This Privacy Policy is effective as of January 01, 2023.
Category of personal data | Data collected | |
When you visit our Website or contact with us | Technical Data | Upon visiting our Website, we process technical data related to your usage of the Website, including but not limited to IP address, location data (down to city level), access-provider, referring URL, date, time, access tokens, session key, browser type and version, browser language, operating system, amount and state of transferred data. This information can be related to you, therefore, Personal Identification Information can be processed as well. These data may also be processed as anonymized statistical data. |
Cookie Data | We apply cookies on the Website, for optimizing the Website and its functionalities. The cookies may collect your personal data. To learn more about the cookies we use, please read our Cookie Policy. | |
Communication Data | In case you interact with us via our Website live chat, emails and sign-up forms, signa.land Facebook page, Youtube channel, Twitter page or Telegram or any other official social media account, we process, in addition to Personal Identification Information (limited in case of contacting via social media), also the contents of your message. | |
When you use the Software | Personal Identification Information | Name, email address, 2FA key, IP address, KYC token, language, Google Analytics client ID, Gravatar image, if you choose to sign up via Facebook, we collect your Facebook UID, Facebook profile name, Facebook email, if you choose to sign up via Apple, we collect your Apple profile name, Apple email or Apple generated email. If you sign up via mobile application, we collect your device language, device region, device type and model. |
Financial and Transaction Data | Exchange Account username, API key, API secret, passphrase, transaction data (date/time/amount of transaction), transaction request/response, Referral status, billing information (country, phone number, address, city, postal code; in case of an entity: business name, registry code and VAT ID). |
Purpose of processing | Category of personal data processed | Legal basis |
Client authentication | Personal Identification Information | Performance of the Terms of Use |
Client identity verification (KYC) for recovery | Personal Identification Information | Performance of the Terms of Use |
Client's transaction history | Financial and Transaction Data | Performance of the Terms of Use |
Responding to your enquiries and requests submitted via the website, sign-up forms, live chat or email or any social media platforms | Communication Data, however, depending on the nature of your enquiry we can process all the data indicated in Section 2 above | In case your question clearly relates to matters connected to the Terms of Use, Client Agreement or Purchase Agreement we process the data for the performance of the Contract. In other cases, we rely on our legitimate interests in ensuring effective relations management with all the interested parties in our Software and services |
Transfer of funds from a payment service provider to your Client Account and making out payments upon your withdrawal request via payment service provider | Personal Identification Information, Financial and Transaction Data | Performance of the Terms of Use |
Determining your location for designating applicable VAT rate | Personal Identification Information | Performance of the Purchase Agreement |
Handling the refunds related to Purchase Agreement | Personal Identification Information, Financial and Transaction Data, Communication Data | Performance of the Purchase Agreement or in certain situations performance of our legal obligation |
Enabling your use of the Trial | Personal Identification Information | Performance of the Trial Terms |
Enabling the Software and its functionalities | Personal Identification Information, Financial and Transaction Data | Performance of the Terms of Use and if relevant performance of the Purchase Agreement |
Sending newsletters to your email | Personal Identification Information | Consent |
Providing you with notifications via your chosen channel (for example, mobile app, email, Website, Telegram Bot) | Personal Identification Information | Consent given for the specific notification channel |
Direct marketing campaigns - Client marketing campaigns in relation to the Software, its functionalities and products already provided to you | Personal Identification Information, Financial and Transaction Data (mainly the transaction activity) | Our legitimate interest in providing you with information relating to the services and products you have previously sourced from us |
Processing data for predictive analytics and insights, improvement and development of the Software | All of the data categories indicated in Section 2 above | Our legitimate interest in detecting and deterring suspicious and fraudulent actions related to the Website and the Software |
Processing (including anonymising) data for predictive analytics and insights, improvement and development of the Software | All of the data categories indicated in Section 2 above | Our legitimate interest in improving and developing the Website and the Software within the course of our business activities or performance of the Terms of Use |
Diagnosing and repairing technical issues related to the Software and the Website | Technical Data | Our legitimate interest in providing data security and preventing fraudulent actions related to the Software and the Website; ensuring the functioning of the Software and the Website |
Storing information containing personal data in backup systems | All of the data categories indicated in Section 2 above | Our legitimate interest in ensuring the security of data processing operations |
Data disclosures to potential acquirers of signa.land business, including legal advisors, auditing service providers in case of a merger, acquisition or selling the whole or part of our business | All of the data categories indicated in Section 2 above | Our legitimate interest in ensuring proper due diligence process and business continuity |
Data disclosures to our service providers | All of the data categories indicated in Section 2 above | Our legitimate interest in utilizing the information technology infrastructure and services provided by our cooperation partners |
Mandatory disclosures to law enforcement and data protection authorities | All of the data categories indicated in Section 2 above | Performance of our legal obligation |
Categories of Recipients | Reason for sharing | Type of recipient |
Service providers | We work with service providers that work on our behalf which may need access to certain personal data to provide their services to us. These companies include those we have hired to operate the technical infrastructure that we need to provide service, assist in protecting and securing our systems and services, and help market our service. Most of the aforementioned service providers are located in the European Union or European Economic Area, however, some of those service providers are located in the United States. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer. | Data processors |
Payment processors | We will share your personal data with our payment processors as necessary to enable them to process your payments. The aforementioned service providers are located in the United States. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer. | Data processors or separate controllers |
Advertising partners | We work with advertising partners to enable us to customize the advertising content you may receive. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising. We and our advertising partners process certain personal data to help us understand your interests or preferences so that we can deliver advertisements that are more relevant to you. The aforementioned service providers are located in the United States. Standard contractual clauses, or other applicable means, are applied to ensure the safeguard of the transfer. We also provide you promotional email campaigns related to our services (educational videos etc.) by using email campaign service providers. In order to do this we may transfer your email address to such service providers so that they can send you the materials. | Data processors |
Professional advisors (legal advisors, accounting etc. bound to confidentiality) | In case not operating as data processors, the legitimate interests in conducting and supporting our regular business activities. | Data processors |
Potential business acquirers and business transferee(s) | If necessary and required for successfully transferring our business or for the purposes of mergers and acquisitions, your Personal data may be disclosed to the specified acquirers and their representatives and / or legal counsels. This is done based on our legitimate interests to sell and reorganize our business activities. | Separate data controllers |