Privacy and cookie policy
PRIVACY POLICY

The privacy practice of collecting and processing of personal data provided by the Clients to Bitspace AG, legal entity duly incorporated in Swiss Confederation with registered number CHE-443.118.327 is described hereby. The provisions of this Privacy Policy are subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“Regulation”) and the Federal Data Protection Act of 19 June 1992 (Swiss Confederation). 

INTRODUCTION  

We understand the importance of protection of your privacy and personal data and commit a lot of efforts to develop and maintain high standards of inner security measures and technologies to provide you with secure processing and storage of the data we collect from you; and keep your data safe against unauthorized or unlawful processing and against accidental loss, destruction or damage.

1. PERSONAL DATA WE COLLECT AND OBJECTIVE 

1.1. When registering for an account via Bitspace AG we collect and further process the following categories of data: 

     (a) Information requested during the registration of the account that identifies you, for example your name, date of birth, citizenship, etc. 
     (b) Financial information, including your income, source of income / funds, taxation residence information, etc.  
     (c) Your identity and residency verification documents, for example passport and/or ID card, utility bill, etc.  
     (d) Contact information, i.e. your phone number, e-mail address, etc.
 
1.2. We are obliged by applicable laws to maintain records of personal data for ten years after the termination of a client relationship, this term may be extended upon request by the local competent authority.
  
1.3. We collect and process the abovementioned data to fulfil our contractual obligations and legitimate interest before you, namely:
 
     (a)  provide services, including execution of requested transactions and related maintenance of the services you registered for and manage the account you hold; 
     (b)  provide you with the information about your activities within the account; 
     (c)  inform about any changes and updates to the services you are provided with; 
     (d)  assess and mitigate risks related to anti-money laundering and terrorism financing regulations as well as transaction related risks; 
     (e)  comply with applicable legislation; 
     (f)  maintain actions in relation to legal claims; 
     (g)  provide additional or supportive services, as well as perform Client surveys and statistical analysis;  
     (h) convery marketing activities; 
     (i)  improve the performance and functionality of our services.
  
The above list may be extended depending on the development of the services.    

2. PROCESSING OF YOUR PERSONAL DATA

2.1. Your personal data may be received and processed: 

     (a) by Bitspace AG within our inner systems of processing, which complies to technical and organizational measures in a manner that meets applicable requirements of Regulation and security standards; and/or 
     (b) by 3rd party service providers and processors who access and use the data only to the extent required to perform the obligations subcontracted to them by Bitspace AG (hereinafter – ‘subprocessors’).  

2.2. Those subprocessors perform tasks on our behalf and are contractually obligated not to disclose or use collected information for any other purposes, than storage, help in facilitation of technical aspects of our services or perform functions related to the administration of services (collection and analysis) or other indicated under contractual closes.
  
2.3. Client specifically agrees that Bitspace AG may to its own discretion engage subprocessors, that comply with technical and organizational measures in a manner that meet applicable requirements of Regulation and security standards implied under this Privacy Policy.
  
2.4. If such subprocessors are outside of Swiss Confederation or the European Union or European Economic Area, the processing of personal data is done or will be done in accordance with the applicable laws.
  
2.5. Subprocessors remain fully liable for all obligations subcontracted to, and all acts and omissions of, Bitspace AG is not responsible if the information is disclosed as a result of a breach or security lapse at any such subprocessors, or for such subprocessors' non-compliance with the foregoing requirements. 

3. INCIDENTS NOTIFICATION

3.1. If Bitspace AG becomes aware of any breach of our security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities) personal data of Clients on systems managed or otherwise controlled by us we will notify you promptly and without undue delay and in compliance to the procedure prescribed under respective Regulation.
  
3.2. The notification will be sent to your e-mail address at the discretion of Bitspace AG or by other direct communication channel available to Bitspace AG and allowed by Client (for example, by phone). It is sole responsibility of the Client to provide us with the e-mail address and ensure that this e-mail address is valid and active.
 
3.3. None of Data Incidents notification from Bitspace AG may not be and will not be construed as an acknowledgment of any fault or liability with respect to data incident by us. 

4. CLIENT’S SECURITY COMMITMENTS
    
4.1. Client agrees that without prejudice to our security measures and data incidents that it is Client’s responsibility to make appropriate use of our services to ensure a level of security appropriate to the risk in respect of your personal data and securing your authorization credentials, system and devices which you use to access to our services.
  
4.2. We are not obliged to protect your personal data that you choose to store or transfer outside Bitspace AG and our subprocessors’ systems.  

