Last updated: March 13, 2018
OUR RELATIONSHIP TO YOU AND COINBASE
bitcointobanks Payments, Ltd is a private limited company incorporated in England and Wales with company number 09708629 and whose registered office is 9th Floor, 107 Cheapside, London EC2V 6DN, United Kingdom. bitcointobanks Payments, Ltd is an authorised electronic money institution authorised and regulated by the UK Financial Conduct Authority ("FCA") with register number 900635. bitcointobanks Payments, Ltd is a data controller for e-wallet transactions originating from the EEA. Coinbase UK, Ltd, is a private limited company incorporated in England and Wales with company number 09083955 and whose registered office is 9th Floor, 107 Cheapside, London, EC2V 6DN.
Coinbase UK, Ltd, based in the United Kingdom and handles Digital Currency transactions originating from the EEA. Coinbase UK, Ltd is the data controller for cryptocurrency transactions. We provide instructions to Coinbase, Inc. ("Coinbase"), to process such transactions on [bitcointobanks.com](gbitcointobanks.com) and [gdax.com](ggdax.com), and to handle various administrative and organisational matters on our behalf related to such transactions.
PERSONAL INFORMATION COLLECTED We collect personal information to provide you with our Services. When we require certain personal information from users it is because such information is relevant for specified purposes. Any information you provide to us that is not required is voluntary.
For example, we collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for a bitcointobanks event or webinar. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you.
In addition, we may collect personal information disclosed by you on our message boards, chat features, blogs and our other services to which you are able to post information and materials. Any information that is disclosed in those forums becomes public information and may therefore appear in public ways, such as through search engines or other publicly available platforms, and may be "crawled" or searched by third parties. It could also be read, collected or used by other users to send you unsolicited messages. Please do not post any information that you do not want to reveal to the public at large.
You are free to choose whether to provide us with the types of personal information described below, but we may not be able to serve you as effectively or offer you some or all of our Services when you choose not to share certain information with us.
Here are some examples of the types of personal information bitcointobanks collects and how we may use it:
When you create an account or use bitcointobanks Services, we, or our affiliates' vendors acting on our behalf may collect the following types of information: your name, date of birth, driver number ID, personal ID, address, phone, email, full bank account details and/or credit card numbers that you link to your Coinbase Account or input when you use bitcointobanks Services. bitcointobanks will use this information to fulfill your requests and provide the relevant Services.
If you seek permissions to raise Digital Currency buy and sell limits associated with your Coinbase Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, a photo of you, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
Whenever you contact us or respond to our communications (e.g., email, telephone, written), we receive your contact information and any other personal information you choose to provide us. bitcointobanks will use such information to fulfill your requests or to provide Services.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorisation.
HOW PERSONAL INFORMATION IS USED
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how we may use this information include:
To provide you with bitcointobanks Services and customer support that you request.
To process transactions and send notices about your transactions.
To verify your identity by comparing your personal information against third-party databases.
To send administrative or account-related information to you.
To better understand our customers and end-users and the way they use and interact with bitcointobanks-owned or -operated websites, mobile apps, and Services.
To provide a personalised experience, and implement the preferences you request.
To customise, measure, and improve bitcointobanks Services and the content and layout of our website and applications.
To enhance security, prevent fraud, monitor and verify identity or service access, combat spam or other malware or security risks.
To deliver targeted marketing, service update notices, and promotional offers based on your communication preferences (where this in accordance with the law).
To communicate with you about our events or our partner events.
To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms.
To resolve disputes, collect fees, and troubleshoot problems.
To comply with legal obligations.
To enforce our agreements with third parties.
For quality control and staff training.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may choose not to have your personal information shared with third parties where we rely on consent as the lawful basis for processing your personal information. You may also choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or bitcointobanks Services may not be available to you.
INFORMATION FROM THIRD PARTY SOURCES From time to time, we may obtain information about you from third party sources as permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.
Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publically available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for such processing is to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you based on public interest grounds to ensure our Services are not used fraudulently or for other illicit activities.
