Privacy Policy

Cryptovea Inc. as owner Cryptovea domiciled at Jankovce 39, 067 24 Slovakia (“Cryptovea”, “cryptovea.xyz”, “we”; “us”; “our”) respects your privacy and is committed to protecting your personal information or, as otherwise termed, your “personal data”. In that regard, Cryptovea has launched and offers a service which provides our clients (subject to prior account registration) with access to certain virtual financial assets on our website www.crytpovea.xyz (the “Site”) and an online trading platform (the “Platform”) which is accessible via the application Cryptovea. The Platform automatically matches trades with open orders from other traders, In addition to the matching and trading services offered over the Platform, the Platform also offers digital wallet services to registered account users, allowing them to store the virtual financial assets which are traded over the Platform.

This Privacy Policy explains how information about you is collected, used, and disclosed by Cryptovea and to set out the basis on which we will process your personal data when you:

visit and use the Platform (regardless of where you visit or use them from);
apply for and open an account in respect of our Platform (your “Account”); and
apply for, receive or use any of the related services that we offer in connection with the Platform, including our virtual financial assets exchange and digital wallet services (the “Services”).

This includes any data that you may provide for and in relation to our newsletters, updates, events and other marketing and promotional communications.

This Privacy Policy also informs you about:

how we will handle and look after your personal data,
our obligations in regard to processing your personal data responsibly and securely,
your data protection rights as a data subject, and
how the law protects you. It should be read in conjunction with our IP Address and Cookie Policy

Purpose of this Privacy Notice

We process your personal data in an appropriate and lawful manner. This Policy aims to give information on how Cryptovea collects and processes your personal data in the scenarios outlined above in the ‘Introduction’ (namely, through your use of the Platform and our related services, including any data that you may provide to us or which we may receive). The Platform are not intended for minors (i.e., persons under 18 years of age) and we do not knowingly collect personal data relating to minors.

It is important that you read this Policy together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the availability of our Platform (amongst other potential and salient issues). Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.

We encourage you to read the privacy Policy of every website you visit.

KEY DEFINITIONS

Set out below are key definitions of certain data protection terms which appear in this Privacy Policy.

“Consent Form” refers to separate documents which we might from time to time provide you where we ask for your explicit consent for any processing which is not for purposes set out in this Privacy Policy.

“Data subjects” means living individuals (i.e. natural persons) about whom we collect and process personal data.

“Data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed.

“Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).

“Personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Privacy Policy, shall be taken have the same meaning as personal data.

“Processing” means any activity that involves use of personal data. It includes collecting, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying it. Processing also includes transferring personal data to third parties.

“Sensitive personal data”, “sensitive data” or “special categories of personal data” includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, genetics and genetics-related aspects, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings, or the conviction or the sentence of any court in such proceedings.

Note that personal data does not include information relating to a legal person (for example, a company or other legal entity). In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. Naturally, we will still treat any and all such information in a confidential and secure manner.

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed and is not relatable to an identified or identifiable person (anonymous data). In the course of your relationship with us (including during the account opening stage), we may collect, use, store and transfer different kinds of personal data about you which we have grouped together. We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive feature of the Services, fill out a form, participate in a community or forum discussion, complete an exchange transaction, apply for a job at Cryptovea, request customer support or otherwise communicate with us. The types of information we may collect include your name, date of birth, email address, postal address, phone number, certain virtual financial asset information, and, in addition any further information you choose to provide. Only personal information necessary for carrying out and performing our tasks and services, or made available by you on a voluntary basis, is collected. For avoidance of doubt, categories marked in blue are applicable to customers (i.e. individuals who hold a registered customer account with us). We shall request this information in order to be able to register you on our Platform.

We shall request this information in order to be able to register you on our Platform.

Identity Data includes your first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and/or passport number. This will form part of your account information on the Platform.
Contact Data includes your billing address, email address and contact number (telephone and/or mobile).
Financial Data includes your bank account and payment details.
AML / KYC Data includes the following due diligence / KYC information and documentation about you: (i) copy of valid I.D. card or passport, (ii) proof of residence (e.g. confirmation of identity), (iii) KYC database checks, (iv) fraud database checks and (v) any documentation or information which we may, from time to time:
- be required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and global AML/KYC practices.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In all cases, we collect the following information upon access to our Site:

Technical/LOG Data includes the IP address, your login data to the Platform (username and password), information on your internet service provider, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Site and Platform. This also includes information about your use of the Services, including the type of browser time and date of access, pages viewed, and the page you visited before navigating to our Services.
Device Data includes information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Usage Data includes information about how you use the Platform.

