Privacy Policy – 20 November 2022
Our Privacy Policy explains how Coinbits or its legal affiliates (“Coinbits”, “we” or “us”) collect, use, or disclose personal information and data we receive through access to and use of the Coinbits website, mobile applications, and any other online services (the “Services”). This policy applies to information we collect through the Services. It does not apply to information collected by: (i) Us offline or through other means; or (ii) Any third party. The policy also gives you choices about the collection and use of your information.
- “Personal Information” means any information that directly or indirectly identifies a natural person, including by reference to an identifier such as a name, an identification number, location data, or an online identifier.
- Generally, we process this Personal Information with your consent, to perform or enter into contracts with you, in conformance with our legitimate business interests (e.g., maintaining the security and integrity of the Services, enforcing the terms and conditions and Privacy Policy associated with the Services, monitoring the use and performance of the Services, quality assurance of our customer service operations, and product improvement and development) where your interests do not outweigh our interests, and to comply with legal obligations. We retain the Personal Information as described below in this Privacy Policy.
Please read the Privacy Policy carefully before you start to use the Services. By using the Services you agree to be bound and abide by the User Agreement (available above and at https://coinbits.app/), this Privacy Policy, our Prohibited Use Policy, and Prime Trust’s Terms of Service and Privacy Policy. If you do not agree to the mutual Terms of Use, Privacy Policies, and/or our Prohibited Use Policy, the choice is yours to not use the Services. If you violate them in any way, your right to access or use the Services is terminated.
Please see Section 20 of the User Agreement regarding restrictions on your legal rights in any dispute involving the Services, User Agreement, or Privacy Policy.
You understand that we may revise and update the Privacy Policy from time to time in our sole discretion. Where appropriate, we may seek to provide advance notice before an updated Privacy Policy becomes effective. You agree that we may notify you of the updated Privacy Policy by posting it on the Services (such as on our website), and that your use of the Services after the effective date of the updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement to the updated Privacy Policy. It is your responsibility to check the Privacy Policy posted on the Services periodically so that you are aware of any changes, as they are binding on you. If you do not agree to the changes to this Privacy Policy, you should request deletion of your Personal Information by contacting us at support@coinbits.app.
By using the Services, you represent and warrant that you are of legal age to form a binding contract with Coinbits and meet all of the eligibility requirements in the User Agreement.
1. Information we collect
We may collect the following types of information.
Information you voluntarily provide
- Username and Password
- Personal Information, such as your name, email address, address, and phone number
- Payment information, such as such as credit card, PayPal, bank, or other financial account information, and billing address
- User Contributions
- Communications between you and Coinbits
Information that is passively collected
- Analytics information. We may use proprietary or third-party analytics tools to help us measure traffic and usage of the Services. Such information is generally not associated with any particular individual.
- Cookies and similar technologies. When you use the Services, we may use “cookies” (small text files stored on your computer) and other similar technologies like pixels, web beacons (also known as “clear GIFs”), and local storage may be used to collect information about how you use the Services and provide features to you. We may also ask advertisers or other third-party partners to serve ads or features through the Services, which may use cookies or similar technologies. If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. We may share non-Personal Information obtained via cookies with our advertisers and affiliates. If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
- Log file information. When you use a device to connect to the Services via a service provider that uniquely identifies your device, we may use this unique identifier to offer you extended services and/or functionality. Log file information may be automatically reported by your browser or device when you request access to, or download content from, the Services. When you use the Services, we may automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information, to allow for an improvement of Services. We may also collect similar information from emails sent to our users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.
- Metadata. Metadata is usually technical data that is associated with content. For example, Metadata can indicate how, when and by whom a User Contribution was collected and how that content is formatted, and sometimes, for content like pictures, they may also include location information about where the Content was recorded (i.e., geotags).
2. How we use your information
In general, we use Personal Information to:
- Quickly process your transactions.
- Provide you with customer support.
- Comply with third party contracts.
- Help you efficiently access your information after you sign in and remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
- Provide personalized content and information to you and others, which could potentially include online ads or other forms of marketing;
- Develop, provide, improve, test, troubleshoot, and monitor the effectiveness of the Services and new products or features.
- Monitor metrics such as total number of visitors, traffic, and demographic patterns.
We may use Personal Information for any purpose otherwise allowed by applicable law, including to market our products to you, the products of our affiliates, or the products of unaffiliated third parties.The processing of your Personal Information for these purposes is based on your consent or on our legitimate interests. You may opt-out from receiving marketing-related communications by either clicking on the unsubscribe link at the bottom of marketing-related emails we send you. We will process opt-out requests without undue delay.
3. Sharing your information
We do not sell personal information about users to third parties without users’ consent. Parties with whom we may share your information:
- Third-Party Service Providers and Affiliates. We may either employ or partner with third-party companies for the purposes of advertising, facilitating, or enhancing the Services. In order for these third-party companies to carry out their services, your Personal Information and other data collected may be shared with these third-party companies (including, without limitation, maintenance services, server hosting, database management, and web analytics).
- Government, Regulatory Agencies, Courts, and Law Enforcement. We may access, preserve, and share any information about you, without your consent, to government or law enforcement officials or private parties if we believe in good faith that it is necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, including Know Your Customer and Anti-Money Laundering laws, to protect the property and rights of Coinbits, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is, illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of audits, inquiries or investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
If you voluntarily share or submit any information (e.g., name) or content (e.g., picture), or commentary (e.g., forums, message boards, chats) through the Services, or link it to any social media platforms, that post and any content or information associated with it may become available to the public.
