California Privacy Policy

Last Material Update: 30 June 2020

Introduction

Welcome to Crypto.com’s Privacy Policy under the California Consumer Privacy Act ("California Privacy Policy").

We respect your privacy and we are committed to protecting your personal information. This California Privacy Policy will inform you as to how MCO Malta Dax Limited ("Crypto.com", we, us, our) look after your personal information when using any of our products, services or applications (together the “Services”) or when visiting or using our websites, crypto.com, getmco.com and shop.crypto.com (“Site”) or mobile application (“App”).

This California Privacy Policy tells you about your privacy rights and how the California Consumer Privacy Act and its inherent California General Attorney Regulations protect you. Please also use the Glossary to understand the meaning of some of the terms used in the text below.

If you are not a California resident, please check our Global Privacy Notice.

Contents

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal information collected?
  4. How we use your personal information
  5. Disclosures of your personal information
  6. International transfers
  7. Data security
  8. Personal information retention
  9. Your legal rights
  10. Glossary
  11. Legal Right Explained

1. Important information and who we are

Purpose of this California Privacy Policy

This California Privacy Policy aims to give you information on:

  • what personal information is being collected about you,
  • whether your personal information is sold or disclosed and to whom,
  • the right to say no to the sale of your personal information,
  • the right to access your personal information,
  • the right to equal service and price, even if you exercise your privacy rights,
  • the fundamental principle that the rights afforded to you as a consumer and the obligations imposed on us as a business shall not adversely affect the rights and freedoms of other consumers.

In relation with your visits of our Site, or through your use of the Services and any data you may provide when you register for or use the Services, sign up for alerts or newsletters, contact us with a question or request for help, participate in any renewals, promotions or surveys.

The Site and the Services are not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.

It is important that you read this California Privacy Policy together with any other privacy notices or fair processing notices, we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This California Privacy Policy supplements other policies and privacy notices and is not intended to override them.

Business

MCO Malta DAX Limited is the Business responsible for the collection and use of your personal information through the Site, the Services and the App.

Data Protection Officer, Complaints and Contact details

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this California Privacy Policy. If you have any questions or complaints about this California Privacy Policy, our privacy practices or if you have a request to exercise your rights, please contact our DPO Team in the following ways:

Email:[email protected]

A toll – free telephone number +1 888-959-8091

In addition, you have the right to make a complaint about the way we process your personal information to the Information and Data Protection Commissioner (IDPC), Malta's supervisory authority for data protection issues.

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please feel free to contact us in the first instance.

Changes to the California Privacy Policy and your duty to inform us of changes

We keep our California Privacy Policy under regular review, and it shall be updated at least once every 12 months. This version was last updated on the date above written. If we change this California Privacy Policy and you have already registered with us, we will let you know by email or via a notification through the app.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-party links

The Site and App may include links to third-party websites, plug-ins and applications ("Third Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements. When you leave our Site or App, we encourage you to read the privacy policy of every Third Party Site you visit or use.

2. The data we collect about you

Personal information, means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de - identified data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped in categories as follows:

Category of Personal Information Specific Pieces of Personal Information
Identity Data
  • first name,
  • maiden name,
  • last name,
  • username or similar identifier,
  • title,
  • date of birth and gender,
  • a visual image of your face,
  • tax identification number,
  • national identity cards,
  • passports or other form of identification documents including proof of address such as utility bill or bank statement.
Contact Data
  • billing address,
  • delivery address,
  • home address,
  • work address,
  • email address and telephone numbers.
Financial Data
  • bank account,
  • payment card details.
Transactional Data
  • details about payments to and from you,
  • other details of any transactions you enter into using products and services you have purchased from us.
Investment Data
  • information about your:
    • investment objectives,
    • investment experience,
    • prior investments.
Technical Data
  • internet protocol (IP) address,
  • your login data,
  • browser type and version,
  • time zone setting and location data,
  • browser plug-in types and versions,
  • operating system and platform, and
  • other technology or information stored on the devices you allow us access to when you visit the Site or use the Services, such as friends lists or other digital content.
Profile Data
  • your username and password,
  • requests by you for products or services,
  • your interests, preferences, feedback and survey responses.
Usage Data
  • information about how you use:
    • our Site,
    • App,
    • products and services.
Marketing and Communications Data
  • your preferences in receiving marketing from:
    • us
    • our third parties
    • your communication preferences.

