1. Introduction

Coinfloor Limited (“We”, “Us” “Our” and “Coinfloor”) are committed to protecting and respecting your privacy.

Capitalised terms not otherwise defined in this Privacy Policy shall have the meanings given in the Terms and Conditions and Cookies Policy.

This policy, together with the Terms and Conditions, explains how We may process any information that We collect from you, or that your provide to us. It covers information that could identify you (“Personal Information”) and information that could not. In the context of the law and this policy, “process” means to collect, store, transfer, use or otherwise act on information. Please read this policy carefully to understand Our views and practices regarding your Personal Information and how We will treat it.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR) and UK Data Protection Act 2018.

The law requires us to tell you about your rights and Our obligations to you in regards to the processing and control of your Personal Information. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.

You have the right to object to the processing of your Personal Information, including where your Personal Information is being processed for direct marketing purposes. Further information on this right, and you other rights, is set out below. To make an objection you can email us at [email protected]

By disclosing your Personal Information to Us, including, but not limited to, by using the Platform (as defined in Our Terms and Conditions), contacting Us by email, and speaking to Us over the telephone, you are confirming you have read and understood the terms within this Privacy Policy.

2. What personal information do we collect?

We may collect, store, and use the following kinds of Personal Information. All Personal Information collected will be stored for as long as is necessary for the relevant purpose for which that Personal Information was obtained.

  • If you register as a user of the Platform, you will be asked to complete an application which will require you to provide your personal details, including, but not limited to, your name, address, email address, telephone number, bank account details, bitcoin wallet details, trading experience, income bracket, a proof of identity, and a proof of address;
  • When you contact Us, by email, telephone, or through any contract form provided by Us, We may ask you to provide some or all of the information set out in the paragraph above. We keep personally identifiable information associated with your message, such as your name and email address;
  • We may collect, store, and use information about your computer, mobile device or other item of hardware through which you access the Platform and your visits to and use of the Platform (including, without limitation, your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, Platform navigation, and search terms that you use); and
  • We collect data regarding your deposits, withdrawals and trades on Our Platform along with any provided bank details and cryptocurrency wallet addresses.

For more information on Our use of Cookies, please see Our Cookies Notice.

We may, from time to time, ask you to complete surveys and give feedback We use for research purposes, although you do not have to respond.

3. How do we use personal information?

We may use your Personal Information for the following purposes:

  • To manage and administer the Platform;
  • To improve your browsing experience by personalising the Platform;
  • To enable you to use the Platform;
  • To send you newsletters and other relevant and targeted promotional communications;
  • To track Our communications with you to provide a high quality service;
  • To deal with enquiries, complaints, and feedback from you and Our service providers;
  • To provide third parties with statistical anonymised information about Our users
  • To publish generic transactional information relating to trades undertaken using the Coinfloor platform;
  • To perform compliance checks;
  • To prevent fraud;
  • To send you emails offering you to take part in surveys and/or to give feedback; and
  • To analyse and improve the services offered on the Platform.

4. Lawful bases for processing

We process your Personal Information on the basis that it is necessary for the performance of a contract We have entered with you, or for Us to comply with a legal obligation applicable to Us. We also process your Personal Information where it is in Our legitimate interest to do so, such as the promotion and operation of Our business or for the protection of others, but only when We have ensured this does not disproportionately impact your privacy.

5. When might we disclose personal information?

Except to the extent required by any applicable law or governmental, regulatory, or judicial body, court order or law enforcement agencies, We will not disclose your Personal Information to any third party other than to a service provider to whom We are required to disclose Personal Information in order for them to provide their services to Us and/or as described below.

If We are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via account message and/or a prominent notice on Our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We may share your Personal Information within the Coinfloor Group (namely, Coinfloor (BVI) Limited, CFE Limited and Coinfloor (UK) Limited).

We may use outsourced services in countries outside the European Union from time to time. Accordingly, your Personal Information may be processed outside the European Union.

