This Privacy Policy describe how we collect, use, protect and share information about you that we obtain when you use our services, our website or otherwise interact with us. This policy also explains what rights you have due to processing your personal data by us.

We process your personal data in accordance with the General Data Protection Regulation, i.e. the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, hereinafter referred to as “GDPR”.

Please read this Privacy Policy carefully to understand how we will treat your data before you start to use our websites or communicate with us. By using our services or communicating with us about them, you acknowledge that your personal data will be processed in accordance with this Privacy Policy.


Who is a controller of your personal data

The data controller of your personal data is Electric Vault sp. z o.o. with its registered office in Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register under KRS no. 0000861440. You may contact us by e-mail at privacy@btcv.com


How we collect your personal data

We collect information that you provide directly to us when you contact us by sending an e-mail to us.

Additionally we collect certain technical information using cookies to help us operate and provide our services to you. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computers hard drive. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

Personal data of children and usage of our website and services by children

Our website and services are directed to adults. Our services are not intended for children under relevant age of majority, and we do not knowingly collect personal data from children under that age. If you are under the age of majority, you are not permitted to submit any personal data to us.


How we use your personal data

We may use your personal data and technical information we collect, as described to you at the time of collection, for the following purposes:

1. providing, operating and maintaining our services;
2. improving and evaluating our services;
3. developing new features, products or services;
4. customer service and support;
5. tailoring and personalizing the content we provide you, including marketing, promotional and sponsored content and advertising within the services;
6. marketing and communications (like contacting you directly about your use of an account or a service for which you are registered; providing you with information about products or services, from us or third parties that may interest you; serving advertisements to you; and responding to your requests, feedback or questions);
7. research and analytics as regards how you interact with our services, including to monitor usage and activity trends and for statistical purposes; creating reports; measuring or understanding the effectiveness of content, communications, our website visits, web traffic, our services, or advertising we or our clients serve to you, and to deliver relevant advertising to you;
8. legal compliance in order to comply with laws, regulations and requests from law enforcement or other governmental entities; carrying out our obligations and enforce our rights arising from any contracts; and using as evidence for litigation purposes;
9. protecting rights, property and interests of ours or any relevant third party; investigating, preventing or otherwise addressing activity that we, in our sole discretion, may consider to be or pose a risk of being, an illegal, unethical, or legally questionable activity.

We may also create aggregate or anonymous information about your and other users’ use of our services for purposes similar to those listed above.


Legal basis for processing of your personal data

Your personal data will be used by us in a way the law allows us to. The legal basis for the processing of your personal data is accordingly:

a. Article 6(1)(b) of GDPR – i.e. processing is necessary for the performance of a contract we are about to enter into or have entered into with you;
b. Article 6(1)(a) GDPR – i.e. your consent to the processing of your personal data for one or more specific purposes;
c. Article 6(1)(f) of GDPR – i.e. processing is necessary for the purposes resulting from legitimate interests pursued by us or by a third party, which are the performance of a contract we are about to enter into or have entered into with a relevant third party, as well as the establishment, investigation or defense of legal claims resulting from or related to our contractual relations with you or a relevant third party (it should be stressed that we make sure that we consider and balance any potential negative impact on you 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) and/or
d. Article 6(1)(c) of GDPR – i.e. processing is necessary to fulfil the legal obligation imposed on us as the Data Controller. Securing your personal data
The security of your personal data is very important to us. That is why we have implemented administrative, technical and physical safeguards designed to protect your personal data against theft or misuse. Unfortunately, no system, safeguards or procedures can guarantee complete security of your information. As a result, while we strive to protect your personal data from unauthorized third parties access, we cannot ensure or warrant the security of such data. Thus, your use of our website, services and communications with us is at your own risk. You are responsible for protecting the data and for the security of information that you transmit to us over the Internet.


