1. Introduction

Cryptal (hereinafter “Cryptal”, “we”, “our”, or “us”) cares about your privacy and protects the privacy of our customers and visitors. This Privacy Policy describes how we handle your information when you use our services on the Cryptal exchange websites. A website with the cryptal.com domain, such as www.cryptal.com (hereinafter “Platform”, “Website”), means our Platform used for providing our product to you.

This Privacy policy (“Privacy Policy”) together with our Terms of Use (“Terms of Use”) sets out the basis on which any Personal Information we collect from you (“you”, “your”, or “customer”), or that you provide to us, will be processed by us. By “Personal Information” we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example, your name, e-mail address, username, contact details, or any unique identifier such as an IP address, device ID, or other online identifier.

2. Gathering and Use of Personal Information

We may collect your Personal Information if you use Cryptal and open an account to use the Platform. This is defined as collection for the purpose of using our website by you in accordance with our Terms of Use.

The types of Personal Information which we collect may include:

1. Your name;
2. Your photographic identification;
3. Details from your identity documents (such as ID card, driver license, passport), number of the document, date of issue and expiration, photographic identification, address, etc.;
4. Your biometric personal data, i.e., your facial image;
5. Your address;
6. Your phone number;
7. Your e-mail address;
8. Your IP address, browser and operating system information, geolocation details;
9. Your banking details, including account numbers and payment card data;
10. Your date of birth;
11. Your employment details;
12. Information on sources of your funds; and
13. Based on our legal obligations and legitimate interest in the prevention of money laundering and fraud, we may request other documents for your identity verification and confirmation of sources of your funds in compliance with our AML policy.
     

We may use your Personal Information for the following purposes:

1. To allow you to open and operate an account on Platform;
2. To identify you and conduct client diligence compliance;
3. To enable you to complete transactions on the Platform;
4. If you contact us, to reply to your queries;
5. To contact you via e-mail or calls;
6. To personalize your experience and offer a more relevant, tailored product;
7. To improve our products;
8. To ensure security of your Account;
9. To analyze your use of our Website;
10. For direct marketing purposes, to provide you with information about products and promotions that may be of interest to you, from us and third parties, although only if you have specifically agreed to receive such information;
11. For market research, e.g., surveying our Users' needs and opinions on issues, such as our performance, etc.;
12. To check client data against the data in multiple databases, including inter alia International Politically Exposed Persons (PEPs) and Sanctions, Country-Specific Sanctions Lists, Criminal Lists, and Financial Lists.

3. IP Addresses

We may collect information about your computer, including your IP address, operating system and browser type, and report aggregate information to our advertisers. This is statistical data about our users' browsing actions and will not be used to identify any individual.

4. Cookies

By using cookies, we collect web browser Information in order to enhance your experience on our Site and track how the product is being used. Cookies are small data files that are stored on your computer’s hard drive. In addition to using cookies to provide you with a better user experience, we use cookies to identify and prevent fraudulent activity. The information collected can include, but is not limited to, your IP address, referral URLs, the type of device you use, your operating system, the type of browser you use, geographic location, and other session data. Cookies are not permanent and will expire after a short time period of inactivity. You may opt to deactivate cookies, but it is important to note that you may not be able to access or use some features of our site. Please note that we are not responsible nor can we be held liable for any loss resulting from your decision or inability to use such features.

5. Disclosure of Personal Information

We use Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy, and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us for the limited purpose indicated to:
 

• Our affiliates and representatives
• Payment service providers and financial institutions
• Customer communications platforms
• Our contractors providing software for identity verification purposes

We may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organization and notify you of such sharing of your information to be able to exercise any of your rights where applicable. 

We may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law. In certain cases, we may not be able to inform you of such sharing of data due to legal restrictions.

6. International Data Transfers

Sometimes we might need to transfer your personal data to third country locations to provide our Product to you. We strive to ensure an adequate level of your personal data protection wherever our contractor is located. Be assured that we may transfer your Personal Information only in the following cases:

• if the country where we transfer your Personal Information provides an adequate level of personal data protection;
• if we take appropriate safeguards to ensure that your rights as a data subject are protected.

7. Your Rights over Your Personal Data

You have the right to access your personal information and to require correction, updating, blocking, deletion, and destruction thereof, in accordance and within the limitations set forth by the laws of Georgia on personal data protection. You can withdraw your consent to direct marketing at any time.

8. Links

There may be links from our Sites to other sites and resources provided by third parties. This Privacy Policy applies only to our Sites. Accessing those third-party sites or sources requires you to leave our Sites.

We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

9. Retention of Personal Information

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. All data you provide to us is stored on our or third-party secure servers located in the European Union.

Your payment method information that you may use to effect payments to or receive payments from Cryptal are passed on to a third-party payment processor(s) which is/are based in Georgia and with which Cryptal has a contractual agreement to safeguard your rights. Unless you create an account with us and conduct transactions, we do not retain your payment method information.

We will hold your Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements.

In accordance with record keeping activities for Anti-Money Laundering and considering the period during which you may bring legal claims against us under the law of Georgia, we will retain Personal Information after our User closes his or her Account and terminates legal relationships with us for five years from the end of the tax period in which the User conducts his or her last transaction.

Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.

10. Marketing

We will ask you for your consent upon registration or post-registration to allow us to contact you or use your Personal Information for marketing purposes.

We may also notify our existing Users of our own products or services.

You have the right to retract your consent for us to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by contacting us at any time at support@cryptal.com.

11. Changes

Our Sites' policies, content, information, promotions, disclosures, and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Cryptal. If we change this Privacy Policy, we will take steps to notify all users by a notice on the Website and we will post the amended Privacy Policy on the Website.

If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continuing our relationship with you.

12. Fraud, Phishing, and E-mail Scams

Please be notified that Cryptal is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media, or who promise to help solve your issues for money.

Remember: customer support is provided only via the CRYPTAL.COM Website and support@cryptal.com, and is always provided by Us.

13. Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices as they relate to the Platform, please contact us at the e-mail address support@cryptal.com.