Coinfloor may use third parties to perform anti-money laundering checks, to carry out audit functions and other necessary and appropriate checks in order to provide Our services to you. Coinfloor may disclose documentation containing personal information about you, including, without limitation, your proof of identity, address, and date of birth.

6. Newsletters & other promotional communications

If you wish to subscribe to any newsletter published by Us or wish to receive other targeted and relevant promotional communications from Us or other carefully chosen affiliates, We offer you the option to ‘opt-in’ to this service. If you change your mind and wish to stop receiving any such communications, please click the ‘unsubscribe’ link in any email from Us.

7. How we protect your personal information

We take the security of your Personal Information very seriously. We take all reasonable endeavours to ensure that appropriate security measures are in place to protect your Personal Information. As part of this, We use Secure Sockets Layer (SSL) certificates to verify Our identity to your browser and to encrypt any data you give Us.

Unfortunately, the transmission of information via the internet is not completely secure and so We cannot guarantee the security of your Personal Information transmitted through the Platform. Any transmission is at your own risk. Once We have received your information, We use strict procedures and security features in an effort to prevent unauthorised access.

More information on Our strict security regime can be found in Our Cyber Security Policy

8. Your rights in relation to personal information which we process relating to you

8.1 Right to Object

You have the right to ask Us not to process your Personal Information for marketing purposes. We will usually inform you before collecting your Personal Information if We intend to use it for such purposes.

You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your information. You can also exercise this right at any time by contacting Us.

8.2 Rectification and Request

By law, you can ask Us what Personal Information We hold about you and have this corrected if it is inaccurate. You can also request Us to provide you with a copy of the Personal Information We hold and, if used unlawfully, for Us to stop using the information.

After receiving the request, We will tell you when We expect to provide you with the information, and whether We require any fee for proving it to you.

8.3 Access

If you wish to confirm if We are processing your Personal Information, please contact Us in order that We may provide you with a copy of any such Personal Information. Please note, if you require additional copies, We may charge a reasonable administration fee.

8.4 Rectification

If the Personal Information We hold about you is inaccurate or incomplete, you are entitled to have it rectified.

8.5 Erasure

If you wish for Us to remove or delete your personal information, please contact Us. All requests are subject to any retention limits with which We are required to comply in accordance with applicable laws and regulations. If your Personal Information has been shared with third parties, We will take reasonable steps to inform them of the erasure request. You may also ask us to inform you who We have shared your information with so that you can contact them directly. We will give an extensive list where possible and lawful.

If you request to have your Coinfloor Account closed, We will keep your information on Our database for a period of time as allowed by applicable law in order to deter fraud. Your information will not be used for any purposes, other than fraud prevention, supporting potential litigation and complying with law enforcement requests.

To exercise your rights, please contact Our Data Protection Officer at [email protected] We aim to respond to all requests as soon as possible, and will respond within, at the very maximum, one calendar month of receiving your request.

9. How you can complain

If you have a complaint about Our services or how We use your personal information, please refer to Our Complaints Notice.

If you are still unhappy with how We use your data, you can refer your complaint to the Information Commissioner’s Office (“ICO”) (www.ico.org.uk). Our ICO registration number is ZA002203.

10. Retention period for personal information

We will hold your Personal Information for as long as is necessary for the relevant purpose for which that Personal Information was obtained or as otherwise described in this Policy.

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 requirements.

11. Customer Representations

We operate worldwide and the Personal Information that we collect directly from you will be stored in Our servers in the United Kingdom. We may also transfer your Personal Information to members of Our third party service providers, many of whom may be located outside of the EEA, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EEA.

Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, We have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission to ensure that appropriate safeguards are used to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to [email protected]

12. Review of this privacy policy

This Policy will be reviewed from time to time and may be changed without notice. Any information held will be governed by our most current Privacy Policy.

Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]