4. How we store and protect your information
By registering for and using the Services you consent to the transfer of information to anywhere in the U.S. where the Services or our Service Providers maintain facilities, and to the use and disclosure of information about you as described in this Privacy Policy.
Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information. Although the Services are intended to provide reasonable administrative, physical and electronic security measures to protect Personal Information from unauthorized access, use, modification, or deletion, we cannot ensure the security of any information you transmit to or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or public posting via the Services, you agree to accept notice in that form.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services. The information you share in public areas may be viewed by any user of the Services.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures on the Services.
5. Your choices about your information
Your account information and profile/privacy settings.
Text messaging. To the extent text messages are provided by the Services, you may opt-out at any time by replying “STOP” to any text message received.
Emails. In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to ten (10) business days for us to process your opt-out request. Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them, such as administrative notices, or services-related communications, e.g., account verification, payment and withdrawal confirmations, technical and security notices.
Cookies. If you do not want information collected through the use of cookies, most browsers allow you to reject cookies. Note however that this may negatively impact functionality or features provided by the Services.
6. What happens in the event of a change of control
We may share all or some of your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control to be used in a manner consistent with this policy. Additionally, in the event we go through or undergo due diligence in anticipation of a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires such Personal Information by transfer may continue to process your Personal Information as set forth in this Privacy Policy.
If we transfer part or the whole of Coinbits or our assets to another organization, your information such as name and email address, public posts and any other information Coinbits has collected may be among the items transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.
7. How long we keep your information
We consider several factors to determine how long we keep Personal Information. We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. Once we no longer have a need for your Personal Information, we will securely destroy it in accordance with our standards and applicable laws and regulations. Coinbits may in its discretion elect to retain Personal Information only while deemed necessary for business, legal and tax purposes.
8. Accessing and correcting your information
You may send us an email at support@coinbits.app to access, to correct or delete any Personal Information you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We do not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Services users. Proper access and use of information provided on the Services, including User Contributions, is governed by our User Agreement.
California residents may have additional Personal Information rights and choices. Please see Your California Privacy Rights for more information.
9. Your California privacy rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@coinbits.app.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. The following may only apply to California residents.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation or potential legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an email to support@coinbits.app. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, send an email to support@coinbits.app with the title "Do Not Sell My Personal Information". Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
10. Your Nevada privacy rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statues Chapter 603A may send an email to support@coinbits.app. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
11. Children's privacy
Our Services are not intended for children under age 16. No one under age 16 may provide any Personal Information to or on the Services. If you are under 16, do not use or provide any information on the Services. In the event that we learn that we have collected Personal Information from a person under age 16 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a person under 16, send an email to support@coinbits.app.
IF YOU ARE A CALIFORNIA RESIDENT UNDER THE AGE OF 18, DO NOT SHARE ANY PERSONAL INFORMATION ON ANY FORUM OR MESSAGE BOARD. If you do post any Personal Information, you can remove it using available functionality or by sending a request to support@coinbits.app. This removal may not be complete given the nature of the Internet.
9. How we respond to "do not track" signals
Coinbits does not track its users over time and across third-party websites to provide targeted advertising. Coinbits does not respond to Do Not Track (DNT) signals and handles all user information consistent with its User Agreement and this Privacy Policy.
10. Other websites and services
Coinbits and the Services may contain links to other websites and services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Your browsing and interaction on any third-party website or service, including those that have a link on the Services, are subject to that third party’s own rules and policies, not ours.
In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your Personal Information. If you are using a third party website or service and you allow them to access your Personal Information you do so at your own risk.
11. International considerations
We have developed data practices designed to assure information is appropriately protected but we cannot always know where Personal Information may be accessed or processed. While our primary facilities are in the United States and the information we collect is governed by U.S. law, we may transfer Personal Information or other information to facilities outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to our employees outside of the United States, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and applicable privacy laws.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by us as a Data Controller (as that term is defined under the General Data Protection Regulation referenced below) of all personal data processed by Prime Trust (the “Data Processor” as that term is defined under the General Data Protection Regulation referenced below), from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. We have appropriate measures in place to protect your Personal Information, such as EU Standard Contractual Clauses. You may email privacy@coinbits.app to request a copy of the safeguards we have in place. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.
Depending on your country of residence, you may have certain privacy rights under applicable law. For example, European Union Regulation 2016/679 (General Data Protection Regulation) includes certain rights pertaining to access, correction, erasure, restricting processing, and portability of individuals’ personal data (Articles 15-18 and 20). While we take various steps to ensure the accuracy and completeness of your Personal Information, we rely upon you to provide accurate and complete Personal Information when interacting with us. All persons in the scope of the General Data Protection Regulation whose Personal Information is being processed by Coinbits have the legal right to request of their Personal Information:
- Access
- Rectification
- Erasure
- Restriction of processing
- Object to processing
- Data portability
If you are in the EU, you also have the right to lodge a complaint with an EU supervisory authority. However, if you have a complaint regarding the processing of your Personal Information, we kindly request that you first contact us directly as indicated below, and we will reply promptly. To exercise any of such rights or for any data protection related queries, please submit a request to privacy@coinbits.app.
12. How to contact us
Please direct questions or concerns about this Privacy Policy or Coinbits and the Services to Coinbits at support@coinbits.app.
The effective date of this Privacy Policy is November 16th, 2022, with last revision on November 16th, 2022.