GoCoin Pte. Ltd.
In operating the Company Websites and Payment Gateway, the Company may require you to register for an account to utilize the Services. When opening an account or electing to receive email newsletters and offers from us, we will collect personal information from you, such as your full name, email address, phone number, Crypto wallet address, financial and banking information, and other information that may be used to personally identify you, specifically for Know Your Customer (“KYC”) reviews (collectively “Personal Information”). We will only collect data from third parties with your authorization and consent, solely for the purpose of providing the Services to you through the Company Websites and Payment Gateway. As described below, Personal Information does not include any anonymized aggregated data that is collected for analysis and reporting purposes.
In some situations, the Company may need to request additional information from you in order to provide the Services to you. We may also collect additional information from you when you contact us for customer service issues or when responding to Company surveys.
Purposes of collecting Personal Information
We use the Personal Information you provide for the specific purposes of:
You may choose to not provide us with Personal Information or any requested additional information, understanding that your ability to use the Company Websites, Payment Gateway and the Services may be impacted if you do not provide the minimum information necessary to complete a transaction on the Company Websites and Payment Gateway.
With your consent, we may also obtain additional Personal Information and non-Personal Information from third party providers.
If you provide us Personal Information about others, or if others give us your Personal Information, we may store that data and will only use that Personal Information for the specific purpose of delivering Services to you.
Usage and Other Information
When you use our Company Websites and Payment Gateway for Services, we collect usage data and other information regarding your communications, transaction history and interactions with the Company Websites and Payment Gateway and other users using cookies (see the “Cookies” section below) or other similar technology.
The Company Websites and Payment Gateway are supported by a network of computers, cloud-based servers and other infrastructure and information technology including but not limited to third-party service providers. Your Personal Information is processed within and outside of the United States. By using the Company Websites and Payment Gateway you consent to your Personal Information possibly being transferred and processed outside of the United States, even to countries that have different data protection rules and requirements than your country of residence, subject to the transfer restrictions set forth in the General Data Protection Regulation (“GDPR”) specifically limiting transfers to countries identified on the Official Journal of the European Union website as having adequate levels of data protection policies.
We collect information that your device sends whenever you visit the Company Websites and Payment Gateway (“Log Data”). This Log Data may include information such as your device's Internet Protocol (“IP”) address, details about how you used the Company Websites and Payment Gateway, the time and date of your visit, your location, the time spent on the Company Websites and Payment Gateway and other statistics. You may choose to not have us collect this information, understanding that it may impact your ability to use the Company Websites, Payment Gateway and the Services. The Log Data is retained by the Company for a period of no longer than 6 months from the date it is collected.
From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Company Websites and Payment Gateway, and your use of the Services. We only store Personal Information in cookies to identify you as a user and to enhance and customize the Services provided to you on the Company Websites and Payment Gateway. Cookies also allow us to learn which areas of our Company Websites and Payment Gateway are useful and which areas need improvement, and cookies provide us with marketing data for analysis. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this functionality, your experience on the Company Websites and Payment Gateway may be diminished and some features may not work as intended.
[Do Not Track (DNT) is an optional browser setting that allows you to limit your sharing preferences with respect to third parties. We do not respond to DNT signals.]
We may communicate with you through multiple channels about your transactions on the Company Websites and Payment Gateway and to keep you up-to-date on promotions, offers, customer experience content and new products or services. We may also use the information you provide to send you marketing communications.
Once you provide your Personal Information, we may contact you through e-mail or text messages, if you choose to provide your mobile telephone number. We may continue to communicate with you through the channels you have selected until you request to stop receiving these communications by opting out. Before sending you mobile marketing we will require your express consent by requesting that you opt-in during your account setup process or upon completing a transaction on the Payment Gateway.
At any time, you may elect to (a) stop receiving marketing communications by opting out or unsubscribing, or (b) update or delete your account and any Personal Information details.
Uses of Information
We use information about you to provide the Services to you through the Company Websites and Payment Gateway and for other business purposes described in the Purposes of Collecting Personal Information section of this Policy.
We do not sell, rent or trade your individual Personal Information to third parties without your consent. We may, however, share, sell or rent aggregated data with third parties for analysis and research purposes. This aggregated data would only consist of anonymized data.
Your Personal Information may be shared with current or future affiliates or subsidiaries of the Company.
