Privacy Policy for COBINHOOD EXCHANGE This Privacy Policy describes how COBINHOOD Exchange ("COBINHOOD"),
cryptocurrency to cryptocurrency exchange owned by BEING, INC., an exempted company incorporated under the laws of the Cayman Islands with an address on The Grand Pavilion Commercial Centre, Oleander Way, 802 West Bay Road, P.O. Box 32052, Grand Cayman KY1-1208, Cayman Islands, processes your personal data whenever you use cobinhood.com, a COBINHOOD mobile app, any COBINHOOD API or third party applications relying on such an API, or any other COBINHOOD services (collectively, the “Services”).
We may periodically post changes to this Privacy Policy on this page, and it is your responsibility to review this Privacy Policy from time to time to ensure you have reviewed the most recent version thereof. When required by law, we will notify you of any changes to this Privacy Policy.
Last updated: May 24, 2018
A. HOW COBINHOOD COLLECTS INFORMATION ABOUT YOU
When you use the Services, we collect information sent to us through your computer, mobile phone, or other access device for the purposes as set forth hereunder. In addition to personal data listed in this Privacy Policy, we also collect certain Cookies information which you may find in a separate Cookies Policy on COBINHOOD website.
COBINHOOD does not target its websites, mobile app, API, or any of the Services at children. COBINHOOD does not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.
If you create an account or use the Services, we, or our affiliates or Vendors (as defined hereunder) acting on our behalf may collect the following types of information for the purpose as set forth hereunder:
Account Information – your email address and password;
Contact Information – your name, birth of date, address, phone number;
Identity Verification Information - our ID number, image of your government issued ID, passport, national ID card, driving license, your selfie along with the above mentioned ID documents, and FATCA (Foreign Account Tax Compliance Act) related information;
Financial Information - withdrawal address, source of fund, the number of bank account linked with your COBINHOOD account, and image of bank statement or similar information;
Nationality/Residence Verification Information - your address, nationality, country of residence, and utility bill or similar information; and/or
Survey Information - certain personally identifiable information you provide in response to our survey. This may include details about your education history, income and your employment;
Technical information - IP, login information, browser information, time zone setting , operating system and platform;
Information about your visit - full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We also use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookie Policy;
Information about geo-location - real-time location based information from your device at any time while you download or use our services. We may use this information to optimize your experience;
Information we receive from other sources - We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
As of the time of this version of Privacy Policy, we have engaged certain vendors for the following services that may collect your personal information (the “Vendors” or “Service Providers”)
(1) Internet infrastructure - cloud storage and cloud computing;
(2) Communication tools and platforms - SMS services, email services, and push notification, and customer support tool;
(3) Error collection tools - web page error message collection, APP crash tracking, web and APP experiment (A/B testing), and APP statistics;
(4) User behavior analysis - user behavior tracking tool and bot prevention tool; and
(5) Anti-money laundering tool - such as AML database.
If you seek permissions to raise digital currency buy and sell limits associated with your COBINHOOD account, we may require you to provide additional information to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal data. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect name and type of your computer, mobile device, or other access device, such as the name and device of your operating system, for fraud prevention purposes, to monitor for possible breach of your COBINHOOD account, and to identify any malicious software or other activity that may harm COBINHOOD or its users.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook, Google, Twitter and any other Third Party). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. If you associate an account managed by a third party with your COBINHOOD account and authorizing COBINHOOD to have access to this information, we may request your consent that COBINHOOD may collect, store, and use this information in accordance with this Privacy Policy.
Finally, we collect additional information that you provide voluntarily to our customer success team.
B. HOW COBINHOOD PROTECTS AND STORES PERSONAL DATA
Throughout this Privacy Policy, we use the term “personal data” to describe information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This Privacy Policy does not apply to personal data that has been anonymized so that it does not and cannot be used to identify a specific individual or be de-identified.
We store and process your personal and transactional data, including certain payment information, where COBINHOOD facilities or our service providers are located, including in EU and in the United States.
We store your personal data securely throughout the life of the your COBINHOOD account, unless otherwise for a shorter period required by this Privacy Policy. COBINHOOD will retain your personal data for a maximum of ten years or as necessary to comply with our legal obligations or to resolve disputes.
C. HOW COBINHOOD USES THE PERSONAL DATA WE COLLECT
Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to:
Provide the Services and requested customer support;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Customize, measure, and improve COBINHOOD Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and/or
Verify your identity by comparing your personal data against third-party databases.
We process your personal data on one or more of the following legal bases in accordance with applicable rules and regulations, including the General Data Protection Regulation (GDPR) in EU:
With the consent from you, we may provide you with Cobinhood and our Services. On the same basis, we may also optimize and enhance Cobinhood for all customers, or for you specifically;
For our legitimate business purposes, we may monitor the usage of Cobinhood, conduct automated and manual security checks of our Service, to protect our rights and perform our lawful obligations; and/or
In order to comply with legal obligations under applicable rules and regulations, we may conduct AML procedure, anti-fraud procedure, identity verification and authentication checks.
