Date of latest amendment: Sep 9th, 2019
1.Information We Collected
We collect several different types of information for various purposes to provide and improve our Services to you.
1.1 Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Your personal profile picture;
- Email address;
- Birth date;
- First name and last name;
- Phone number;
- Passport or other identity documents;
1.2 Your Device Data
If you access our Services through a mobile device, we may be able to collect certain information related to your device, including but not limited to: unique identifiers(Android ID, mobile advertising identifier ,etc), the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background.
1.3 Your Usage Data
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
1.4 Tracking & Cookies Data
2.How We Use Your Data
We use the collected data for various purposes, including but not limited to the following. If we use your personal information in any other ways, we will disclose this to you. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.
- To provide and maintain the Services;
- To verify user identity and prevent fraud or unauthorized access;
- To notify you about changes to our Services；
- To allow you to participate in interactive features of our Services when you choose to do so;
- To provide customer contact and support Services;
- To provide analysis or valuable information so that we can improve the Services;
- To monitor the usage of the Services;
- To detect, prevent and address technical issues;
- To deliver you certain material relating to our Service;
3.Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers or cloud service center located outside of your country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Our company is headquartered in Switzerland. If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland or any other jurisdiction where we deploys data decenters to process it there.
4.Disclosure Of Data
We may disclose and share your personal data with third-party under the following circumstances:
4.1 Legal Requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation;
- To protect and defend the rights or property ofBiconomy;
- To prevent or investigate possible wrongdoing in connection with the Service;
- To protect the personal safety of users of the Service or the public;
- To protect against legal liability.
4.2 With your consent
With your consent, we may share your personal data with third party for the purpose as prescribed in the consent notice.
4.3 Employees, Third-Party Processors and Third-Party Service Providers
We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.
4.4 Business Transfers or Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
5. Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
6. Third-Party Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may use third-party Service Providers to monitor and analyze the use of our Service.
7. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
8. Information for users residing in the European Economic Area, United Kingdom(collectively referred as "Designated Countries)
This article only applies to all users residing in the Designated Countries at the time of data collection. We may ask you which specific country you come from while you use some of our service, or we may also reply your IP address or other similar technology to identify your country. Where we rely IP address, we can’t apply this article to any user who masquerade his/her IP so as to not appear in the Designated Countries.
8.1 Our Relationship to You
Biconomy is a data controller with regard to any personal information collected from users of its Services. A “user” is an individual providing personal information to us via our Service, such as by creating an account with our Services, signing up for our website, or otherwise accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.
8.2 Legal Basic for Processing Personal Information
The legal basis on which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; necessity to process in the public interest; or for our legitimate interests as described in those sections.
8.3 Marketing Activities
If you are a current user of our Service, we will only contact you by electronic means (such as email or SMS) per your communication preferences and/or with information about our Service that are similar to the Services you previously purchased from us or negotiated to purchase from us.
For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer of marketing emails or contact us at firstname.lastname@example.org . Marketing communications are promotional in nature and do not include transactional or Service-related communications.
8.4 Individual Rights Under EEA's
We provide you with the following rights when you use our Service. Please contact us at email@example.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:
- Where denial of access is required or authorized by law;
- When granting access would have a negative impact on other's privacy;
- To protect our rights and properties;
- Where the request is frivolous or burdensome.
- Right to withdraw consent.
If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
- Right to erasure (the “Right to be Forgotten”).
You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
- Right to restriction.
You have the right to restrict our processing your personal information where one of the following applies:
- You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
- The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
- TWe no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims;
- You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
- Right to object to processing.
You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
- Right to data portability.
If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
- Notification to third-parties.
If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
- Automated individual decision-making, including profiling.
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
- Right to Lodge a Complaint.
If you believe we have infringed or violated your privacy rights, please contact us at firstname.lastname@example.org So that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
We have appointed a local coordinator for privacy/Data Protection Officer (DPO). To get in touch with him/her for any information regarding the Personal Data, please contact: DPO@biconomy.com.
9. Children's Privacy
Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
10. Special Provisions for California Users
California law allows any of its resident to file a request and receive a notice from us, once a year and free of charge, demonstrating what personal information we have shared with our third party partners for direct marketing activities. If you habitually reside in California and would like request this information, you can contact us by sending us an email, which should specify “California Privacy Right Notice”. In general, we would respond your request in 30 days.
12. Contact Us