Last Updated: May 17, 2022
1. General provisions1.1. The entity responsible for data processing is MainCoin OÜ (“Neocrypto”, “we”, “us”), a company incorporated under to the laws of the Republic of Estonia under registration number 16091714, registered and located at Harju maakond, Tallinn, Kesklinna linnaosa, Järvevana tee 9, 11314.Our contact details are as follows:
2. Types of information we collect about you2.1. The main purpose for which Neocrypto collects your personal data is to provide you with access and utility through our digital platform via software, API (application program interface), technologies, products and/or functionalities (“Services”). In the course of providing you our Services, to abide by the laws and to improve our services, we need to collect and maintain personal information about you.2.2. Neocrypto will collect and process the following data about you:2.2.1. Information you give us.You may give us information about you when you sign up to use our Services, e.g. when you provide us with personal details like your name, phone number and email address. This also includes information you provide through your continued use of our Services, through entering a promotion or survey, and by reporting problems with our Services. The information you give us may include your name, date of birth, address, email address, phone number, identity information (e.g. identity documents), financial information (e.g. credit card, debit card information), geographical location, personal description and photograph. In some cases, such as when you send or receive high value or high volume transactions, or where we need to comply with anti-money laundering regulations, we may also need more commercial or identification information from you.2.2.2. Information we collect about you.With regard to your use of our Services, Neocrypto may automatically collect the following information:
3. How we protect your personal informationNeocrypto has kept your personal information safe using secured storage with industry standard encryption and implemented a number of security measures to ensure that your information is not lost, abused, or altered, including, but not limited to:3.1. Physical MeasuresMaterials containing your personal data will be stored in a locked place.3.2. Electronic MeasuresComputer data containing your personal data will be stored in the computer systems and storage media that are subject to strict log-in restrictions.3.3. Management MeasuresOnly authorized employees are permitted to come into contact with your personal data and such employees must comply with our internal confidentiality rules for personal data.3.4. Technical MeasuresEncryption technology may be used to transmit and store your personal data. We use various currently available security technologies and management systems to minimize the risks that your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization, or altered. Our technical security team proactively monitors for abnormal and malicious activity in our servers and services.3.5. Other MeasuresWe endeavor to protect your information from unauthorized access, alteration, disclosure, or destruction of personal data we collect and store. We take various measures to ensure information security, including encryption of our communications with you; required two-factor authentication for all sessions; periodic review of our personal data collection, storage, and processing practices; and restricted access to your personal data on a need-to-know bases for our employees and vendors who are subject to strict contractual confidentiality obligations. Please note that it is impossible to guarantee 100% security of information. As such, Neocrypto requests that you understand the responsibility to independently take safety precautions to protect your own personal information. You agree that Neocrypto shall not be liable for any information leakage and other losses not caused by our intention or gross negligence, including but not limited to hacker attack, power interruption, or unavoidable technical failure, to the maximum extent permitted by law. If you suspect that your personal information has been compromised, especially account and/or password information, please immediately contact with us.
4. Ways we use your informationWe use the information we collect about you for the following purposes or in the following ways:4.1. To provide our ServicesNeocrypto uses the information collected to carry out our obligations relating to you, to provide you with the information, products and services, to deliver, maintain and provide better Services and verify your identity. We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and activities and provide Services.4.2. To protect our usersWe use the information collected to protect our platforms, users’ accounts, and archives. We use IP addresses and cookies to protect against automated abuse such as spam, phishing, and DDoS attacks. Neocrypto analyzes your activities in our Services with the goal of detecting suspicious behaviors as early as possible to prevent potential fraud and loss of funds to bad actors.4.3. To comply with legal and regulatory requirementsWith respect to the privacy and security of personal data, Neocrypto will use the information in compliance with our legal obligations, government requests, and reasonable user-generated inquiries.4.4. For research and development purposesNeocrypto actively measures and analyzes data to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to understand the way you use and interact with our Services. This review activity is conducted by our operation teams to continually improve our Services and to resolve issues with the user experience. In addition, Neocrypto uses such information to customize, measure, and improve our Services and the content and layout of our websites, and to develop new services. We continuously monitor activity information within our systems and our communications with users to look for and quickly fix problems.4.5. To communicate with youWe use personal information collected, like your phone number or email address to interact with you directly when providing customer support on a ticket or to keep you informed on logins, transactions, account security and other aspects or to notify you about changes to our Services. Without collecting and processing your personal information for confirming each communication, Neocrypto will not be able to respond to your submitted requests, questions, and inquiries. All direct communications are properly kept at Neocrypto or the service provider designated by Neocrypto, to be reviewed for accuracy, to be kept as evidence, or to be used to perform other statutory or contractual obligations.4.6 To secure compliance with our terms and conditionsThe collected information is also used to continually and actively enforce our terms and conditions, including but not limited to reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate the foregoing provisions, or disclose the relevant information to a third party in accordance therewith. Neocrypto reserves the right to suspend or terminate provision of any Services to any user found to be engaged in activities that violate our terms and conditions.4.7. For marketing and advertisingNeocrypto may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.4.8. For other purposeNeocrypto may disclose your personal information for any other purpose you consent to.
6. Who receives your personal data6.1. Neocrypto receives your personal data in order to carry out requests and provide services, and to perform our contractual and legal obligations.6.2. We will not share personal data with third parties unless this is necessary for our legitimate business needs, to carry out requests, provide services and/or as required or permitted by law. Third parties under these circumstances include:6.2.1. Service providersNeocrypto will disclose personal data to third party partners and service providers (processors) so they can process it on our behalf where required. These service providers are required to provide sufficient assurances in accordance with data protection law. (e.g. being bound contractually to confidentiality and data protection obligations). We will only share personal data necessary for them to provide their services.6.2.2. Auditors, advisors and consultantsWe may disclose personal data for purposes and in the context of audits (e.g. external audits, security audits), to legal and other advisors, in order to investigate security issues, risks, complaints etc.As such, personal data may be transferred and disclosed to:
7. Transfers outside the EEA or to international organizations7.1. Your personal data may be transferred to third countries (outside the EEA) or to international organizations if the transfer is necessary and has a legal basis as described in this document. Such transfers take place for example:
8. Automated Decisions and Profiling8.1. We sometimes use systems to make suggestions or assist in decisions, including profiling, based on personal information we have, or that we are allowed to collect from other authorised sources, about you.This helps us ensure our decisions are quick, fair, efficient and correct, based on what we know. These automated processes can affect the products, services or features we may offer you now or in the future.The types of automated decisions we make may include:
9. Your rights9.1 Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. Under certain conditions, you may have the right to require us to:
10. Right to file a complaint10.1. If you have any complaints about the use of your data, exercise of your rights, please notify and/or file a complaint with us at the contact details indicated below. We will immediately investigate and inform you in regards to your complaint.10.2. Complaints must be made in English in a comprehensive manner, and contain sufficient details and a clear description of the complaint. Neocrypto will not be able to process requests which are incomprehensive or in languages other than English.10.3. You can also file a complaint with the supervisory authorities, but if the complaint has not been previously sent to us, we can use this fact as evidence of your unwillingness to settle the issue in a pre-trial manner.
11. Third-party linksOur Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
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