Website.
CoinJar aims at keeping the Personal Data we hold as accurate and up-to-date. Please ensure that the Personal Data you communicate to us is accurate and up-to-date.
If you fail to provide certain Personal Data when requested, we may not be able to perform the contract we have entered into with you (such as providing you with a product or service), or we may be prevented from complying with our legal obligations.
Each visitor to the Website may be identified by cookies or similar technologies (see our Cookies Notice ) as well as by an IP address during their visit. Please note that IP addresses are automatically captured when you visit the Website.
Personal Data We Collect From Other Sources
We and third parties we engage may combine data we collect from you over time and across our Website with data obtained from other sources. This helps us improve the data’s overall accuracy and completeness, and also helps us better tailor our interactions with you (see our Cookies Notice).
How we use your Personal Data
We only collect, use and store your Personal Data for the Purposes of operating our business, delivering, improving, and customizing our Website as well as products and services we provide, sending marketing and other communications related to our business, providing you with information, products and services that you request from us. For other legitimate Purposes we refer to the “At A Glance” table above.
How we share your Personal Data
Where required or permitted by Applicable Law, we use or disclose your Personal Data to limited third parties when we believe, in good faith, that such use or disclosure is reasonably necessary to (i) comply with the legal obligation bearing on CoinJar, (ii) enforce or apply the terms of any agreement to which we are a party, or (iii) protect the rights, property or safety of CoinJar, CoinJar’s clients, or others.
We may also share your Personal Data with other third-party business partners, providers, vendors or contractors acting on our behalf and under our instructions, whether located inside and outside of the European Union (“EU”) the Economic Area (“EEA”), or the United Kingdom (“UK”) for the Purposes of operating our business, delivering, improving, and customizing our Website as well as our products and services, sending marketing and other communications related to our business, to reply on job applications and when needed, with your consent.
Therefore, we may share Personal Data in the following ways:
- Within CoinJar and any of our affiliate entities located inside or outside of the EU/EEA/UK, for purposes of Personal Data Processing or storage in connection with the aforementioned purposes;
- With CoinJar’s business partners, vendors, authorized third-party agents or contractors to provide our products and services or facilitate transactions. Examples include, but are not limited to: processing of orders, hosting websites and providing support.
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by another company;
- If we share Personal Data with third parties for Purposes other than those listed above, CoinJar will, for further protection of your privacy, share your Personal Data in aggregated and/or de-identified form that cannot be used to identify you.
We may share Personal Data with third parties as listed below:
- Payments and Banking Providers: including Clear Junction Limited.
- Anti-Money Laundering and Identity and Compliance Providers: including Jumio Corporation, ComplyAdvantage and Notabene, Inc.
- Compliance Providers: GB Group plc and Sift Science, Inc.
- Blockchain Analytics Providers: including Chainalysis Inc.
- Customer Support Software Providers: including Zendesk, Inc.
Where mandated or permitted by Applicable Law, regulation or legal process, we will disclose your Personal Data to law enforcement officials, government authorities or other third parties, located inside and outside the country where you are located (including inside and outside the EU/EEA/UK), where such disclosure is in accordance with due process of law and binding upon CoinJar, to the extent necessary to comply with legal process or meet national security requirements, protect the rights, property, or safety of CoinJar, its business partners, you, or others.
Transfer, Processing and Storage of Personal Data
We may transfer your Personal Data to our affiliates or to third-party business partners, providers, vendors, or contractors, that are located inside or outside of the EU/EEA/UK (including Australia and the United States), for Purposes described in the section “How We Share your Personal Data” above, including for the Purpose of Personal Data Processing or storage on behalf and under the control of CoinJar.
International Transfers of Personal Data
CoinJar implements cross-borders transfers in compliance with Applicable Laws. Where mandated by Applicable Law, to ensure that your personal data does receive an adequate level of protection, CoinJar implements the appropriate measures to ensure that your Personal Data is transferred in a way that is consistent with and which respects Applicable Laws. Specifically, we rely on the standard contractual clauses published by the European Commission and similar measures under UK laws when we share your Personal Data within the CoinJar corporate group.
Links to third-parties’ websites
The Website may contain links to third-party websites that are operated by companies outside of our control. Your activities on those third-party websites will be solely governed by the privacy policies and procedures of those third parties. CoinJar takes no responsibility whatsoever for the content or information practices of such third parties and encourage you to review the privacy polices of these third parties before disclosing any information on their websites.
Security and confidentiality of your Personal Data
The security and confidentiality of your Personal Data is important to us. We implement appropriate physical, administrative, and technical measures and safeguards designed to protect your Personal Data from loss, theft, misuse, alteration, unlawful or unauthorized access, use, or disclosure.
CoinJar also relies on reasonable measures to safeguard Personal Data in our possession, including:
- Enforcement of group-wide policies and procedures on Personal Data use, security and confidentiality;
- Restricting access to Personal Data to only those employees and third-party service providers on a “need to know” basis and under strict confidentiality requirements;
- Use of technologies to safeguard data during transmission, such as SSL encryption for some of the data that you provide via the Website and using appropriate security measures to safeguard the data we collect and possess;
- Use of reasonable measures and processes for detecting and responding to inappropriate attempts to breach our computer systems and networks.
The Internet and any communication thereon cannot be guaranteed to be secure at all times, and we cannot ensure or warrant the security of any Personal Data you provide us through this technology. In this regard, we have procedures to deal with any suspected data security breach and will notify you and any regulator of a suspected breach, as mandated by law.
Your Rights in Connection with Personal Data
You have the right to:
- Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully Processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data that we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data after we no longer need to Process it.
- Object to Processing of your Personal Data if we are relying on our legitimate interest (or those of a third party) and your particular situation makes you want to object to Processing on this ground. You also have the right to object if we are Processing your Personal Data for direct marketing Purposes.
- Request the restriction of Processing of your Personal Data. This enables you to ask us to suspend the Processing of Personal Data about you if, for example, you want us to establish its accuracy or the reason for Processing it.
- Request the portability of the Personal Data you provided to another party, where your Personal Data is part of a Processing (i) based on (a) a contract with you or (b) your Consent, and (ii) is carried out by automated means.
If you want to review, verify, correct or request erasure of your Personal Data, object to the Processing of your Personal Data or request that we transfer a copy of your Personal Data to another party, please contact privacy@coinjar.com.
No Fee Usually Required
We do not charge a fee to give you access to your Personal Data or to exercise any of the other rights described above. We may, however, charge a reasonable fee if your request for access is clearly unfounded or excessive or we may refuse to comply with the request.
Right to Withdraw Consent
If for some reason you provided your Consent to the collection, Processing and transfer of your Personal Data for a specific Purpose, you have the right to withdraw your Consent for that specific Processing at any time. To withdraw your Consent, please contact privacy@coinjar.com. Once we receive notification that you withdrew your Consent, we will no longer Process your Personal Data for the Purpose or Purposes you originally agreed to, unless we have another legitimate basis for doing so under Applicable Law.
For how long will CoinJar use my Personal Data?
We will only retain your Personal Data for as long as necessary to fulfil the Purposes we collected it for, including for the Purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the Purposes for which we Process your Personal Data and whether we can achieve those Purposes through other means and the applicable legal requirements.
In some circumstances, we may anonymize your Personal Data so that it can no longer and irreversibly be associated with you. Once we anonymize your Personal Data, we may use the anonymized information without further notice to you. We will retain and securely destroy your Personal Data in accordance with our internal policies. Nothing in the foregoing shall prevent CoinJar from retaining copies of your Personal Data for the Purpose of compliance with Applicable Law, including any statute of limitation which may be applicable.
Children’s Privacy
CoinJar encourages parents and guardians to take an active role in their children's online activities. CoinJar does not sell or offer its products and services to children. As such, our Website is exclusively designed for adult user interaction. We do not intentionally collect Personal Data from children under the age of 18. If you are a parent or legal guardian of a minor under the age of 18 and believe that the minor has disclosed Personal Data to us, please contact us using the contact details provided in this Privacy Policy.
Choice and Opt-Out
We may send you service communications relating to the products or services we provide you via email (e.g. to inform you about changes to the product or service you requested from us, revisions of our terms and conditions or the Privacy Policy). As such service communications are necessary for the Purposes of providing you with our products or services or complying without legal obligations, you will not be able to opt-out from receiving them.
Subject to your choices, we may also send you marketing communications via email. In addition to the “unsubscribe” link contained in each of our e-mail marketing communications, you may opt-out freely and at any time of receiving CoinJar newsletters or other e-mail marketing communications from CoinJar by sending an e-mail to privacy@coinjar.com.
Updates to the Privacy Policy
We may update the Privacy Policy from time to time. We will post the most current version of this Privacy Policy with its effective date on our Website. Where such changes are substantial, we will notify you of the expected changes prior to their entry into force.
Contact Us
To ask questions or comment about the Privacy Policy and/or our privacy practices, you may contact us at privacy@coinjar.com.
You have a right to lodge a complaint with your local supervisory authority (a list of EU and UK national data protection authorities can be found (EU) and (UK)) if you have concerns about how we are Processing your Personal Data. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Definitions
a) Applicable Law(s): means all data protection laws and regulations applying to CoinJar processing of Personal Data including as may be the case: (i) the EU Data Protection Laws meaning the General Data Protection Regulation 2016/679/EU (“EU GDPR”) and laws and regulations supplementing the GDPR, and (ii) the “UK Data Protection Laws” and the Data Protection Act 2018 (“UK GDPR” – and together with the EU GDPR, the “GDPR”);
b) Consent: freely-given, specific, informed and unequivocal expression by a positive action by which Data Subject agree to the Processing of their Personal Data for a specific Purpose;
c) Personal Data: information relating to an identified or identifiable natural person;
d) Processing (or “Process”): any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, Processing, archiving, storage, elimination, assessment or control of information, modification, communication, transfer, dissemination or extraction; and
e) Purpose: means the reasons for which the Personal Data can be collected and Processed under Applicable Law.
Your information is handled in accordance with CoinJar’s .
CoinJar Europe Limited (CRO 720832) is registered and supervised by the Central Bank of Ireland (Registration number C496731) for Anti-Money Laundering and Countering the Financing of Terrorism purposes only.
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