Privacy policy

1. INTRODUCTION

The following Privacy Policy applies to the platform (including any applicable websites and mobile applications used to access the same) (collectively the “Platform”) known as Bitcomma (“we, “us,” or,“ “our”).

Bitcomma.com is owned and operated by Centralex Sp. z o.o., the company number 1132566, authorised to provide virtual currency service, with a registered and operational address at Hoża Street No. 86, 210 spaces, Warsaw, postal code 00-682.

The Policy describes how we collect, use, and disclose Personal information that we obtain from current or prospective customers or users (“you” or “your”) of the Platform and any account services provided through the Platform. For this Policy and associated Platform Terms & Conditions at https://bitcomma.com/terms-conditions, “Personal Information” refers to any information related to an identified or identifiable individual. We do not consider Personal Information to include information that has been anonymised, where it does not identify a specific user.

2. YOUR ACKNOWLEDGMENT OF THIS POLICY

By providing us with, or authorising us to collect, your Personal Information, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal information by this Policy and any other arrangements that apply between us.

3. INFORMATION COLLECTED

3.1. We collect these types of Personal Information:

Non-Personally Identifiable Information. The first type is non-personally identifiable data and statistical information. Non-personally identifiable data being gathered consists of technical information and behavioural information that does not pertain to a specific individual (“Non-Personal Information”). This includes your device type, browser type and version, IP data, screen size and resolution, language, and other technical data. While it is not specifically personally identifiable, it may be reverse-engineered to be identifiable and, therefore, is considered Personal Information.

Personally Identifiable Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information and financial data, including:

Your contact details, which include your email address, phone number, full name, date of birth, gender, residential address, and postal address.
Your financial data, including the identity of cryptocurrency, accounts you transferred sums to or from, your bank details, tax identification number, income/next assets/wealth verification statements, and your transaction list.
Your documents and data are uploaded in our Know-Your-Customer (KYC) process, including a photocopy of your government-issued ID, passport, driver’s licence, occupation, and place of work, a video containing your image, proof of address and utility bills, and other data filled in our forms, such as your source of wealth and source of funds.

4. HOW WE COLLECT YOUR PERSONAL INFORMATION?

4.1. We collect your Personal Information in the following ways:

When you visit our Platform. When you visit our Platform, we collect information from your computer, mobile phone, or other access device. This information may include your IP address, browser type, operating system, and other device characteristics or identifiers.
When you register for our services. When you register for our services, we collect information such as your name, email address, phone number, date of birth, residential address, and postal address. We may also collect additional information to verify your identity or address, such as your driver’s licence, passport number, or other information.
When you use our services. We collect information about your transactions and other activities on our website when you use our services. This information may include the amount of money you send or receive, the date and time of the transaction, and the recipient’s name and address. We may also collect information about your computer or other access device for fraud prevention.
To protect against fraud and misuse, we may collect information about your use and interaction with our Platform to help prevent fraud and misuse of your Personal Information. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of our services.
Other ways. We may also collect additional information from or about you in other ways, such as interactions with our customer support team.

4.2 What are the purposes of collecting and processing your Personal information?

4.3 We may collect, hold, use, and disclose your personal information for:

(a) Provide you with the services you have requested. We use your Personal Information to provide you with the services you have asked for, such as opening an account, making a transaction, or contacting customer support;

(b) Communicate with you about your account and transactions. We use your Personal Information to communicate with you about your account and transactions, such as sending you account statements, confirmation emails, and fraud alerts;

(c) Protect our users and the Platform from fraud and other illegal activities. We use your Personal Information to protect our users and the Platform from fraud and other unlawful activities, such as screening for suspicious activity and enforcing our terms of service;

(d) Improve our service and the Platform. We use your Personal Information to improve our service and the Platform, such as developing new features, fixing bugs, and measuring the effectiveness of our marketing campaigns;

(e) Deliver direct marketing, service update notices, and promotional offers based on your communication preferences. We may use your Personal Information to deliver direct marketing, service update notices, and promotional offers to you. We will only do this where you have opted in to receive these communications and

(f) Comply with applicable laws and regulations. We may use your Personal Information to comply with applicable laws and regulations, including but not limited to anti-money laundering and KYC.

5. HOW CAN WE CONTACT YOU?

If you register for our service, we may contact you with periodic updates and promotional emails about the service and the products or services we offer.

You may opt out of these anytime, but not from transactional emails, such as payment updates, withdrawals, or cryptocurrency purchase orders.

Moreover, if you show interest in one of our products or services, we may contact you about it by email, phone, text, or post.

6. RIGHT TO ACCESS, EDIT, UPDATE OR DELETE

You can access, edit, update, or delete your account or the Personal Information we have collected at any time by accessing settings or contacting us via support@bitcomma.com. We will respond to your request within a reasonable period but no later than the period required by all applicable laws.

7. CIRCUMSTANCES IN WHICH WE MAY NOT BE ABLE TO ACCOMMODATE YOUR REQUEST

(a) Please note that notwithstanding the preceding, there may be circumstances in which we cannot accommodate a request to edit, update, access, or delete an account profile or Personal Information. This includes but is not limited to:

any basis where such a request can be denied under applicable law; or
where we need to retain the information to comply with federal, state, or local laws or for accounting or tax purposes; or
where we need to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; or
where we need to cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local laws; or
where we need to retain information to exercise or defend legal claims or
where the information contains legal privilege or proprietary information of another party or
where complying with the request would compromise others’ privacy or other legitimate rights.