As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors, to check your identity for onboarding purposes. This data falls within the scope of special categories of data (see Special Categories of Data below). When we ask to collect a visual image of your face you will be asked for your specific consent. You can refuse to provide this, but it means that we will be unable to register you and provide you with the Services.

Special categories of personal information are data revealing your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. We will only use special categories of personal information for a specific purpose and if we are able to satisfy both the Lawful Basis requirements, as well as at least one of the following additional conditions:

  • You have given explicit consent;
  • Processing relates to personal information which are manifestly made public by the data subject;
  • Processing is necessary for the establishment, exercise of defence of legal claims, or
  • Processing is necessary for reasons of substantial public interest based on EU or EU Member State Law.
We are subject to the EU Anti-Money Laundering Directives 4 and 5 and the relevant EU Member States' law implementing them which require us to process for instance information from your ID documents including a photographic picture of you. See also row iv, in the table which describes the purposes for which we will use your personal information.

We also collect, use and share Aggregate Consumer Information such as statistical or demographic data for any purpose. Aggregate Consumer Information could be derived from your personal information but is not considered personal information in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Consumer Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this California Privacy Policy.

If you refuse to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal information collected?

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your IdentityContact and Financial  Data by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal information you provide when you:

  • apply for our products or services;
  • create an account;
  • subscribe to our services or publications;
  • make use of any of our Services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We will also collect Transactional Data and Investment Data. We may also receive Technical Data about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies through the Cookie Settings.

Third parties or publicly available sources. We also obtain information about you from third parties (such as employers, credit reference agencies and fraud prevention agencies) who may check your personal information against any information listed on other databases.

4. How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • For the provision of the Services.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • For business purposes we disclose your personal information as described in Section Disclosures of your personal information.
Please refer to the Section Glossary to find out more about the types of lawful basis that we will rely on to process your personal information.

Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. See below for further details on marketing.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

No Purpose/Activity Categories of personal information Lawful basis for processing including basis of legitimate interest
i. To register you as a new customer
  • Identity
  • Contact
  • Financial
  • Performance of a contract with you
  • Necessary to comply with a legal obligation (e.g. to comply with Anti-Money Laundering requirements)
ii. To process and deliver our Services and any App features to you including:
  • Execute, manage and process any instructions or orders, you make
  • Manage, process, collect and transfer payments, fees and charges
  • Collect and recover money owed to us
  • Identity
  • Contact
  • Financial
  • Transactional
  • Technical
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (e.g. to prevent abuse of our Services and promotions)
iii. To manage our relationship with you which will include:
  • Notifying you about changes to our terms or Privacy Policy
  • Asking you to leave a review or take a survey
  • Keep you informed of our company's business and product development
  • Identity
  • Contact
  • Profile
  • Transactional
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated, study how our customers use our products/services and how prospective customers respond to our marketing campaign)
iv. To manage risk and crime prevention including:
  • Detect, investigate, report and prevent financial crime in broad sense
  • Obey laws and regulations which apply to us
  • Responding to complaints and resolving them
  • Identity
  • Contact
  • Financial
  • Technical
  • Transactional
  • Investment Data
  • Special Categories Data that you give us directly or that we receive from third parties and/or publicly available sources:
    • special categories data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);
    • special categories data that is revealed by photographic ID although we do not intentionally process this personal information;
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to develop and improve how we deal with financial crime)
  • For Special Categories Data it's necessary for reasons of substantial public interest under the EU Anti-Money Laundering Directives 4 and 5 and the relevant EU Member States' laws implementing them.
v. To enable you to partake in a prize draw, competition or complete a survey
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaign and growing our business)
vi. To administer and protect our business, our Site and App(s) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
  • Identity
  • Contact
  • Financial
  • Technical
  • Transactional
  • Investment Data
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
  • Necessary to comply with a legal obligation
vii. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
viii. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy)
ix. To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Investment Data
Necessary for our legitimate interests (to develop our products/services and grow our business)
x. Relevant for individuals related to partnering companies
  • Corresponding with partnering organizations
  • Invoicing, billing and other business enquiries related to the partnering organizations
  • General management of relationships with partnering organizations
  • Identity (partially)
  • Contact (partially)
  • Performance of a contract with partnering organizations
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

Promotional offers from us

We may use your IdentityContactTechnicalTransactionalUsage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please refer to our main website.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. Disclosures of your personal information

We may share your personal information with our third party service providers, agents, subcontractors and other associated organizations, our group companies and Affiliates in order to complete tasks and provide the Services to you on our behalf. When using third-party service providers, they are required under written agreements, to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We may pass your personal information (Identity Data, Contact Data, Financial Data, Transactional Data, Investment Data, Technical Data, Profile Data, Usage Data) to the following entities:

  • companies and organizations that assist us in processing, verifying or refunding transactions you make via our App or the MCO Visa Card and in providing any of the Services that you have requested;
  • identity verification agencies to undertake required verification checks;
  • fraud prevention agencies to help fight against financial crime including fraud, money-laundering and terrorist financing;
  • mobile application developers;
  • organizations which assist us with customer service facilities;
  • anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant Terms & Conditions governing the use of any of the Services;
  • any third party as a result of any restructure, sale or acquisition of our group or any Affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
  • regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law allows or requires us to do so.

6. International transfers

We share your personal information within our group. This will involve transferring your personal information outside the European Economic Area (EEA) or the origin of where your personal information is collected.

Many of our external third parties are based outside the EEA so their processing of your personal information will involve a transfer of data outside the EEA.

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
(https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en)

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
(https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en)

Where we use providers based in the US, we may transfer personal information to them if they are part of the Privacy Shield Program which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission:
EU-US Privacy Shield
(https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en)

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

Depending on the nature of the risks presented by the proposed processing of your personal information, we will have in place the following appropriate security measures:

  1. organizational measures (including but not limited to staff training and policy development);
  2. technical measures (including but not limited to physical protection of data, pseudonymization and encryption); and
  3. securing ongoing availability, integrity and accessibility (including but not limited to ensuring appropriate back-ups of personal information are held).

We have put in place procedures to deal with any suspected personal information breach and will notify you and any relevant regulator of a breach where we are legally required to do so.

If you want to know more about our security practice, please visit the following link:
https://crypto.com/en/security.html

8. Personal Information retention

How long will you use my personal information for?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including ContactIdentityFinancial and Transactional Data) for at least 5 years. For example, under the EU Anti-Money Laundering legislation (Anti-Money Laundering Directives 4 and 5) we are obliged to retain your personal information for a period of 5 years after the end of the relationship between us as a company and you as a customer.

For the purpose of defending our legitimate interests against possible legal claims, please note that correspondence (e.g. email addresses and content, chats with the customer service team, call recordings etc.) will be kept up to 10 years, depending on the limitation period (a limitation period is a time period during which a claim can be made) applicable in your country, after the end of the relationship between us as a company and you as a customer.

Another example relates to our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer's personal information for the time of the promotion in order to prevent the appearance of abusive behavior.

Please note that under certain condition(s), your can ask us to delete your personal information. In some circumstances we will de-identify your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under the data relevant legislation in relation to your personal information:

  • Right to know about personal information collected, disclosed, or sold. ("Verifiable Consumer Request to Know").
  • Request correction of your personal information.
  • Request erasure / deletion of your personal information. ("Verifiable Consumer Request to Delete")
  • Object to the processing of your personal information.
  • Request restriction of processing your personal information.
  • Request transmission of your personal information to another entity.
  • Right to withdraw consent.
  • Right to opt-out of the sale of your personal information
  • Right to Non-Discrimination for the Exercise of a Consumer's privacy Rights. You will not receive a discriminatory treatment by us for the exercise of the privacy rights set out above.
  • If you wish to exercise any of the rights set out above or if you want to raise a question or a concern about our privacy policy and practices, please contact us at [email protected] or at our toll-free telephone number: +1 888-959-8091. Detailed information on your legal rights could be found in Section "Legal rights explained".
We will promptly take steps to disclose and deliver to you, free of charge your personal information according to your Verifiable Consumer Request to Know.

Please note that:

If we decide not to take action on your Request for disclosure, we will inform you about the reasons for not taking action. We will send the response without delay and at the latest within one month of receipt of the request.

Under the California Consumer Privacy Act, we are not obliged to honor your Verifiable Consumer Request to Know more than twice in a 12-month period.

You will not have to pay a fee to exercise a Verifiable Consumer Request to Know (or to exercise any of the other rights enlisted in this California Privacy Policy). However, we may charge a reasonable fee if your request(s) is manifestly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. In case of refusal you will be notified for the underpinning reasons.

What we may need from you

Please note, that the law obliges us to use:

  1. a Reasonable degree of certainty (e.g. matching at least two data points) for requests for Disclosure of Categories of Personal Information or
  2. a Reasonable high degree of certainty (e.g. matching at least three data points) for requests for Disclosure of Personal Information and requests for deletion.
In our case the reasonable degree of certainty will be also determined considering the fact that we operate in the Fintech domain. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all verifiable consumer requests within one month of receipt. If extension is needed, we will notify you for the reasons within the initial one month.

10. Glossary

Terminology Explanation
Lawful Basis
  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.
Business

Legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that collects consumers' personal information, or on the behalf of which such data is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.*

*This is not the full legal definition and is tailored specifically for the needs of the present privacy policy.
Verifiable consumer request

a request that is made by:

  • a consumer,
  • by a consumer on behalf of the consumer's minor child, or
  • by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer's behalf,

and that the business can reasonably verify to be the consumer about whom the business has collected personal information. The verification is performed under the applicable California legislation.

A business is not obligated to provide information to the consumer if the business cannot verify, pursuant to the applicable California legislation, that the consumer making the request is the consumer about whom the business has collected information or is a person authorized by the consumer to act on such consumer's behalf.

Business purpose

the use of personal information for the business’s or a service provider’s operational purposes, or other notified purposes, provided that the use of personal information shall be reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.

Business purposes are (the list is not exhaustive):

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

11. Legal Rights Explained

Verifiable Consumer Request to Know enables you to:

  • Receive a copy of the specific pieces of personal information and the categories of personal information that we have collected about you.
  • Receive information on:
    • the categories of sources from which the personal information is collected,
    • the business purpose for which we collect your personal information,
    • the categories of third parties with whom we share your personal information,
    • the categories of personal information that we disclosed about you for a business purpose.

Verifiable Consumer Request to Delete personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure / deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Please note that:

We can honor your request ONLY if it is a verifiable consumer request.

Depending on the status of our relationship with you, to verify your request we may need:

  • the type and the last four digits of your ID which is registered with us and/or,
  • last four digits of the phone number used for registration and/or,
  • selfie, the list is not exhaustive.

The additional information we may need you to provide will be solely used for the purpose of verification. In that sense, to perform the verification we will also use any personal information previously collected from you.

If you want to make a request under the California Consumer Privacy Act through a natural person or a business entity authorized to act on your behalf, please beforehand contact us and in a due time we will provide you with a reply on how to designate such a person.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen (where technically feasible), your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.