How we may share your personal data

We may share your personal data as follows:

a. with our subsidiaries and affiliates, including any future ones;
b. with our service providers and sub-contractors to the extent reasonably necessary to enable us to provide our services;
c.with a third party with whom we must legally share information about you;
d. with other third parties with your express consent;
e. to comply with any court order, law or legal process, including to respond to any government or regulatory request;
f. to investigate potential unauthorized access or misuse of our services or otherwise enforce or apply our terms of use and other agreements;
g. to protect our assets or rights, including, but not limited to, for billing and collection purposes;
h. if we believe disclosure is necessary or appropriate to protect rights, property or safety of ours or our customers or third parties, including exchanging information with other companies and organizations for the purposes of fraud protection and/or any illegal activities; and
i. with any other entity disclosed by us when you provide the data.

We may also share aggregate or anonymous data for marketing, advertising, research, compliance, or other purposes.

Transfer of your personal data from European Economic Area (“EEA”)

As our business activity is worldwide we may share your personal data with entities cooperating with us around the world. Given that we are an organization of international scope of activity, this may involve transferring your personal data outside of the EEA. Where your personal data is transferred outside of the EEA, we take appropriate measures to ensure that recipients properly protect the personal data. In particular, these measures include:

a. for entities based in the United States – signing with them standard contractual clauses approved by the European Commission or ensuring that they join the EU-US Privacy Shield data protection program or
b. for entities based in other countries outside the EEA, signing with them standard contractual clauses approved by the European Commission.

You can obtain a copy of the above mentioned security features by contacting us at the above mentioned e-mail address for contact in matters related to data processing and data protection.


Google Analytics

This website also uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Inc. is an enterprise of the holding company Alphabet Inc., domiciled in the USA. The information generated by the cookie about your use of the websites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on websites activity and providing other services relating to websites activity and internet usage. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google.

Generally, before the data is transmitted to the provider, the IP address will be abbreviated by activating IP anonymization on this website, within the member states of the European Union or in other contracting states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and abbreviated there. In these cases, we provide contractual guarantees to ensure that Google Inc. maintains a sufficient level of data protection. According to Google Inc., under no circumstances will the IP address be associated with any other user-related data. More information about the web analytics service used is available at the websites of Google Analytics.

We do not use the information and personal data collected by Google Analytics to identify individuals unless we become aware of specific indications of illegal use.


Your rights

As your personal data is processed by us, a company acting in the European Union, you have certain rights under the GDPR. Under the conditions set out in the GDPR you have the right to:

1. request us to access, rectify, delete or restrict the processing of your personal data;
2. object to the processing of your personal data;
3. transfer your personal data;
4. receive a copy of your personal data;
5. withdraw your consent to the processing of your personal data at any time without affecting the lawfulness of the processing that was carried out on the basis of your consent prior to its withdrawal (this applies if the processing is based on your consent);
6. lodge a complaint with the data protection authority at any time. We hope, however, that we would be able to resolve any concerns that you may have before you approach your data protection authority, so please do contact us in the first instance. How long will we use your personal data?

We will keep your personal data only for as long as is necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations. It means that in practice we will process your personal data no longer than until the end of the calendar year in which the longest period possible under the relevant legal regulations expires: the statute of limitations for public law liabilities or the statute of limitations for potential contractual claims that may be raised against us due to civil contractual or tort liability.

We will not keep more data than we need.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time to align with changes to our business practices and/or changes to our legal requirements. We will post the updated Privacy Policy on this website and will indicate that the updates have been made by changing the effective date first written above. We urge you to check back periodically to see whether there have been updates to our Privacy Policy.

Your continued use of our services or communication with us about our services or our website after the updated Privacy Policy has been posted (or any other indication of your consent) will constitute your acceptance of the updated Privacy Policy. Please note that we may condition your continued access to our services on your consent to changes to this Privacy Policy.

For more information on applicable privacy regulations, you may refer to:

EU General Data Protection Regulation:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG


Contact us

Should you have questions, remarks, comments or requests relating to this Privacy Policy or wish to opt out of any usage of your personal data as described herein, please e-mail us at privacy@btcv.com

Last updated on October 6th, 2020.

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