Last updated: April 7, 2021
We collect, use and process certain personal information about you. When we do so we are subject to the EU General Data Protection Regulation 2016/679 (hereafter “GDPR”) and we are responsible as ‘Controller’ of that personal information for the purposes of the GDPR as well as Cyprus Law (125(I)/2018) providing for the protection of natural persons with regard to the processing of personal data and the free movement of such data.
It would be helpful to start by explaining some key terms used in this policy:
Personal information Any information relating to an identified or identifiable individual.
DXone Ltd. is the controller and responsible for your personal data.
Our Data Protection Officer (“DPO”) We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.
Scott McKenzie[email protected]
Full legal name of entity: DXone Ltd.
Full address: DXone Ltd., Floor 7, Novel Tower, Alexandrou Panagouli 1, Avenue, 6057 Larnaca, Cyprus
Complaints procedure: DXone Ltd. has the highest standards to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our Data Protection Officer. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
You have the right to make a complaint at any time to the Office of the Commission for Personal Data Protection in Cyprus. Their contact information can be found in Section 11. However, we would appreciate it if you could allow us the opportunity to address your concerns before you approach their office.
3. Information we collect about you
We will collect and process the following data about you:
- Information you give us: This is information about you that you give us by filling our client forms/agreements, or by corresponding with us by phone, email, in person or otherwise. It includes information you provide when you choose to use our services and/or become an affiliate to our company, participate in any company event and when you send any information to us under any capacity. This information may include but is not necessarily limited to the stated areas,
- Identity data such as name, address, date of birth, username or similar identifier, title, gender.
- Identity verification data such as the images of your government issued ID, passport, national ID card, utility bill or driving license, or other data related to KYC processes.
- Contact data including your address, messenger or social media handles, email address and telephone numbers.
- Financial data such as your financial position, status and history, and payment account details which can include bank, credit card, or other payment details.
- Transaction data which includes details about payments to and from your accounts with us.
- Technical data includes details about the devices you use to access our services including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or services.
- Blockchain data such as the blockchain addresses and public keys.
- Profile data like your username and password, purchases, posts, interests or other information you provide, preferences, feedback or survey responses.
- Social media data includes social media handles and other social media profile information that you make available to us or to the public.
- Usage data includes information about how you use our website, products and services.
- Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregated data includes statistical or demographic data for any purpose. This type of data can be created from personal data but legally is not considered personal data because it does not directly or indirectly reveal your identity. If this type of data is connected to your personal data so you are directly or indirectly identified, this will be handled under this privacy notice.
- Information we collect/receive from other sources: This is information we receive about you if you use any of the websites we operate or the services we provide and/or from other affiliates and/or professionals. We are working closely with third parties (including, for example, compliance partners, business partners, brokers, payment service providers including fiat on-ramps, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
In certain cases we require personal data by law, or under the terms of the service we are providing to you. If that data is not provided, we may not be able to complete the contract. If so, we will inform you if we have to cancel the service.
How we use your data
We use the information we collect about you in the following ways:
- To carry out our obligations and contracts arising from any agreements and/or contracts between you and us and to provide you with the information, products and services that you request from us;
- For our legitimate and permitted interests or those of a third party, for example, to prevent and detect fraud/unauthorized access to our systems that can be damaging to us and you and services or to study how customers use our products/services, to develop them, to grow our business, to inform our marketing strategy to develop new products/services and grow our business, and to provide additional tools and functions for our clients,
- To comply with our legal and regulatory obligations, for example, conducting checks to identify our customers and verify their identity as required by relevant regulations to which we are subject;
- To provide information to you with information about other services we offer that are similar to those that you have already used or enquired about or to notify you about changes to our services.
4. Disclosure of your information
You agree that we have the right to share your information with:
- Any team member of our company for the purpose of ensuring we maintain a correct record, understanding and response regarding all of your communications, requests, responses and interests with us and only as appropriate to ensuring a helpful, constructive business relationship between you and our company, this may include anyone in our group of companies including subsidiaries or our holding company or any of our agents or partners;
- Selected third parties we use to help deliver our products and/or services to you including: business partners, brokers, fiat on or off ramps, vendors, insurers, fraud prevention services, payment service providers for the performance of any contract we enter into with them or you; analytics and search engine providers that assist us in the improvement and optimization of our site;
credit reference agencies and/or banking and financial institutions and/or auditors for, among others, the purpose of assessing your credit score (where this is a condition of us entering into a contract with you).
- For the purposes of complying with local and international regulations against money-laundering, fraud and the general prevention of crime and illegal activities, we maintain communications with law enforcement agencies and regulatory bodies of those jurisdictions relevant to your citizenship and our legal requirements for compliance with those regulations including for tax reasons. This may include as well for the pursuit of our own legal claims.
We will disclose your personal information to third parties:
- In the event that this is necessary for the delivery of our products and/or services to you;
- If DXone Ltd., or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
We only allow the third parties we work with to process your personal information if we are satisfied they take appropriate technical and organizational measures to protect your personal information. We also impose contractual obligations on our selected third parties to ensure they can only use your personal information to provide services to us and to you. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions or as based on any notice provided to you.
5. Where we store your personal data
All information you provide to us is stored on secure servers. Where we may have given you (or where you have chosen) a password which enables you to access certain parts of our site and/or use any other of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6. Duration your personal information will be kept
We will keep your personal information while you have an account with us or while we are providing services and/or products to you or while we are in a contractual relationship with you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law, regulations and regulatory authorities.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
By law we are required to keep certain data for minimum periods, namely:
- we must retain Transaction Data for a minimum of six years after the date of the transaction;
- we must retain certain Account Information, for a minimum of six years after your agreement with us has ended.
The majority of personal data we hold will be deleted 10 years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes. In some circumstances you can ask us to delete your data: see request erasure below for further information. In some circumstances we may anonymise your personal data (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.
7. Transferring your personal information outside the EEA
All information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the General Data Protection Regulations with respect to the processing of your personal data.
The General Data Protection Regulations is the legal instrument that deals with the protection of your data (‘GDPR’). Where your data is transferred to such countries it will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC) can be found on the EC’s website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contractstransfer-personal-data-third-countries_en
It is sometimes necessary for us to share and/or store your personal information outside the EEA, for example:
- With any member of our group and/or subsidiaries located outside the EU;
- with your and our service providers located outside the EEA;
These transfers are subject to special rules under GDPR, as non-EEA countries do not have the same data protection laws as Cyprus and other Member States of the EEA. We will, however, ensure that those transfers comply with the GDPR and that all of your personal information will be secure. Unless the individual has specifically consented to the transfer, we will only transfer personal data outside the EEA where:
- we transfer the data to a country or international organization which the EU Commission has decided ensures an adequate level of protection for your personal data;
- the transfer of your personal data is subject to adequate safeguards, which may include binding corporate rules, data processing agreements or standard data protection clauses adopted by the EU Commission; or
- one of the derogations in the GDPR to transfer personal data outside the EEA applies.
Where data is to be transferred to a group company in a country outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data, we will ensure that the group company agrees to binding corporate rules in accordance with Article 47 of the GDPR. Further information can be found on the EC’s website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporaterules_en
Where we transfer data to organisations based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see EC’s website page: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacyshield_en#eu-us-privacy-shield
If you would like further information please contact our DPO.
8. Your rights
You have the following rights, which you can exercise:
The right to be provided with a copy of your personal information
The right to require us to correct any mistakes in your personal information
To be forgotten
The right to require us to delete your personal information—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, for example, if you contest the accuracy of the data. These can include (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
The right to object:
at any time to your personal information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information, for example, processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We use automated processing for services such as tailoring products and services, fraud detection, and opening accounts.
Consent to processing can be withdrawn at any time, where relevant. He/she must contact the DPO if he/she wishes to do so.
We aim to comply with requests of data subjects as quickly as possible and will ensure that we comply with legislation, unless exceptions apply. In such cases, the reasons for any delay will be explained in writing to the data subject making the request.
In processing a request, the identity of the data subject needs to be verified before information will be released. No personal data will be disclosed to a third party without the written consent of the data subject.
We reserve the right to refuse repeated/vexatious requests.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless they are clearly repetitive or vexatious.
For further information on each of those rights, including the circumstances in which they apply, please contact our DPO.
9. Keeping your personal information secure
We have appropriate technical and organizational security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breaches. We will notify you and the relevant supervisory authority of a suspected data security breach when we are legally required to do so.
10. How to complain
We hope that we and our DPO can resolve any concerns or complaints you may have about our use of your information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in Cyprus is the Office of the Commission for Personal Data Protection. Their office is located at Iasonos 1, 1082 Nicosia, Cyprus. They can be contacted by telephone at +357 22818456, by fax at +357 22304565, or by email [email protected]. To contact them online, please click here.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. By visiting our website and using our products and services you are accepting and consenting to the practices described in this policy.
12. How to contact us
Our DPO’s contact details:
Name: Scott McKenzie
Email: [email protected]