Effective: March 11, 2018
Information We Collect
We collect both Personal Information and Other Information about visitors to our Sites, as described below. For purposes of this Policy, “Personal Information” means information we can directly associate with a specific individual without any additional information, such as a name, an email address, a physical address, or a phone number. “Other Information” means any information that is not Personal Information. We may combine Other Information and Personal Information, in which case we will treat the combined information as Personal Information.
We may also combine Personal Information or Other Information we have about you with additional information that we or third parties collect in other contexts – like if you contact us by phone or email and provide information we did not already have, or when third-parties share information about you with us. In those circumstances, we will treat the combined information as Personal Information in accordance with this Policy.
Your Account: We collect Personal Information from you when you provide it to us by creating a CredoEx account. Depending on the type of account you create, we may collect your:
- First and last name
- Email address
- Phone number
- Physical address
- A government-issued identification number
- A copy of your government issued identification card (such as a driver’s license)
- Proof of address
We will associate this account information with other information about your use of CredoEx, including your preferences and other account settings, your transactions, your account balance, your customer service or support requests, and [anything else?].
The Sites may also include community sections where you can post questions, comments, or other inquiries related to CredoEx. Your posts will include your account name and be visible to other members of the CredoEx community and the general public. You are responsible for ensuring that you do not post information you wish to keep private or confidential.
Other Personal Information: The Sites may allow you to contact us by email, web chat, or other means. We collect the information you provide to us through such communications, which might include your name, phone number, and email address.
The Sites may allow you to submit a resume or other information to apply for employment or other opportunities at CredoEx. We will collect your resume and other requested information you submit in association with your application.
Other Information. We also collect Other Information automatically when you visit our Sites. This may include information such as your IP address and domain name, your Internet service provider, the time and duration of your visit, how you used the Sites (including pages viewed and actions taken), the URLs from the websites you visit before and after navigating to the Sites, how you were referred to our Sites, your operating system and browser type, your software and hardware attributes (including device type), your MAC address, and your general geographic location (for example, your city, state, or metropolitan region). We collect this information using the following technologies:
- Server Logs. When you use the Sites, we automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
- Pixel tags. The Sites or the emails that you receive from us may use an application known as a “pixel tag” (also known as a “clear gif” or “web beacon”). A pixel tag is an electronic tracking mechanism that usually consists of a single-pixel image. It can be embedded in a web page, an online display advertisement, or in an email to transmit information, which could include Personal Information. For example, it allows an email sender to determine whether a user has opened a particular email or an online display advertisement.
We may partner with certain third parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use pixel tags on the Sites, in email communications from us, and in connection with delivering display advertisements from us or others. This information may be used for a variety of purposes, including analytics (such as how many emails or online ads were opened) and targeted advertising, as described in the “Third-Party Analytics and Targeted Advertising” section below.
How We Use Information
We may use Personal and Other Information for a variety of purposes, including to:
- Provide you with services, including enabling you to manage your account, place trades, exchange digital currencies and other types of funds, and engage in other transactions;
- Verify your identity when you use our Sites;
- Respond to your requests by email or phone call, to fulfill the terms of any agreement we have with you, or to complete any other transaction that you initiate;
- Manage the user community section of our Sites, including moderation of the content you post;
- Communicate with you; including sending you newsletters, updates, information about your account or activity; marketing communications and other materials related to our Sites or other products or services we believe may be of interest to you;
- Analyze and research user experiences and activity on our Sites so that we can improve the user experience and enhance our Sites, products, and services;
- Comply with any legal or regulatory requirements or to serve the other legal purposes described below in the section entitled “How We Share Information with Third Parties” and as described in our Anti-Money Laundering Policy, at [url]; and
- Compile and share aggregated information, such as information about trading volumes, prices, and usage of our Sites.
We use Other Information for a few additional purposes, including to:
- Count and recognize visitors to the Site, and analyze how visitors use the Site;
- Engage in analytics or targeted advertising as described in the “Third-Party Analytics and Targeted Advertising” section below; and
- For any other business purpose permitted by law, including any purpose for which we use Personal Information.