(b) If we determine that we cannot respond to any request in any particular instance, we will explain why that determination has been made and provide you with a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before responding to any request under this provision, including complying with any applicable legal requirement for verifying your identity.

(c) To the extent permitted by applicable laws, we reserve the right to charge you a reasonable fee for handling and processing your requests to access your Personal Information, where applicable. If we choose to charge, we will provide you with a written estimate of the fee we will charge. Please note that in many jurisdictions, we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

8. HOW WE KEEP YOUR PERSONAL INFORMATION ACCURATE AND UP-TO- DATE?

We are committed to ensuring that the personal information we collect, use, and disclose is relevant, accurate, complete, and up-to-date.

We encourage you to contact us to update any personal information we hold about you. If we correct information previously disclosed to another entity, we will notify the other entity within a reasonable period of the correction. If we are satisfied that the information is inaccurate, we will take reasonable steps to correct it within 30 days unless you agree otherwise. We do not charge you to correct the information.

9. SHARING PERSONAL INFORMATION WITH THIRD PARTIES

9.1. Your personal information may be disclosed to third parties for purposes described in this Policy or any other specific and additional privacy provisions that apply to certain products and services the Platform provides. We may disclose your personal information to the following third parties (as distinct from the member of the Platform to whom you have provided your Personal Information):

Our partners will assist us in the KYC process and provide any further support needed to use our services.
Any third-party service providers carrying out functions for or on behalf of the Platform
Government agencies, law enforcement regulatory agencies, bodies, or other third parties as required by and by applicable laws and regulations.
Organisations involved in facilitating payments on our behalf, including banks, third-party payment processors who process your credit card and other payment information, and other financial institutions.
An agent, contractor, or service provider we engage to carry out functions and activities, such as our bankers, lawyers, accountants, debt collectors, and other advisers;
Other companies in the case of a merger, divestiture, or other corporate reorganisation;
Anyone else to whom you authorise us to disclose it or which is required by law.
Any other third party with your consent or where authorised or required by law.

Where necessary (such as when we transfer data to service providers), we put in place appropriate contractual arrangements and security mechanisms to protect the Personal Data shared and comply with our data protection, confidentiality, and security standards and obligations.

10. LOCATION OF YOUR PERSONAL INFORMATION

The personal data collected from you, as detailed in this Privacy Policy, may be transferred to and stored at servers located in countries outside your jurisdiction and countries according to our third-party providers’ standard contractual obligations.

It may also be processed by staff of our suppliers, service providers, or partners operating outside your country.

We are committed to protecting your Personal Data. As detailed in this privacy policy, we will take appropriate steps to ensure that your Personal Data is processed and stored securely and in accordance with applicable privacy laws. Such steps include establishing data transfer agreements or ensuring our third-party service providers comply with our data transfer protection measures.

By submitting your Personal Information through the Platform, you acknowledge and agree, in a jurisdiction where such consent is required, to the transfer, storage, and/or processing of such Personal Information.

11. COOKIES

11.1. When you access our Platform, we use both first-party and third-party cookies. Cookies are small text files placed in your computer browsers to store your preferences. Our Platform and our third-party partners collect and store information that is generated automatically as you use it, including your preferences and anonymous usage statistics.

11.2. We collect information about your device and use tracking mechanisms such as cookies to:

Facilitate customer use of our Platform;
Enable customization of our online services and website features;
Avoid customer re-entry of data,
Store customer preferences for certain kinds of information;
Enhance security measures and
Gather data about the usage of our website and mobile applications for research and promotions.

11.3. We use cookies from third-party service providers to facilitate website tracking and security measures. We may share the information collected with third parties acting as our service providers, who are required to maintain the confidentiality of the information.

11.4. We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you or because using them is in our legitimate interests (where we have considered that your rights do not override these), and in some cases, where required by law, where you have consented to their use.

12. SECURITY

We take reasonable steps to preserve the security of the personal information we collect. Your Personal Information is held in an environment with reasonable security measures, either in writing or electronically.

We have implemented security procedures, controls, and protocols across all our physical premises and electronic environments to minimise the risk of interference, loss, misuse, unauthorised access, modification, or disclosure of Personal Information.

However, due to inherent risks in the transmission of information over the Internet or other methods of electronic storage, we cannot guarantee that unauthorised access or use will ever occur.

We will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information. We will inform you of such a breach if required by applicable law.

To the extent that we implement the required security measures under applicable law, we shall not be responsible or liable for unauthorised access, hacking, or other security intrusions, failure to store, or the theft, deletion, corruption, destruction, damage, or loss of any data or information included in the Personal Information.

13. DATA RETENTION

We will retain the Personal Information for as long as we believe it is accurate and can be relied upon. Personal Information that is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it that is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

14. DATA BREACH NOTIFICATION

We comply with local authorities in data breach notifications. If there is an actionable breach of your Personal Information, we will notify you within 72 hours

15. CONTACT US

If you have questions, concerns, or complaints regarding this Policy or handling your Personal Information, you may contact our data protection officer at support@bitcomma.com.

Please include your name, contact information, and the nature of your concern/request so we can appropriately respond to your communication.

16. UPDATES TO THIS POLICY

(a) This Policy is current as of the Effective Date above. We may change our Policy from time to time, so please be sure to check periodically. We will post any changes to this Policy on the Platform.

(b) To the extent required by all applicable laws, if we make any changes to this Policy that materially affect our practices, we will endeavour to provide you with notice in advance of such change. This notice may be provided through a push notification through the Platform (you should ensure your Platform settings allow for such push notification), email, or other means.

You are responsible for ensuring that your contact information is up-to-date so we can effectively communicate with you.