BETA

Bitwyre Privacy Statement

[Last updated November 1, 2023]

Thank you for visiting https://bitwyre.com (the “Site”). The Site is owned and operated by Bitwyre AG or PT.Teknologi Struktur Berantai and its affiliates (together “Bitwyre”). “we”, “our”, or “us” means either or respectively: Bitwyre Inc., and Bitwyre Financial Technologies Limited.

This privacy notice (“Privacy Statement”) 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, email address, username, contact details or any unique identifier such as device ID or other online identifier.

Capitalised terms that are not defined in this Privacy Statement shall have the meaning ascribed in our Terms of Service (which can be found at Bitwyre Regulatory & Compliance Statement) or the additional terms incorporated into or referenced in such Terms of Service.

Please read the following carefully to understand what Personal Information we collect, how that Personal Information is used and the ways it can be shared by us.

Our Processing of Your Personal information

Purpose

Personal Information

Legal Basis

From You

From Others and Your Devices

You are using us

(performance of a contract)

Establish and maintain a commercial relationship with you (creation and management of your Accounts with us, including dealing with your request to make Accounts changes)

Username, email address, password, time zone.

Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site, logs history

Understand your needs and your eligibility for products and services

Contact details, investment history

N/A

Deliver our Services to you (including in relation to Sub accounts)

Username, email address, digital token wallet addresses, accounts, deposit and withdrawals, deposits addresses, balance history, bank account numbers, Personal Information posted by you

N/A

Purchasing or repurchasing tokens on the Site and responding to enquiries and problems that may arise in relation to such purchase or repurchase

Username, email address, digital token wallet addresses, accounts, deposit and withdrawals, deposits addresses, balance history,  bank account numbers, Personal Information posted by you

N/A

Inform you about trading and financing features, inform you on developments and new products

Contact details

N/A

Operation of Derivative Service

Personal Information you provide when you created or update you user profile, or the information you create, post or submit through the Bitwyre Service, such as in Public or Private, Bitwyre Bio, your username and nickname, wallet addresses

Information about your usage patterns and behaviours on the Bitwyre Services.

Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site, logs history

Operation of the P2P MarketPlace

Personal Information you provide when you create or update your P2P MarketPlace Bio, such as details about yourself and your display name

Personal Information you provide when posting notices on the electronic bulletin board, communicating through the electronic chat functionality, or otherwise choose to enter, including in a “free form” text field, including information about your payment methods or any other Personal Information you may decide to share.

Personal Information in your P2P MarketPlace Bio about you or about your use of the P2P MarketPlace Services populated by us, such as the amount of time since your account was verified, your verification level, how long you have been using the P2P MarketPlace Services, number of P2P MarketPlace transactions you have completed or cancelled, average time to confirm a transaction

Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the P2P MarketPlace, length of visits, interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the P2P MarketPlace, logs history

Process billing and collection of any fees

Contact details, email address, Token Wallet addresses, deposit and withdrawals, deposits addresses, balance history, bank account numbers, Personal Information posted by user

N/A

Administer the website, system administration and detecting usage patterns (including broad demographic information for aggregated use), provide information about developments and new products, including enhancement to the Site, develop and enhance the Site, sending you service announcement

Contact details

Browser type, access times, URL requested and referral URL

We think we can

(legitimate interest)

Detection for troubleshooting purposes

N/A

Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site

Comply with industry self-regulatory, audit and security requirements

Username, email address, full name and contact details, 1 forms of ID, picture (KTP for Indonesian or Passport), signature, skype pseudo and call, bank accounts numbers, employment status, certificate of incorporation, business registration, article of association, ownership and control structure, directors, authorised signatories.

N/A

Protect the right, property, safety of us, our clients or others

Any of the Personal Information in this table, taking into account necessity and data minimization

N/A

Conduct surveys and get feedback from you

Contact details

N/A

Ensure that yours or the other customers’ usage of the P2P MarketPlace Services complies with our terms and applicable laws

Personal Information you provide when posting notices on the electronic bulletin board or communicating through the electronic chat functionality

Personal Information you provide in complaints sent through the P2P MarketPlace reporting process or via email

Technical information the browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the P2P MarketPlace, length of visits, interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the P2P MarketPlace, logs history

Administer the P2P Market Place, detect usage patterns, develop and enhance the P2P Market Place Services

Personal Information you provide when posting notices on the electronic bulletin board or communicating through the electronic chat functionality

Personal Information we collect from your usage of the P2P Market Place Services including IP address, browser type, access times, URL requested and referral URL, interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the P2P Market Place, logs history

Provide you with news and other matters of general interest to you as a Bitwyre customer

Email address

Technical information through cookies, web beacons and other tracking technologies (and plug-ins)

You agreed to it

(consent)

Meet our legal and regulatory requirements, including checking your identity against money laundering and terrorist financing or answering your requests

Username, email address, full name and contact details, 1 forms of ID (KTP for Indonesian citizen and/or Passport), gender, date of birth, nationality, picture, signature, skype pseudo and call, bank accounts numbers, proof of residence.

Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site

Compliance with a legal requirement

Verifying your identity for authentication purposes and Know-Your-Customer requirements (i.e., automated match between your selfie and your ID picture)

Facial geometries derived from the picture used in official documentation (such as your ID or passport) and your selfie.

N/A

You agreed to it

(consent)

When we say that we think we can process your Personal Information, it is because we considered we have a legitimate interest (for ourselves or of a third party) to do so; it is in the interest of our organisation to conduct and manage our business; this includes conducting analytics to improve and optimise the Site and the services, protecting our interests and enforcing agreements with others, as well as complying with industry self-regulatory requirements.

