Last Revised: December 13, 2018
SIRIN LABS (“us“, “we” or “Company“) respect the privacy of our users (each, “you” or “User“) and are committed to protect the privacy of Users who access, visit, use, register or engage with our website (collectively: the “Services“).
Legal basis for processing
If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it.
We normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the BitGoals Services you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such information under applicable laws. In some cases, we may need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us through the contact details available below.
What type of information we collect
We may collect two types of data and information from our Users.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information“). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website’s domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information“). Such information may include:
- Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. You may register to the Services directly through our website.
- Registering through our website: When you register to the Services through our website, we may collect from you the following information: full name, email address, as well as any other information you agreed to share with us.
- Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us.
- Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
How we use the information we collect
- To set up your account and to provide our Services;
- To identify and authenticate your access to certain features of the Services;
- To communicate with you and to keep you informed of our latest updates and newsletters;
- To market our website, products and the Services;
- Subject to your explicit consent, to share your Personal Information with our business partners for the purpose of direct marketing;
- To serve you personalized advertisements when you use the Services;
- To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
- To support and troubleshoot the Services and to respond to your queries;
- To investigate and resolve disputes in connection with your use of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information and for what purpose
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers (e.g., Amazon Web Services, CoinGate, Kuende, etc.); (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
In addition, we may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics; and (iv) communicating promotional and informational materials (see below under “Marketing”).
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third party tracking technologies
When you visit or access our Services, we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies“).
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
Third-party collection of information
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA. The data protection and other laws of these countries may not be as comprehensive as those in the EEA − in these instances we will take steps to ensure that a similar level of protection is given to Personal Information, including through adequate contractual measures. You hereby consent to the transfer of Personal Information to countries outside the EEA.
For how long we retain the information
We retain the Personal information we collect from you for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing Personal Data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
Your privacy rights
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:
- Right to receive confirmation as to whether or not Personal Data concerning you is being processed;
- Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
- Right to see what Personal Information about you we have;
- Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
- Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
- Right to export Personal Information in a portable format.
If you wish to exercise any of these rights, contact us at: email@example.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: firstname.lastname@example.org.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.
How we protect your information
We take great care in implementing and maintaining the security of the Services and safeguarding information which relates to you. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
We may use a third-party advertising technology to serve advertisements when you use the Services. This technology uses your information with regard to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org and http://optout.aboutads.info.
We may use your Personal Information, such as your full name, email address, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning the Services.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to:email@example.com.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
The Services are not designated to individuals under the age of 16. If you are under 16 years old, you should not use the Services or provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you by us. In the event that we become aware that an individual under the age of 16 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, it will be advisable to contact us at: firstname.lastname@example.org.
How to contact us
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at: email@example.com.
Moserstrasse 48, 8200 Schaffhausen