We will not use your personal data for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal data with third parties for the purpose of provide the Services. You may refuse to provide or may withdraw your consent at any time without adverse consequence. Your refusal and withdrawal of consent will have no effect on the services we provide hereunder, provided that such consent is not necessary for our performance of the Services hereunder.
We do not engage in individual automated decision-making.
We will never sell or rent your personal data to any third parties.
Any communications we send to you will either be related to your account or will be related to COBINHOOD services or products. In the event COBINHOOD sends any communication to you which is not related specifically to your account, COBINHOOD will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future.
D. HOW COBINHOOD SHARES PERSONAL INFORMATION WITH OTHER PARTIES
We may share your personal data with the following parties for the following reasons.
Various service providers. The Venders or service providers, as set forth in this Privacy Policy, are those under contract to help with parts of our business operations, such as know-your-customer procedure, bill collection, marketing, and technology services. Our contracts require these service providers to only use your personal data in connection with the services they perform for us and prohibit them from selling your information to anyone else.
Authorized Third Party Applications. If you authorize one or more third-party applications to access your COBINHOOD account, then information you have provided to COBINHOOD may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during you use of the Services.
Prospective M&A Partners. Our business plans may entail discussions with companies or other entities that we plan to merge with or be acquired by, or companies intending to acquire certain portions of our business. Should such a merger or acquisition occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal data. You will receive prior notice of any change in the applicable policy.
Law enforcement, government officials, or other third parties. We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure.
Miscellaneous. We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.
Before COBINHOOD shares your personal data with any third party, COBINHOOD will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.
If you establish a COBINHOOD account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a COBINHOOD website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
E. SPECIFIC CONSENT BY USERS IN THE EUROPEAN ECONOMIC AREA
If you are located in, or a resident of, the European Economic Area (“EEA”), we, with your specific and voluntary consent, may transfer your personal data to our affiliates and Vendors in the United States and Israel, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
The United States and Israel may not have protections in place for personal data as extensive as those within the EEA and may not provide adequate protection for personal data within the meaning of the GDPR. Although we rely on your explicit consent to the transfer rather than an alternative data transfer mechanism, we require our service providers to treat your personal data in strict confidence and use appropriate security measures to protect it.
You may refuse to give or revoke your consent to this international transfer of your personal data at any time by emailing [email protected] with the subject line “Revoke EEA data consent”. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use COBINHOOD and our services. You will have the ability to withdraw Digital Assets; however, all other functionality will be disabled.
F. SPECIFIC CONSENT BY USERS IN SINGAPORE
If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in the United States and Israel, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
The United States and Israel may not have protections in place for personal data as extensive as those within Singapore. However, we require our service providers, including BEING, Inc., to treat your personal information in strict confidence and use appropriate security measures to protect it. We also require them to uphold all of our other obligations under this Privacy Policy.
You may revoke your consent to this section at any time by emailing [email protected] with the subject line “Revoke Singapore data consent”.
G. HOW YOU CAN CONTACT US ABOUT PRIVACY QUESTIONS AND EXERCISE YOUR DATA SUBJECT RIGHTS
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page by emailing [email protected].
If you are located in, or a resident of, EEA, you have the following rights under EU data protection law :
Right of access: you can request information about your Personal Data and request a copy of that data.
Right of rectification: you can request that we correct or update your Personal Data if they are incomplete or incorrect by COBINHOOD at any time by submitting a request to: [email protected] with the subject line “Revise Personal Information”.
Right to restriction: you can request that we restrict the processing of your Personal Data.
Right to erasure: you can request erasure of your Personal Data, if the data are inaccurate or processed in a way which is incompatible with the purpose(s) pursued by us.
Right to data portability: if we process your Personal Data on the basis of a contract with you or based on your consent, you can request to receive your Personal Data in a structured, commonly used and machine-readable format, and ask us to transfer such data to a third party, where technically feasible. Furthermore, if you wish to have a copy of your ledger in COBINHOOD, you may download them by submitting a request to [email protected] with the subject line “Download Ledger”.
Right to objection: you can object to the processing of your Personal Data for direct marketing purpose at any time.
Right to lodge a complaint: you can lodge a complaint with a competent supervisory authority in the EU situated at your habitual residence, place of work, or place of alleged infringement of the GDPR.
Right to refuse or withdraw your consent: you can refuse to give and withdraw your consent to data processing at any time. You can also oppose processing of your Personal Data, based on our legitimate interests, including profiling based on this provision, on compelling grounds relating to your particular situation at any time.
Right not to be subject to automated individual decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to deactivate/delete your account: if you no longer wish to use our Services, you have the right to deactivate/delete your COBINHOOD account by submitting a request to [email protected] with the subject line “Deactivate/Delete Account”. Please note, however, that we may need to retain certain information for record keeping or regulation compliance purposes on a necessary basis.
If you want to exercise these rights, you can contact us at [email protected] .