CoinField Ventures OÜ (“CoinField”, “we” or “us”) are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy (the “Privacy Policy”) is to inform you about our privacy practices, including how we collect, use and disclose your personal information. This Privacy Policy applies to our website, mobile applications, digital asset trading platform, and related services (collectively, the “CoinField Services”). By visiting, accessing, or using CoinField Services, you consent to the policies and practices of this Privacy Policy so please read them carefully. If any policies or practices of this Privacy Policy are unacceptable to you, please do not visit, access, or use the CoinField Services.

• Privacy Policy Amendments
• Personal Information We Collect
• How we use personal information
• How we share personal information
• Privacy of Digital Assets
• Information Security
• Retention of personal information
• Rights regarding your Personal Information
• Direct Marketing
• Data Transfer
• Third Party Websites and Services
• Children's Privacy
• Contact Us

Your privacy matters to us so whether you are new to CoinField Services or a long-time user, please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time. But don’t worry, you can always find the latest version of this Privacy Policy here on this page. Visiting, accessing, or using the CoinField Services following any changes to this Privacy Policy is considered to be your acceptance of any such changes. You should, therefore, read this Privacy Policy from time to time. If you do not agree to be bound by this Privacy Policy, you should not visit, access, or use CoinField Services.

The personal information we collect about you may include the following. In each case, we identify the grounds that we rely on to process your personal information under the Estonian Personal Data Protection Act (“Act”) and the EU General Data Protection Regulation (the “ GDPR”):

• · Account Profile – when you open an account, we may collect your name, email address, phone number, home address, date of birth, social insurance number or any comparable identification number issued by a governmental authority and any other information or documentation we require for identity verification (e.g. driver’s license, passport or other government-issued ID) or other legal compliance purposes (for more information, please read our AML & KYC Policy). Applicable legal grounds: contract performance, consent, legitimate interests (to enable us to perform our obligations and provide our services);
• · Device Information – information that is automatically collected about your device, such as hardware, operating system, browser, etc. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
• · Location Information – information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
• · Log Information – information that is generated by your use of the CoinField Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity, and any internal and external information related to CoinField pages that you visit. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
• · Account Activity – information that is generated by your account activity including, but not limited to, trading activity, order activity, deposits, withdrawals, and account balances. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), legal claims, consent, contract performance;
• · Financial Account Transfer Information – information that you provide to us to facilitate the transfer of fiat currency or Digital Assets (as defined below) into and out of your CoinField account, such as your bank account information and public cryptocurrency wallet address (we do not collect private keys): Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance; and
• · Correspondence – information that you provide to us in correspondence, such as when you submit questions or inquiries and with respect to ongoing customer support. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), consent, contract performance.

CoinField may also make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (“Cookies”) on your computer or other devices used to access the CoinField Services. Cookies are small bits of information that are automatically stored on the web browser of your device that can be retrieved by us. The type of information we collect includes, but is not limited to, uniquely identifying visitor information and information related to usage preferences. We use these technologies to help us recognize you as a user, collect information about your use of the CoinField Services to better customize our services and content for you, and collect information about your computer or other access devices to (i) ensure compliance with our BSA/AML Program (for more information, please read our AML & KYC Policy) and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities. By using CoinField Services, you acknowledge and agree that we may collect and/or transmit any data collected to our third-party service providers, such as analytics providers, which may also make use of such technologies described above. Please note that if you block or delete cookies you will not be able to use some or all of the CoinField Services.

• We take steps designed to ensure that only those employees who need access to your personal information to fulfill their employment duties will have access to it. We may use the personal information we collect to:
• provide you with the CoinField Services, including customer support;
• optimize and enhance the CoinField Services, including developing new products, services, features, and functionality;
• respond to inquiries and other requests;
• conduct anti-fraud and identity verification checks, including by engaging third party services providers to assist with such checks (for more information, please read our AML & KYC Policy);
• provide you with information that we think may interest you, including in regards to our products and services;
• monitor the usage of the CoinField Services, including by conducting automated and manual security checks;
• understand and analyze the usage trends and preferences of our users;
• create aggregated and anonymized reporting data about the CoinField Services;
• investigate legal claims;
• carry out such purposes for which we may obtain consent from time to time; and
• carry out such other purposes as may be permitted or required by applicable law.