Resellers, Channel Partners, Joint Marketing Partners, and Social Media Platforms: We collect information about your publically available social media profile, interests or preferences, and page-view information from some business partners with which we operate co-branded services or joint offerings. There are multiple purposes for collecting this information. First, we process such information under a legitimate interest to better understand you and/or maintain and improve the accuracy of the records we hold about you as well as to position, promote or optimise our Services. In addition, we may also use this information in conjunction with your browsing habits / preferences (as obtained from our data partners) and your contact details, professional information and bitcointobanks transaction history to deliver targeted advertising and marketing to you, where permitted by applicable law and in accordance with your advertising / marketing preferences. Second, we also process such information to provide support to you as part of our contractual obligations to you. Lastly, we process such information in the public interest because it helps us monitor, prevent and detect fraud.
COLLECTION & USE OF INFORMATION COLLECTED AUTOMATICALLY
We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third party site.
HOW WE PROTECT AND STORE PERSONAL INFORMATION
We understand how important your privacy is, which is why bitcointobanks maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the United States and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to bitcointobanks or Coinbase staff.
However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. bitcointobanks will never sell or rent your personal information. We will only share your data in the following circumstances:
We share your information with third party identity verification services in order to prevent fraud. This allows bitcointobanks to confirm your identity by comparing the information you provide us to public records and other third party databases.
We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
We share your information with financial institutions with which we partner to process payments you have authorised.
We may share your information with companies or other entities that purchase bitcointobanks assets pursuant to a court-approved sale under U.S. bankruptcy law and / or where we are required to share your information pursuant to insolvency law in the U.K. or in any other jurisdiction;
We may share your information with any third parties where required to do so by applicable law or any court or other authority to which we are subject in any jurisdiction; or we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the bitcointobanks User Agreement and any other applicable policies.a
We may share your information with other third parties with your consent or direction to do so.
If you establish a bitcointobanks Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a bitcointobanks website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.
HOW PERSONAL INFORMATION IS SHARED WITH THIRD-PARTY SITES AND SERVICES
If you use your bitcointobanks Account to transfer Digital Currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to transfer Digital Currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a Digital Currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a bitcointobanks customer, that Digital Currency transfers are enabled, and/or to notify you that you have received Digital Currency. If you request that we validate your status as a bitcointobanks customer with a third party, we will do so. You may also choose to send Digital Currency to or request Digital Currency from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action.
Please note that merchants you interact with may have their own privacy policies, and bitcointobanks is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you authorise one or more third-party applications to access your bitcointobanks Account, then information you have provided to bitcointobanks may be shared with those third parties. Unless you provide further authorisation, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using bitcointobanks Services.
SPECIFIC CONSENT BY USERS IN SINGAPORE
If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in the USA, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing email@example.com with the subject line "Revoke Singapore data consent".
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab. This right shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
RIGHTS in RELATION TO THE USE OF YOUR PERSONAL INFORMATION
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
RETENTION OF PERSONAL INFORMATION
bitcointobanks will retain your personal data for as long as is necessary for the purposes of our business relationship with you, to perform our contractual obligations to you, or if longer, as required for legal and regulatory purposes.
We have established internal policies for the deletion of data from customer accounts following termination of a customer's subscription to the Service.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
While Coinbase UK, Ltd, and bitcointobanks Payments, Ltd, are based in the United Kingdom (which is within the EEA), our service providers may store, transfer, and otherwise process your personal information in countries outside of the country of your residence, including the United States, the Philippines, and possibly other countries. We use approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland, or require that any third party located in the U.S. receiving your personal information is certified under the E.U.-U.S. and/or the Swiss-U.S. Privacy Shield Frameworks and require that the third party agree to at least the same level of privacy safeguards as required under applicable data protection laws
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please contact us at firstname.lastname@example.org.
CHILDREN'S PERSONAL INFORMATION
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, bitcointobanks will require the user to close his or her account and will not allow the user to continue buying or selling digital currencies. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
HOW TO CONTACT US
bitcointobanks Payments, Ltd
9th Floor, 107 Cheapside, London, EC2V 6DN
Coinbase UK, Ltd
9th Floor, 107 Cheapside, London, EC2V 6DN
You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place. In the UK, the relevant data protection authority is the Information Commissioner's Office (ICO).
Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF