Foris DAX Inc. Privacy Policy

Effective Date: June 1, 2021

Introduction

Welcome to the Privacy Policy of Foris DAX, Inc. (“Privacy Policy”).

We respect your privacy and we are committed to protecting your personal information. This Privacy Policy will inform you as to how Foris DAX, Inc., a company incorporated under the laws of Delaware, with a registered address: 10752 Deerwood Park Boulevard, South Waterview II, Suite 100, Jacksonville, FL 32256, and its affiliates ("Crypto.com", we, us, our) handle your personal information when using any of our products, services, or applications (together, the “Services”) or when visiting or using our websites or mobile application (collectively, “Site”).

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

Contents

  1. Important informationa and who we are
  2. The information 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. Personal information security
  7. Personal information retention
  8. Your legal rights
1. Important information and who we are
Purpose of this Privacy Policy

This Privacy Policy describes your privacy rights and how you can exercise these rights.

It is important that you read this Privacy Policy together with any other notice or policy that we may provide on certain 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 Privacy Policy supplements but is not intended to override those other notices or policies.

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 Privacy Policy. If you have any questions or complaints about this Privacy Policy, our privacy practices or if you have a request to exercise your rights, please contact our DPO in the following ways:

Email: [email protected]
Phone (toll free): +1 888-959-8091

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

We review and update our Privacy Policy from time to time. Please refer to the effective date at the top to determine when the most recent version took effect.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

Third-party links

The Site 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 and data security practices. When you leave our Site, we encourage you to read the privacy notice of every Third-Party Site you visit or use.

2. The information we collect about you

Personal information is a broad term which includes 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).

The definition of personal information includes the specific pieces of personal information which we have described below. Depending on whether and how you use our Services or Site, 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
  • full name
  • maiden name
  • username or similar identifier
  • title
  • date of birth and gender
  • biometric information
  • tax identification number
  • national identity cards
  • passports, driving licenses or other form of identification documents
    Social Identity Data
    • your group/company data
    • information on referrals related to you
    • political background
    • close connections
    • behavioral data
    • risk assessment
    • compliance assessment
    Contact Data
    • residence details
    • billing address
    • delivery address
    • home address
    • work address
    • email address and telephone numbers
    • proof of address documentation
    Financial Data
    • bank account
    • payment card details
    • virtual currency accounts
    • stored value accounts
    • external account details
    • source of funds and related documentation
    Transactional Data
    • details about payments to and from you
    • other details of any transactions you enter into using the Services or Site
    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
    • other information stored on or available regarding the devices you allow us access to when you visit the Site or use the Services
    Profile Data
    • your username and password
    • your identification number as our user
    • information on whether you have Crypto.com account and the email associated with your accounts
    • requests by you for products or services
    • your interests, preferences and feedback
    Usage Data
    • information about how you use:
      • the Site
      • mobile applications
      • Services
      • other offerings made available by us
    Marketing and Communications Data
    • your preferences in receiving marketing from us or third parties
      • your communication preferences
      • your survey responses

    We also collect certain biometric information (e.g. visual image of you), which we use, in conjunction with our sub-contractors, to verify your identity for onboarding purposes.

    Certain personal information may be sensitive and used only in accordance with applicable law

    We may also collect, use, and share information that has been anonymized or de-identified, including statistical or demographic data, for any purpose (“Aggregate Consumer Information”). 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 pursuant to applicable law.

    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, including the ability to offer or provide or continue to provide Services or other functionality.

    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 Identity Data, Social Identity Data, Contact Data,Financial Data,Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Services, by email, through the Crypto.com App or otherwise. This includes personal information you provide when you:

    ● visit the Site
    ● apply for, access or attempt to access the Services
    ● create or modify an account
    ● subscribe to our publications
    ● use any of the Services
    ● request marketing to be sent to you
    ● enter a competition, promotion or survey, including through social media channels
    ● give us feedback or contact us

    Automated technologies or interactions. As you interact with us via our Site, we will automatically collect Technical Data about your equipment, browsing actions, activity, and patterns. We collect this data by using cookies, server logs, and other similar technologies. We will also collect Transactional Data, Investment Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies. You may find more information about how we use cookies through the Cookie Preferences.

    Third parties or publicly available sources. We also obtain information about you, including Social Identity Data from third parties or publicly available sources. These sources may include:

    ● fraud and crime prevention agencies
    ● a customer referring you
    ● public blockchains
    ● publicly available information

    4. How we use your personal information

    We will only use your Personal Information in accordance with applicable law. For the most part, we will use your Personal Information in the following ways:

    ● To provide Services
    ● When necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
    ● To comply with a legal obligation
    ● For business purposes and in accordance with this Privacy Policy
    ● When you use our Services, our authorized partners may collect categories of personal information about you and use this data for their own purposes. This activity may qualify as a sale under the California Consumer Privacy Act (“CCPA”). Under the CCPA, you can make choices to allow or prevent such uses

    Purposes for which we will use your personal information We have set out below an illustrative example of the common ways we may use your Personal Information.

    Purpose/Activity Categories of personal information
    To register you as a new customer
    • Identity Data
    • Social Identity Data
    • Contact Data
    • Financial Data
    • Technical Data
    To carry out and comply with legal and compliance obligations
    • Identity Data
    • Social Identity Data
    • Contact Data
    • Financial Data
    • Technical Data
    • Profile Data
    • Transactional Data
    To process and deliver the Services and any features and functionality
    • Identity Data
    • Contact Data
    • Financial Data
    • Investment Data
    • Transactional Data
    • Technical Data
    • Marketing and Communications Data
    To prevent abuse of our Services, Site, and promotions
    • Identity Data
    • Contact Data
    • Financial Data
    • Transactional Data
    • Technical Data
    • Profile Data
    • Marketing and Communications Data
    To manage our relationship with you which will include notifying you about certain changes to our terms or Privacy Policy, asking you to leave a review, take a survey or keeping you informed of our business and product development
    • Identity Data
    • Contact Data
    • Profile Data
    • Investment Data
    • Transactional Data
    • Marketing and Communications Data
    To keep our records updated and to evaluate how customers use our products/services
    • information about your:
      • Identity Data
      • Contact Data
      • Financial Data
      • Profile Data
      • Investment Data
      • Transactional Data
      • Technical Data
      • Usage Data
      • Marketing and Communications Data
    To manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to us
    • Identity Data
    • Contact Data
    • Financial Data
    • Transactional Data
    • Social Identity Data
    To ensure proper management of our payments, fees and charges and collection and recovery of payments owned to us
    • Identity Data
    • Contact Data
    • Financial Data
    • Transactional Data
    • Social Identity Data
    To manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them
    • Identity Data
    • Social Identity Data
    • Contact Data
    • Financial Data
    • Technical Data
    • Transactional Data
    • Investment Data
    • Usage Data
    • Sensitive personal information that you give us directly or that we receive from third parties and/or publicly available sources:
      • sensitive personal information which might be revealed by fulfilling our customer identification program requirements
    To enable you to partake in a prize draw, competition or complete a survey
    • Identity Data
    • Contact Data
    • Profile Data
    • Usage Data
    • Marketing and Communications Data
    To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business
    • Identity Data
    • Contact Data
    • Profile Data
    • Usage Data
    • Marketing and Communications Data
    To administer and protect our business, the Site, and social media channels including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
    • Identity Data
    • Contact Data
    • Financial Data
    • Technical Data
    • Transactional Data
    • Investment Data
    • Usage Data
    To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
    • Identity Data
    • Contact Data
    • Profile Data
    • Usage Data
    • Marketing and Communications Data
    • Technical Data
    • Transactional Data
    • Usage Data
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
    • Technical Data
    • Usage Data
    To make suggestions and recommendations to you about goods or services that may be of interest to you
    • Identity Data
    • Contact Data
    • Technical Data
    • Usage Data
    • Profile Data
    • Marketing and Communications Data
    • Investment Data
    To use the services of social media platforms or advertising platforms some of which will use the personal information they receive for their own purposes, including marketing purposes
    • Technical Data
    • Usage Data
    • Profile Data
    To use the services of financial institutions, crime and fraud prevention companies, risk measuring companies, which will use the personal information they receive for their own purposes
    • Identity Data
    • Social Identity Data
    • Contact Data
    • Financial Data
    • Transactional Data
    • Investment Data
    • Technical Data
    • Usage Data
    • Profile Data
    To record voice calls and other conversations for compliance, quality assurance, and training purposes
    • Identity Data
    • Social Identity Data
    • Contact Data
    • Financial Data
    • Transactional Data
    • Profile Data

    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 Personal Information 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. You may receive marketing communications from us if you have requested information from us or used the Services and have not opted out of receiving that marketing.

    Opting out

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

    Further, you can let us know directly that you prefer not to receive any marketing messages by emailing [email protected].