We may disclose your personal information to law enforcement and governmental entities when required by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We may also disclose your personal information to a third party in the event of any potential or completed reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business.

We rely on third-party services providers to perform a variety of services on our behalfs, such as identity verification, detection of fraud or security threats, telephone or technical support, payment card processing, hosting services, and data storage or processing, and we may transfer your personal information to our service providers for such purposes. Third-party service providers have access to and may collect personal information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures to protect your personal information.

As used herein, “Digital Asset” means a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as Bitcoin or Ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Please be aware that Bitcoin, Ether, and other Digital Assets are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public Digital Asset address. We, and any others who can match your public Digital Asset address to other information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, information published on a blockchain (such as your Digital Asset and IP address) can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of our security, anti-fraud, and/or identity verification and authentication checks, we may conduct such analysis to process such information about you. You acknowledge and agree to allow us to perform such practices.

We take your privacy very seriously and have implemented physical, organizational, and technological security measures with a view to protecting your personal information from loss or theft, unauthorized access, disclosure, copying, use, or modification. In particular, we encrypt the CoinField website with SSL; we require two-factor authentication for all user sessions; we periodically review information collection, storage, and processing practices; and we restrict access to your information on a need-to-know basis for our employees, contractors, and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we, unfortunately, cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

Under certain circumstances and in accordance with the Act and the GDPR or other applicable data protection laws, you have the following rights:

• Access – ask if we are processing information and, if we are, request access to your personal information. This enables you to receive a copy of the personal information we hold and certain other information about you;
• Corrections – request that any incomplete or inaccurate personal information about you that we hold be corrected;
• Erasure – ask us to delete or remove your personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with legal claims;
• Restriction – ask us to suspend the processing of your personal information, for example, to establish its accuracy or the reason for processing it;
• Transfer – request the transfer of certain personal information to another party;
• Objection – challenge our processing of personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information in certain circumstances;
• Automated decisions – contest any automated decision made where it has a legal or similar significant effect and ask for it to be reconsidered; and
• Consent – where we are processing personal information with consent, withdraw your consent.

You also have a right to make a complaint with a data protection supervisory authority, in particular in the Country (as defined below) where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us as set forth in the “Contact Us” section.

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you. If you no longer want to receive marketing-related communications from us, you may opt out of such communications by clicking the “unsubscribe” link at the bottom of emails you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. We will endeavor to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. We will not provide your information to third parties for direct marketing or other unrelated purposes without your written consent.

Please note that if you opt-out from receiving marketing-related communications, we may still need to send you communications about your use of our products or services, or other matters, subject to applicable laws and regulations.

Your personal information may be stored and processed in any country, province, or state (each a “ Country”) where we have facilities or in which we engage third-party service providers. As a result, your personal information may be transferred to Countries outside your country of residence, which may have different data protection rules than in your Country. While such information is outside of your Country, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts or law enforcement, or regulatory agencies of such other country, pursuant to the laws of such Country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and we will comply with the Act and GDPR requirements of providing adequate protection for the transfer of personal information from the EU/EEA to other countries. We confirm not to transfer data to the countries which are not covered by the adequacy decision of the European Commission.

This Privacy Policy applies only to CoinField Services and does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites or products, or services.

The CoinField Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access CoinField Services at any time or in any manner. If we learn that personal information has been collected on the CoinField Services from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided personal information, then you may alert us as set forth in the “Contact Us” section and request that we delete that child’s personal information from our systems.

For any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers, our Privacy Officer can be reached at compliance@coinfield.com.

• Data Controller Contact

  Manticore Labs OÜ

  Metalli tn 3, 10615, Tallinn, Estonia

  email: compliance@coinfield.com

• Contact details for Estonian Data Protection Inspectorate

  39 Tatari St., 10134 Tallinn, Estonia

  Telephone: (from abroad add +372) 627 4135

  email: info@aki.ee