The storage’s purpose is based on the security of processing in order to ensure the stability and operational security of the system as well as for statistical purposes in order to derive Aggregated Data from Usage Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data will be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site and/or the Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide Personal Data

Where we need to collect personal data about you:

by law; or
under the terms of, or in connection with, the contract that we have with you (as discussed in Section 1 above); or
as part of our legitimate (business) interests to verify the identity of our applicants and clients, mitigate against risks (such as potential or suspected fraud) and in particular, to assess and take a decision on whether we will or should enter into a relationship with you (as subject to our client acceptance criteria and policies);

and you either fail to provide that data when requested, or else provide incomplete or insufficient data, we may not be able to perform or conclude the contract which we have or are otherwise trying to enter into with you (namely regarding your account opening on the Platform and provision of our related services).

In certain instances, particularly where this relates to AML / KYC Data, we may even need to exercise our prerogative to terminate our contract with you, and thus withdraw the availability of our services to you, or else, if still at application stage, we may have to decline to enter into a relationship with you. We will, however, notify you if this is the case at that point in time.

Sensitive Personal Data

We do not knowingly collect any information qualifying as Special Categories of Personal Data under article 9 of the GDPR (or Sensitive Personal Data) about you. Should we receive sensitive personal data about you, we will only process that data where there is a legitimate reason and purpose as set down in article 9 para. 2 of the GDPR to do so and, in all circumstances, in accordance with our obligations at law and under the appropriate safeguards. We collect and process AML / KYC Data in order to be able to

comply with legal and regulatory obligations, as applicable
conduct our AML and KYC checks, and other due diligence checks, on you
verify your identity or claimed identity and identify and/or verify your source of funds and source of wealth, as appropriate
perform a risk assessment on the potential customer relationship
take an informed decision on whether we want to enter into a customer relationship with you, and, if positive, to conduct initial and ongoing screening and monitoring
to comply with any legal or regulatory obligation that we may have and/or any Court, regulatory or enforcement order that may be issued upon us.

HOW IS YOUR PERSONAL DATA COLLECTED?

Account Registration and Opening.

We will ask you to provide us with your Identity, Contact, Financial and AML/KYC Data when you apply to register and open an account with us on our Platform (including at account finalisation stage). You provide these personal details and information to us, which we collect and process, when you fill in and submit our application form (together with other related forms), and complete our required application steps.

Your Account Data will be generated on the basis of your application, and is also processed and stored by us.

Service Use.

This encompasses namely, Identity, Contact, Financial, AML and KYC Data, Marketing and Communication Data; Enhanced KYC Data, Portfolio Data, and Transaction Data)

Direct Interactions.

You may also give us your Identity, Contact, Financial, AML/KYC Data, Marketing and Communications Data, and Transaction Data by filling in our other forms (i.e. separate to our account opening and registration form), or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data that you provide when you, as applicable:

apply to open an account;
update or edit your account details;
subscribe to our Platform;
request withdrawals from your Account;
contact us with complaints or queries;
report issues;
submit the (additional or supplementary) AML / KYC Data that we may request from you;
request marketing to be sent to you;
participate in a survey; or
provide us with feedback.

Automated Technologies or Interactions.

As you interact with the Platform and the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns (please see the bullet point “Technical/LOG Data” for the relevant information that is collected and processed). We collect this personal data by using cookies, server logs and other similar technologies.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits, manage the registration process for accounts, remember your site preferences, retain certain information to process orders for exchange transactions, and retain information to provide you with support. Web beacons are electronic images that may be used on our Platform or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. Cookies remain stored until you delete them. Thus, we can recognize your browser when you visit the Site again.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of our Services.

The legal basis for the data processed by the way of cookies is article 6 para. 1 subpara. 1 lit. f of the GDPR. Furthermore, we analyse the use of our internet presence with the web analysis tool Google Analytics. This exclusively serves the optimisation of the Site with regard to user-friendliness and to making available useful information about our services. There is no consolidation of this information with other sources of information relating to persons; nor does a transfer to third parties occur.

The legal basis for the temporary storage of information and the logfiles is article 6 para. 1 subpara. 1 lit. f of the GDPR. There is no personal evaluation. The analyses are based on anonymized sets of data.

Third Parties or Publicly Available Sources.

