Privacy policy
This Privacy Policy (collectively "agreement") was written in English (US). To the extent any translated version of this agreement conflicts with the English (US) version, the English (US) version controls.
Please read this agreement completely when using Coinvert which is owned and operated by Coinvert B.V. This agreement documents the legally binding terms and conditions attached to the use of Coinvert.
This is a contract between you and Coinvert B.V. a private limited company incorporated in the Netherlands chamber of commerce registration number 41228766 and whose registered office is Keizersgracht 482, 1017 EG Amsterdam, Netherlands. By using, accessing or signing up to Coinvert or any associated websites, APIs, or mobile applications (collectively "Coinvert"), you agree that you have read, understood, and accept all of the terms and conditions contained in this Agreement.
Changes to this agreement
We reserve the right to modify this agreement at any time, and when required by law, we will notify you of changes to this agreement. If we make any material changes these will be visible on the web page of this agreement. If you have an account with us, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective. By continuing to use our services after any changes to this agreement, you agree to the latest and leading version of this agreement. All prior versions of this agreement become invalid.
Acceptance of privacy policy
By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Coinvert may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify Coinvert privacy practices or may provide you with additional choices about how Coinvert processes your data.
Our relationship to you
Coinvert B.V. a private limited company incorporated in the Netherlands chamber of commerce registration number 41228766 and whose registered office is Keizersgracht 482, 1017 EG Amsterdam, Netherlands, which handles Payment requests and Digital Currency transactions.
As data controllers, we determine the means and purposes of processing data in relation to cryptocurrency transactions. If you have any questions about your Coinvert Account, your personal information or this Privacy Policy, please direct your questions to support@coinvert.me.
The personal information we collect
Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.
You may be asked to provide personal information anytime you are in contact with Coinvert services. The Coinvert services may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content.
Except as described in this Privacy Policy, Coinvert will not knowingly give, sell, rent or loan any personal Information to any third party.
Personal information collected
We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.
For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for a Coinvert event. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Policy.
We may collect some the following types of information about you:
Personal Identification Information
Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
Formal Identification Information
Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
Financial Information
Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
Transaction Information
Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
Employment Information
Office location, job title, and/or description of role.
Online Identifiers
Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
Usage Data
Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.
How your personal information is used
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
To maintain legal and regulatory compliance
Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, Coinvert must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. In certain cases, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements.
EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.
To enforce our terms in our user agreement and other agreements
Coinvert handles very sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our terms.
To provide Coinvert Services
We process your personal information in order to provide the Services to you. For example, when you want to acquire a Digital Currency, we may require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.
To provide Service communications
We process your personal information in order to provide the Services to you. For example, when you want to acquire a Digital Currency, we may require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.
To provide Service communications
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
To provide customer service
We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
To ensure quality control
We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.
EEA Residents: For all of the above categories, excluding the first bullet point, pursuant to EEA Data Protection Law, we process this personal information based on our contract with you.
To ensure network and information security
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legal obligations.
For research and development purposes
We process your personal information to better understand the way you use and interact with Coinvert Services. In addition, we use such information to customize, measure, and improve Coinvert Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To enhance your service experience
We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To facilitate corporate acquisitions, mergers, or transactions
We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To engage in marketing activities
Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Services and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy on your consent.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features of the Coinvert Services may not be available to you.
Information from third party sources
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.
Public Databases, Credit Bureaus & ID Verification Partners:
We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records, financial records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, banking information, status on any sanctions lists maintained by public authorities, and other relevant data.
We obtain such information to comply with our legal obligations, such as anti-money laundering laws. Pursuant to EEA Data Protection Law, our lawful basis for processing such data is compliance with legal obligations. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.
Collection & use of information collected automatically
We receive and store certain types of information automatically, such as whenever you interact with the Websites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at the Site via an external link, such as a link appearing on a third-party site.
Why we share personal information with other parties
We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. Coinvert will never sell or rent your personal information. We will only share your information in the following circumstances:
We share your information with third party identity verification services in order to prevent fraud. This allows Coinvert to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
We share your information with financial institutions with which we partner to process payments you have authorized.