    When you opt-out of receiving these marketing messages, this will not apply to service messages which are directly related to use of our Services (e.g. change in the terms and conditions or this Privacy Policy).

    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 review the Cookie Preferences.

    Change of purpose

    We will only use Personal Information in accordance with this Privacy Policy and applicable law.

    Sale or transfer of business We may need to process your Personal Information in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or a part of our shares, business or assets.

    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, provide the Services, and use of the Crypto.com App to you on our behalf, and otherwise fulfill our obligations. When using third-party service providers, we request they respect the security of your Personal Information and treat it in accordance with the law.

    We may share your Personal Information and other data you provide to us for the following purposes:

    ● To verify your identity.
    ● To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.
    ● To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
    ● To improve our information, technology, and security systems including websites and mobile applications.
    ● To provide customer service.
    ● To promote our Services if you submit a product review or post content on public areas of our Services, or social media accounts.
    ● To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
    ● To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.
    ● To evaluate, effectuate, or otherwise transfer your personal information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.

    We may have disclosed (or sold) the following categories of personal information to the following categories of third parties:

    Categories of Third Parties Categories of Personal Information
    Companies and organizations that assist us in processing, verifying or refunding transactions or orders
    • Identity Data
    • Financial Data
    • Transactional Data
    • Technical Data
    Identity verification agencies
    • Identity Data
    • Contact Data
    Fraud or crime prevention agencies
    • Identity Data
    • Social Identity Data
    • Financial Data
    • Transactional Data
    Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services All the categories in the table under Section The information we collect about you above
    Any third party because of any restructure, sale or acquisition of our group or any affiliates The categories would depend on the nature of the restructure, sale or acquisition
    Regulatory and law enforcement authorities, where the law allows or requires us to do so All the categories in the table under Section The information we collect about you above

    We disclose Personal Information to third parties only in accordance with applicable law.

    6. Personal Information security

    While there is an inherent risk in any information being shared over the internet, we have put in place commercially reasonable security measures to prevent your Personal Information from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful 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 legitimate business need to know. They will only process your Personal Information on our instructions.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a qualifying breach when required.

    If you want to know more about our security practice, please visit this link.

    7. Personal Information retention
    How long will you use my personal information for?

    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 unauthorized 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.

    Here are some exemplary factors which we usually consider when determining how long we need to retain your Personal Information and data:

    ● in the event of a complaint;
    ● if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims, the respective personal information (e.g., email addresses and content, chats, letters) will be kept in accordance with the statutory limitation period applicable following the end of our relationship;
    ● to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal information, including relevant sanctions regimes:
    - under the Bank Secrecy Act and its related statutes we are obliged to retain your Personal Information for a period of at least 5 years after the end of our relationship;
    - information needed for audit purposes;
    ● in accordance with relevant industry standards or guidelines;
    ● in accordance with 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 and for a certain period after its end to prevent the appearance of abusive behavior.

    Please note that under certain conditions, you can ask us to delete your Personal Information.

    8. Your legal rights

    Under certain circumstances, you may have certain rights in relation to your Personal Information:

    ● Right to know about Personal Information collected, and how it is used and disclosed.
    ● Right to request correction of certain Personal Information.
    ● Right to request deletion of certain Personal Information.
    ● Right to opt-out of the sharing of certain Personal Information.

    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.

    When allowed by applicable law and required, we will take steps to disclose and deliver to you, free of charge, your Personal Information accordingly. We may also contact you to ask you for further information in relation to your request to speed up our response.

    If you are a Californian resident, you also have the right to know about Personal Information sold. In addition, you may also opt-out of the sale of your personal information. Please follow the “Do Not Sell My Personal Information” link on our homepage or landing page.

    If you are a Californian resident, please also note that there are some exceptions related to your Personal Information that is subject to Gramm-Leach-Bliley Act. Information we collect for the purposes of complying with these financial regulations is not covered by CCPA (and therefore may not be subject to deletion requests). Due to the different scope of the regulations, some of your Personal Information we collect could still be subject to the CCPA.

    Non-Discrimination

    You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.

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

    App

    The purpose of this website is solely to display information regarding the products and services available on the Crypto.com App. It is not intended to offer access to any of such products and services. You may obtain access to such products and services on the Crypto.com App.

    Please note that the availability of the products and services on the Crypto.com App is subject to jurisdictional limitations. Crypto.com may not offer certain products, features and/or services on the Crypto.com App in certain jurisdictions due to potential or actual regulatory restrictions.

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