We also obtain information from other sources and combine that with information we collect through our Services. For example, we collect information about you from third parties, including but not limited to social media platforms and publicly available sources.

We also receive personal data about you from various third parties and public sources, as set out below:

Technical Data from the following parties:
- Analytic providers such as Google Analytics:

On our Site, we use “Google Analytics”, a web analysis service by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, for evaluating the usage of our Site. Google Analytics uses cookies that are saved on your computer. The information on the usage of our Site and the internet by the user can be processed and evaluated by Google.

You can opt out of making your site activity available to Google Analytics by installing and activating the Google Analytics opt-out browser add-on (for Chrome, available on https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en) or a similar browser add-on corresponding with the browser you use (Edge, Firefox, Safari etc.). The add-on prevents the Google Analytics JavaScript that is running on websites from sharing information with Google Analytics about visit activity.

The information collected by Google will, if applicable, transferred by Google to countries outside the European Union and the European Economic Area, including in particular to the USA. However, Google has submitted to the Privacy Shield Framework. For further information regarding your rights as a result thereof, please see http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf.

Furthermore, we ensure that your IP Address is anonymised before the transfer to Google.

The legal basis for the use of Google Analytics is article 6 para. 1 subpara. 1 lit. f of the GDPR.

We also receive personal data from advertising networks such as Google Ads, which uses Google

Analytics as explained above: On our Site, we use “Google Ads”, an advertisement service by Google Inc. for providing user information related to Cryptovea. Google Ads uses cookies that are saved on your computer. The information on the usage of our Site and the internet by the user can be processed and evaluated by Google. Regarding the transfer of the relevant information collected by Google, please see the corresponding statement on Google Analytics. The legal basis for the use of Google Ads is article 6 para. 1 subpara. 1 lit. f of the GDPR.;

Identity, Contact, AML / KYC Data

from publicly available sources such as public court documents, the Commercial Register and the company houses and registers of other jurisdictions, and from electronic data searches, online KYC search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists, outsourced third-party KYC providers and from general searches carried out via online search engines (e.g. Google).

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when Slovak Republic law allows us to. Most commonly, we will use our personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you in respect of your customer relationship with us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Purposes for which we will Use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Marketing

We strive to provide you with choices regarding certain personal data uses in relation to your account. Through your Account, Identity, Contact, Technical, Usage and Marketing and Communications Data, we can form a view on what we think you may want or need. We will send details as to how you may enhance your trading activity in relation to the account.

You may receive marketing communications from us (which may consist of newsletters, industry updates, mailshots, publications, promotional materials and/or information about our events) where:

you provide your consent to receiving such marketing material; or
you have an ongoing commercial or contractual relationship with us (e.g. where we consider you to be an active customer and user of the Platform); and
provided you have not opted out of receiving marketing from us

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third parties (including our associated or related corporate entities) for marketing purposes. If consent is not provided, your personal data shall not be shared.

Change of Purpose / Processing under a Different Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court or other enforceable orders.

If we need to use your personal data for an unrelated purpose based on a legal provision requiring such processing, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes :

External third parties.
Suppliers and external agencies that we engage to process information on our and/or your behalf, including to provide you with the information and/or materials that you have requested.
Our subsidiaries, associates and agents where necessary to facilitate your relationship with us.
The Tax Administration, the Office for Data Protection, regulators, law enforcement agencies and other authorities who require reporting of processing activities, or may request information from us, in terms of applicable law and in certain circumstances.
Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
Other organisations where exchange of information is for the purpose of fraud protection or credit risk reduction.
Debt recovery agencies who assist us with the recovery of debts owed to us.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way and for the same purposes as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties access and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.

We may also disclose your data:

if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority, or
if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Cryptovea or others, or
in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; or
if we have your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

DATA SECURITY

While no online or electronic system is guaranteed to be secure, we take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.

In relation to you visiting our Site, we use the industry standard encryption for the connection between our servers and the user's browser. Whether an individual page of our internet presence is transmitted through encryption can be seen by e.g. the shut padlock symbol in your browser’s address bar. We have put in place appropriate technical and organisational security measures to prevent your personal data from being partially or entirely lost, accidentally or intentionally manipulated, used or accessed in an unauthorised way by third parties, altered, disclosed, or destroyed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Our security measures are improved in accordance with technological progress. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time, particularly where we need to take into account and cater for any

business developments and/or
legal or regulatory developments to the issuance or trading of virtual financial assets and virtual financial assets under applicable law. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.