We may share your information with companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
We may share your information with companies or other entities that purchase Coinvert assets pursuant to a court-approved sale under Dutch bankruptcy law and / or where we are required to share your information pursuant to insolvency law in the Netherlands or in any other jurisdiction.
We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.
How we protect and store personal information
We understand how important your privacy is, which is why Coinvert maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the Netherlands and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption. We authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Coinvert staff.
However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at support@coinvert.me.
Compromise of information
In the event that any information under our control is compromised as a result of a breach of security, Coinvert will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Payment processing
Coinvert only does business with licensed payment processing/service providers, however Coinvert may, in its sole discretion, develop a feature that allows Coinvert to process the payments in-house.
Cryptocurrency processing
Coinvert only does business with licensed cryptocurrency platforms, however Coinvert may, in its sole discretion, develop a feature that allows Coinvert to purchase cryptocurrency in any other method such as the creation of an in-house exchange or purchasing and/or selling directly off the blockchain. Coinvert may in its sole discretion decide to migrate its current holdings to another location should the need arise to do so.
Analytics information
We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
Cookies information
Full details can be found on our Cookie Policy. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets Coinvert help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you shut down your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.
Log file information
Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Links to Other Websites and Services
We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services.
Commercial and marketing communications
We use the information we collect or receive, such as your email address, to communicate directly with you. We may send you emails containing newsletters, promotions, and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails. You may also be able to be “found” on Coinvert based on information that you provide (see “Find friends on Coinvert”) above.
How you can access or change your personal information
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking Account tab.
If you close your Coinvert Account, we will mark your account in our database as "Closed," but will keep your account information in our database for a period of time. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
Rights in relation to the use of your personal information
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us at support@coinvert.me.
Retention of personal information
We store your personal information securely throughout the life of your Coinvert Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
Recording of our telephone calls with you may be kept for a period of up to six years.
Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
International transfers of personal information
While Coinvert B.V. is based in the Netherlands (which is within the EEA), our service providers may store, transfer, and otherwise process your personal information in countries outside of the country of your residence, including the United States, and possibly other countries. We use approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland, or require that any third-party located in the U.S. receiving your personal information is certified under the E.U.-U.S. and/or the Swiss-U.S. Privacy Shield Frameworks and require that the third party agree to at least the same level of privacy safeguards as required under applicable data protection laws.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please contact us at support@coinvert.me.
EEA Users & data
If you are a resident of the EEA, Coinvert B.V. is a controller with respect to your personal information. This controller determines the means and purposes of processing data in relation to payment requests and cryptocurrency transactions.
Legal bases for processing personal information
Our legal bases for processing under EEA Data Protection Law are described above in the sections entitled “How Your Information Is Used” and “Information from third-party Partners.” We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of Coinvert, our customers or others.
Individual Rights
EEA Residents have the following rights, which can be exercised by logging into your account and going to the Account tab. or contacting us at support@coinvert.me so that we may consider your request under applicable law.
Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of Coinvert processing based on consent before your withdrawal.
Right of access to and rectification of your personal information
You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by Coinvert that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
Right to erasure
You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your personal information public and are obliged to erase the personal information, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal information that you have requested the erasure of any links to, or copy or replication of your personal information. The above is subject to limitations by relevant data protection laws.
Right to data portability
If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.
Right to restriction of or processing
You have the right to restrict or object to us processing your personal information where one of the following applies:
(a) You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
(b) The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
(d) You have objected to processing, pending the verification whether the legitimate grounds of Coinvert processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
Notification of erasure, rectification and restriction
We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.
Right to object to processing
Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
Right to lodge a complaint
If you believe that we have infringed your rights, we encourage you to contact us first at dpo@coinvert.me so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.
Storage of your personal information
Coinvert will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.
Data Protection Officer:
You may reach the Coinvert Data Protection Officer at dpo@coinvert.me.
Your rights to personal information are not absolute. Access may be denied when:Denial of access is required or authorized by law;
Granting access would have a negative impact on other's privacy;
Granting access would have a negative impact on other's privacy;
To protect our rights and properties; and
Where the request is frivolous or vexatious.
Complaints
You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place. In the UK, the relevant data protection authority is the Information Commissioner's Office (ICO).
Contact
If you have any questions about this agreement, please feel free to contact us at support@coinvert.me.