5. CLIENT’S RIGHTS IN RESPECT TO HIS PERSONAL DATA 

5.1. You may access and amend your personal data, request the details about purposes of processing of your personal data and prevent undesirable marketing activities by opting-out. If you wish to opt-out of marketing activities, use ‘unsubscribe’ option available within our e-mails.
 
5.2. Client may also send a request to receive the information which has been processed, amended, deleted or locked and information about any parties to which we transmit your personal data.
 
5.3. In some case we may charge a fee (based on our reasonable costs) if the requests are excessive considering the nature of the request itself or nature and functionality of our services.. 

6. COOKIE & SIMILAR TECHNOLOGIES 

6.1. We also use cookies and similar technologies for collecting technical information, which contains your unique identifiers.  We automatically receive the web address of the site that you came from and the IP address of the computer or device that you are using to access the Bitspace AG website. This information helps us to understand your preferences, improve website navigation, allows to develop and improve our services, and better manage our servers.
  
6.2. If you prefer to prohibit the usage of cookies, please use your browser settings. Most browsers give you an ability to manage your cookies or provide you with an “incognito mode” or similar features, which allows you to not record your visits and downloads in your browsing and download histories. In this mode any cookies created during this type of session are deleted after you close all “incognito” windows.
 
For more details please check our Cookie policy.

7. CHANGES TO THESE PRIVACY POLICY

7.1. Please note that we may amend this Privacy Policy from time to time at our sole discretion. Therefore, please check this Privacy Policy for updates. If any significant updates with regard to the data processing terms are made here, we will notify you additionally within reasonable time period via e-mail provided by you.

8. CONSENT

By applying for an account with Bitspace AG, you consent to the collection, processing and receipt of your personal data, as described in this Privacy Policy.

9. CONTACT DETAILS
  
If you require any additional information or have any further questions concerning this Privacy Policy, please contact us at support@bitspace.ltd

COOKIE POLICY

A. Cookie is a small text file placed on your computer by websites that you visit.

B. They are widely used in order to make websites work more efficiently, as well as to provide information about functionality and behavior of the users on the site.

C. Cookie helps you to better interact with a website and helps a website to better interact with you. 

D. Cookie does not contain your personal data. 


1. We use cookies, tags (together - Cookie) to:

     (a) understand how you use website and to provide you with a safe, effective and user-friendly website; 
     (b) remember your settings, such as preferred language, type of the device, news already shown to you, your preference about Cookie allowance;  
     (c) keep opened sessions and conversation during your last visit to the website; 
     (d) identify the popularity of different sections of the website and improve them respectively;  
     (e) prevent and exclude unauthorized use of the website. 

2. We normally do not associate your account with your Cookie, however in exceptional cases we may use this option to prevent or avoid unauthorized use of the website and violation of applicable agreements between you and us. In this case we will treat this information as personal and process as described in the Privacy Policy. 

3. We use third party web analytics services that assist us in better understanding of our website use, those services are complied with the prescribed adequacy of security measures. For example, we use Google Analytics service powered by Google LLC (US). This service helps us to improve the effectiveness of our advertising efforts and understand your preferences and interests. It collects information and reports website usage statistics without personally identifying you – we use it for better delivery of our ads. Please check the details about Google Analytics services here: https://policies.google.com/technologies/partner-sites. However, in some cases Google can match information collected through Cookie with your Google account and use it under Google Privacy Policy explained here: https://policies.google.com/privacy.

4. If you do not want to share your Cookie you may restrict it or block it.  

4.1. If you prefer not to allow cookies, please use your browser settings, most browsers give you an ability to manage your cookies or provide you with “incognito mode” or similar options. For more information about how to disable cookies completely or how to amend your cookie settings check http://www.allaboutcookies.org/.

5. We also use similar technology and collect unique identifiers of our visitors of the website, the information we collect by this means includes:
  
     (a) Unique identification numbers, e.g. Internet protocol (IP) address and device ID; 
     (b) Your login information;  
     (c) As applicable to your type of device, browser type and version, and browser plug-in types and versions, application release and version, device model, manufacturer (brand), operating system, operating system version, OS library version, time of last seen, enable wifi, radio (EDGE, HSDPA, LTE, WCDMA, none), device screen (width, high, dpi), NFC, telecom operator, Bluetooth enable, Bluetooth version;  
     (d) Time zone setting, city, region, country and language; 
     (e) Operating system and platform; 
     (f) Information about your visit, including the full Uniform Resource Locators (URL) click stream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. 

5.1. We use this information for the same purposes as a Cookie.