We might have legitimate interest to process Personal Information in other contexts. We ensure that we balance any potential impact on you and your rights before we process your Personal Information on that basis. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Please also consult the section “Your rights” below.

It is important that the Personal Information we collect from you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You can do so by lodging a customer support ticket. We will endeavour to effect those changes within a reasonable timeframe.

If you do not wish for your Personal Information to be used in the ways described within this Privacy Statement then you should not use the Site or use the services, functions, or features offered from time to time on the Site (“Services”). Where we need information from you to offer our Services or meet any of our legal or regulatory requirements, failure to provide such information will mean that you will not get access to the Services.

We do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies (please see our cookies policy for more details) when we send third party direct marketing communications to you via email or text message and when we process special categories of data in our automated check of your ID for authentication purposes and Know-Your-Customer requirements. From time to time, Bitwyre may share your Personal Information with third parties with your consent.

1. Aggregated Data

We may also aggregate personal and other data captured by us so that the data is no longer capable of identifying an individual. Aggregated data may cover patterns of usage or information and data that you provide to us, and we reserve the right to use this aggregated information for the purposes of improving and enhancing our Services, generating insights, for use in marketing to other users and current and potential partners and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be Personal Information and is not covered by this Privacy Statement.

2. Security and Confidentiality

We are committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers' Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality. We audit our personal compliance regularly.

The Site's systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We take all reasonable endeavours to protect and safeguard Personal Information. Unfortunately, the transmission of information via the Internet is not completely secure. While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us over email or through the Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or online. Do not keep wallet seed phrases online. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA). You should change your password regularly. We will never DMed you through an unofficial channel.

3. Sharing your Personal Information

Sharing with third parties

As necessary, we will share your Personal Information with:

  1. With any member of our group, including any of our Associates or Affiliates or any of their representatives.
  2. With our service providers, to the extent necessary to supply the Services to you.
  3. With selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services.
  4. With third-Party Services integrated with our Site.
  5. With authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us
  6. If Bitwyre or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
  7. If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.

Bitwyre reserves the right to share current and historical bids, asks, and market prices; opening and closing range prices; high-low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the Digital Tokens.

Sharing with other customers.

If you are using the P2P Market Place Services we will share your Personal Information with other customers of the P2P Market Place, to the extent necessary to supply the P2P Market Place Services.

We will share the following Personal Information with the customers of the P2P Market Place:

  • Personal Information you provide when you create or update your P2P Market Place Bio (such as details about yourself, your display name);
  • Personal Information in your P2P MarketPlace Bio about you or about your use of the P2P MarketPlace Services populated by us (such as the amount of time since your account was verified, your verification level, how long you have been using the P2P MarketPlace Services, number of P2P MarketPlace Services transactions you have completed or cancelled, average time to confirm a transaction); and
  • Personal Information you provide when posting notices on the electronic bulletin board.

When you are communicating through the electronic chat functionality, we will also share Personal Information you provide with customers of the P2P MarketPlace involved in that direct communication.

Transfers.

Your Personal Information will be stored in Japan and may be transferred worldwide.

Personal Information and other data may therefore be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

EEA customers. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Statement. All data you provide to us is stored on our secure servers. Where we transfer our data outside of the EEA, we ensure that adequate safeguards are in place. That includes, where necessary, taking steps to evaluate the risks raised by the transfers in countries that do not offer an adequate level of protection. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

Data Retention

We have data retention and deletion policies designed to retain Personal Information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business needs. Because of those retention requirements, we might not be able to honour erasure requests.

Your rights.

All customers. You may access, verify, request the deletion of your Personal Information held by Bitwyre and, where consent is the legal basis for processing of your Personal Information and subject to any legal or contractual restrictions, withdraw your consent, in each case, by a written request to Bitwyre at here. Our email communications also contain opt-out mechanisms and options to update your contact information or change your preferences at any time. We will do our best to honour your request promptly. For cookies, this is done by setting up the cookie’s preferences. Please visit our Cookies Policy.

EEA customers. You have a number of rights in relation to how we process your Personal Information. You may exercise these rights by contacting us (see details below). These include the right to:

  • access the Personal Information that we may hold about you;
  • rectify any inaccurate Personal Information that we may hold about you;
  • have your Personal Information erased in certain circumstances, for example, where it is no longer necessary for us to process your Personal Information to fulfill our processing purposes; or where you have exercised your right to object to the processing;
  • restrict the processing of your Personal Information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
  • object to the processing of your Personal Information which may be exercised in certain circumstances, for example, where we are processing your Personal Information for direct marketing purposes, or where your own legitimate interests outweigh ours;
  • have your Personal Information ported to a new service provider if you no longer wish to use the Services. You may exercise these rights by contacting us (see details below);
  • when we rely on your consent to process Personal Information (special categories of data, cookies and newsletter communication), you have the right to withdraw your consent at any time. For cookies, this is done by setting up the cookie’s preferences. Please visit our Cookies Policy https://www.bitwyre.com/cookie. For newsletters, you can do so by opting-out using the link provided in the newsletters at any time or by lodging a customer support ticket. For special categories of data, please send a written request to Bitwyre at here. We will do our best to honor your request promptly.

No fee usually required.

You will not have to pay a fee to access your Personal Information or to exercise any of your other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Statement

Any changes we make to our Privacy Statement in the future will be posted on this page and, where material, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Statement.

Contact

If you have any questions or concerns about this Privacy Policy or our privacy practices, or wish to exercise your rights, please contact at  here

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