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”):
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 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.
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:
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.
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.
Data Controller Contact
Manticore Labs OÜ
Metalli tn 3, 10615, Tallinn, Estonia
Contact details for Estonian Data Protection Inspectorate
39 Tatari St., 10134 Tallinn, Estonia
Telephone: (from abroad add +372) 627 4135