In limited circumstances, we may need to share your Personal Information with third parties that perform services on our behalf in order to complete a transaction on the Payment Gateway. In order for the Company connect your Company Websites and Payment Gateway account with your account from third-party platforms, we will require your affirmative consent, understanding that your Personal Information may be shared with such third-party platforms.
From time to time, we may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may share Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves. We may also transfer Personal Information in the event of a corporate sale, merger, acquisition, dissolution or similar event.
Your Personal Information is retained as long as you are continuing to use the Company Websites, Payment Gateway and the Services. If you decide to close your account, the Company will continue to store and share your Personal Information as described in this Policy unless you provide a written request to [email protected] to have your Personal Information deleted, understanding that the Company shall retain copies of transaction history on the Company Websites and Payment Gateway for the Company’s record keeping purposes.
Third Party Websites
At times we may partner with a third party to create a site that may look as if you are on a Company page. These sites may be co-branded or may have the look and feel of being on the Company Websites and Payment Gateway. However, the information collected on these pages may not be covered under our Policy. It is your responsibility to review the privacy policies of those websites to confirm that you understand and agree with their policies.
Information from Children Under 13
We are a general audience website and do not direct any of our content specifically at children under the age of 13 years old. We understand and are committed to respecting the sensitive nature of children’s privacy online and we do not knowingly collect information online from children under 13. If you are a parent or guardian and you learn that your children have created an account or otherwise provided Company with Personal Information, please contact us. If Company becomes aware that Company has collected Personal Information from a child under age 13 without verification of parental consent, Company will take steps to remove that information from Company servers.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, information with respect to the types of Personal Information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To request a copy of the information disclosure provided by the Company pursuant to Section 1798.83 of the California Civil Code, please contact [email protected].
European Union’s General Data Protection Regulation
Residents of the European Union have the right under the GDPR to request from a business, with whom the European Union resident has an established business relationship, information with respect to the types of Personal Information the business collects and processes. Further, such residents of the European Union may also request a portable copy of such resident’s Personal Information collected by the business and may also request changes to any incorrect Personal Information collected. Such residents may also restrict a business’s processing activities and sharing of Personal Information with third-parties and may request that such resident’s Personal Information be deleted altogether.
To request such information from the Company pursuant to the GDPR, please contact [email protected].
Security of Your Personal Information
We use reasonable security measures, including but not limited to physical, electronic, and procedural safeguards, to protect the confidentiality of Personal Information under our control and appropriately limit access to Personal Information, including Secure Sockets Layer (“SSL”) protection technology.
The Company Websites and Payment Gateway have security measures in place to prevent the loss, misuse, disclosure and alteration of the Personal Information that we obtain from you, but we make no assurances to you or to any third party about our ability to prevent any such loss or misuse arising out of any such loss, misuse, disclosure or alteration as a result of any malicious cyber attacks against the Company, interruptions in telecommunications, utility, Internet services or network provider services, disruption or malfunction of the Bitcoin network or other cryptocurrency network, acts or omissions of a third party, infiltration or disruption of the Service by a third party by any means, including without limitation, 51% attacks, DDoS attacks, software viruses, Trojan horses, worms, time bombs or any other software program or technology designed to disrupt or delay Services, could impair the Company’s ability to complete your transactions.
We also avoid storing your user passwords in plain text. While we use the security measures described above along with others, we cannot ensure or warrant the security of any information you transmit to us by e-mail, and you do so at your own risk.
If we become aware of a security breach involving your Personal Information, we may need to notify you electronically of such breach, in addition to posting information about the breach on the Company Websites or Payment Gateway. By using the Company Websites, Payment Gateway and Services, you agree to receive such communications. Please contact us at [email protected] if you would like to withdraw your consent to receiving such communications or to request a free written notice of a security breach from the Company, upon providing us with a mailing address, as applicable.
As we continue to improve the Company Websites, Payment Gateway and Services, products and the features we provide, this Policy is subject to change. We will post significant changes to this Policy here and/or other formats for you to review. If we change our information practices or this Policy in such a way that your Personal Information may be used or shared in a manner not described in the Policy at the time you provided it, we will give you the opportunity to opt-out of having your Personal Information used or shared in that new manner.
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GoCoin Pte. Ltd.
Last updated: June 18, 2018