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Privacy Policy

Version 2 – September 15, 2021

Please read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities in the event you have a complaint.

This Privacy Policy sets forth the policy of XBTO Trading, LLC and its affiliates (collectively, the “Company”) with respect to personal information that the Company may collect through this website (including any mobile application or version of the website, collectively, the “Site”). This Privacy Policy may be changed at any time, provided that if we make any substantial change to this Privacy Policy, we will post a prominent announcement on the Site and will post the updated Privacy Policy here. This Privacy Policy applies only to the personally identifiable information of individuals (the “Personal Information”), not the trade secrets or other intellectual property of any person.

Who we are

XBTO Trading, LLC is licensed and fully regulated under Bermuda’s Digital Asset Business Act (DABA) in 2018 under Bermuda law. XBTO Trading, LLC collects, uses, and is responsible for certain personal information about you. In the United Kingdom and across Europe, when we do so we are regulated under the Data Protection Act 2018 and General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The personal information we collect and use

Information you provide voluntarily

In the course of signing up for and using the XBTO LLC, Trading website, consulting with our support teams, sending us an email, or communicating with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your end-users’ name, email address, IP address, phone number, postal address, in addition to other details that may include gender, location, occupation or other information of a demographic nature. In supplying this information, you consent to this information being collected, used, disclosed, transferred to XBTO, LLC affiliates and stored by us, as described in our Terms and this Privacy Policy.

Information we automatically collect

When you browse one of our websites, use the XBTO, LLC platform or interact with an email that we send to you, we may collect information about your web browsing and use of the site or platform. This may include details of your operating system, location, IP address, browser ID, browsing activity, and other information about how you interacted with XBTO, LLC’s services. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. We use this information to help improve the website or monitor the performance of our campaigns.

Both XBTO, LLC and our third-party partners may use assorted technologies to collect and store information when you use the XBTO, LLC website or interact with an email from us. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyze behavior, track movements around the website, provide targeted advertisements, and gather demographic information. We may partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. You are able to control the use of cookies at an individual browser level. 

Except as required by law, the Company does not disclose any of the Personal Information to anyone, other than to its affiliates, and except as permitted by law, to the Company’s attorneys and regulators and to certain service providers, such as a third party that hosts this Site.

This Site may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from the Company’s web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this Site. Cookies also help the Company diagnose problems with the Company’s server.

The Company seeks to carefully safeguard your Private Information and, to that end, restrict access to nonpublic Personal Information to those employees and certain other persons, including service providers such as a third party that hosts this Site, who need to know such information.

If you have any questions or comments about this Privacy Policy, please feel free to contact the Company at [email protected]

Information from elsewhere

XBTO, LLC may obtain information about you or end-users from third parties, such as public databases, social media platforms, third-party data providers, and our marketing partners. Examples of the information we may receive from other sources include device information (e.g. IP address and browser), location, behavioral data, and demographic information. We may use this information, alone or in combination with other information described above, to develop or provide more relevant platform features or services (e.g. social media data of end-users allowing you to send more relevant content) or provide more relevant marketing and content to you.

 

 

 

How we use personal information

We use and disclose personal information to:

Supply, improve and support the user experience. This allows XBTO, LLC to monitor your use of our website, products, and services and tracks our relationship so that we can improve our service to you. We may also use these third-party services for communications, either through email or through messages within our products and services. These third-party services may collect publicly available contact and social information related to you, such as your name, email address, gender, company, job title, photos, website URLs, social network handles, and physical addresses, to enhance your user experience.

 

 

Third parties

We may disclose personal information to advertising partners, networks and exchanges to display advertising on our website or to manage and serve our advertising on other sites and may share personal information with them for this purpose. All third parties with which we share this information are required to use your Personal Information in a manner that is consistent with this policy. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyze behavior, track movements around the website, provide targeted advertisements, and gather demographic information. We partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. Please refer to our Cookie Policy for more information.

 

How long your personal information will be kept

In providing services to you, we will hold personal information for as long as you opt-in. 

 

Transfer of your information out of the UK or the EEA

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Please note that all XBTO, LLC entities operate under Standard Contractual Clauses and applicable measures of the GDPR providing protections and safeguards for cross-border transfers. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

Your GDPR rights

For UK & European residents, under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise, restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to our Data Protection Officer
  • let us have enough information to identify you,
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates, including any account or reference numbers, if you have them

If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to 24 hours for this to take place.

 

Your CCPA Rights

In addition to the general rights set out under this Privacy Policy, if you are a resident of California, Californian law means you have a number of important rights free of charge. In summary, those include rights to:

  • request information, including a list of the categories of Personal Information (e.g. name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties direct marketing purposes, from businesses with whom you have an established business relationship, & the names and addresses of all such third parties.;
  • portability of such information and receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
  • require the erasure of personal information concerning you in certain situations.

We do not sell your data to third parties, and the categories of information that we collect are listed above in this policy, but for any queries or other requests please [email protected]

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

 

For individuals in the UK & Europe, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. For UK individuals, the supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone at 0303 123 1113 or other channels as updated at https://ico.org.uk/global/contact-us.

 

For individuals in the Netherlands, the supervisory authority is the Dutch Data Protection Authority who may be contacted at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us.

 

How to contact us

If you have any questions or concerns about the way in which XBTO, LLC handles any privacy matter or the information we hold about you, please contact us at [email protected]

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