How We Share Information with Third Parties
We may share Personal and Other Information with third parties for a variety of purposes, as described below:
Affiliates. We may share information with our corporate affiliates, including BitBounce.com, for any of the purposes described in this Policy, including sending marketing communications to you about products or services offered by our affiliates.
Business partners. We also may share your Personal or Other Information with our business partners to fulfill your requests for services; to process or service a transaction that you initiate; meet the terms of any agreement that you have with us or our business partners; and [anything else?].
Third-party service providers. We use third-party service providers to help us manage and improve our Sites and CredoEx. These service providers may collect or use your Personal or Other Information to assist us in achieving the purposes described in this Policy. For example, we may use third parties to collect information about visitors to our Site and report it to us.
Legal purposes. We also may use or share your Personal or Other Information with third parties:
- To comply with applicable law or a court order, subpoena, request from government or law enforcement, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To verify your identity, conduct due-diligence and comply with anti-money laundering requirements related to your use of the Sites, including to implement our Anti-Money Laundering Policy, available at [url];
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
De-identified or aggregated information. We may also share de-identified or aggregated information about the Sites users and transactions that occur on the Sites, including sharing aggregated data about transactions and activity on the Sites.
Third-Party Analytics and Targeted Advertising
Certain portions of the Sites may also enable third-party tracking mechanisms to collect Other Information over time and across unaffiliated websites for use in online behavioral advertising. For example, third parties may use the fact that you visited the Sites to target online ads for CredoEx services to you on non-CredoEx websites. In addition, our third-party advertising partners might use information about your use of the Sites to help target non-CredoEx advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.
Our website currently does not respond to “do not track” browser headers.
Our Site uses commercially reasonable physical, electronic, and procedural safeguards to protect Personal and Other Information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and we cannot guarantee the absolute security of your personal or other information.
Reviewing and Updating Your Information
If you want to learn more about the information we have about you, or you would like to update or change that information, please contact us by email at [insert contact email address]. You can also change or update certain information about your account directly, through the [Preferences? Account Settings?].
If you would no longer like to receive e-mail marketing communications from us, please follow the “unsubscribe” instructions that are include at the bottom of each message. Please note that if you unsubscribe from our marketing communications, you will continue to receive non-marketing, administrative emails from us about your CredoEx account.
You may also have the opportunity to opt-out of certain information sharing done by CredoEx. You can opt-out by calling us at [number], where our menu will prompt you through your choices, or by visiting [website]. If you are a new CredoEx customer, we can begin sharing your information 30 days from the date you first signed up for CredoEx. When you are no longer our customer, we continue to share your information as described in this notice. However, you may contact us at any time to limit our sharing.
Your California Privacy Rights
California law gives residents of California the right, under certain circumstances, to request information from us regarding the manner in which we share certain categories of personal information with unaffiliated third parties for their own direct marketing purposes. To request such information, please contact us at the information provided below.
If you are a California resident under the age of 18 and a registered user of the Sites, you may request that we remove content and information that you post on the Sites. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to [insert contact address]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been reposted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.
Information For Site Users From Outside The United States
The Personal and Other Information we collect through or in connection with the Sites is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this Policy, using the Site, or providing information us, you expressly consent to such transfer and processing. Currently, we do not support users from the European Union, Switzerland, China, or Russia.
The Sites are not directed to children under the age of 13, and CredoEx does not knowingly collect Personal or Other Information through the Sites from anyone it knows is under the age of 13.
Changes to This Policy
We may change the Sites or our data-handling practices in the future and therefore need to revise this Policy. We will post the revised Policy with an “effective date” that indicates when the revisions take effect. We encourage you to review this page periodically.
Questions or Comments
If you have any questions or comments regarding our privacy practices or this Policy, please email us at [insert contact email address] or contact us by mail at: [email protected]