Last Updated: Jan 1, 2022
EU-U.S. Privacy Shield Framework
What Information We Collect; the Purpose of Collection and Use
We collect the following categories of information. Subscribers of our Services (“Subscribers”) authorize the collection, processing and transfer of such information, and assume contractual responsibility for providing notification to Subscriber’s customers who are end users of the Services and obtaining all consents as required under applicable laws and regulations.
Contact Information: We collect contact information on our Site from visitors, and customers who wish to obtain information or support, to purchase our Services or receive our newsletter. Contact information is provided via browser forms or online forms, and includes first name, last name, e-mail address, name of the organization, and country (“Contact Information”). This Contact Information is used by our sales, support and product teams to contact our Site visitors and customers, as appropriate, for the purpose of providing the requested information, support, Services, newsletters, or other news, materials or updates regarding our Services.
Service Information: In the course of performing our Services, we collect the following categories of information (collectively, “Service Information”).
End User Information: End User means (i) Subscribers’ customers who are end users of our Services; and (ii) all customers of Securitief ’s other Subscribers who seek to enter into Transactions (as defined below) through the Services. We may collect limited End User information at the direction of our Subscribers. Where we have End User information it is limited to IP addresses and e-mail addresses. Subscribers may, at their discretion, prefer to keep all End User information private consistent with their internal policies. Alternatively, Subscribers may utilize the functionality to collect limited private information (which is only accessible in a Subscriber’s environment). End User information is used to operate, maintain and improve the Services.
Transaction Information: We collect transaction-related information for transactions conducted by End Users through the Services (“Transactions”) but it is anonymized. Transaction information includes price, quantity, and any associated or supporting data related to the trade. Transaction information is used to provide the Services, facilitate the Transactions, provide support, and to operate, maintain and improve the Services.
Billing Information: We collect billing and payment information which may include a purchase order number, an account number, credit card number, expiration date, billing zip code, bitcoin-related information, instructions for wire transfers, and/or ACH transfers (“Billing Information”) from Subscribers (and not End- Users). Billing Information is collected and processed by our third-party payment processor operating as our agent (See, Onward Transfers to Third Parties). Securitief does not directly obtain or process any Billing Information; except in the case of ACH transfers in which case we obtain the Billing Information related to ACH transfers and send (not store) it to our third-party bank processors operating as our agent (See, Onward Transfers to Third Parties).
Other Information: In addition to the Contact Information, Service Information, and Billing Information, we may collect or receive the following information:
From Your Activity. In an ongoing effort to improve the Site and the Services, we automatically collect certain information when visitors visit the Site and when Subscribers and End Users use the Services. This information consists of IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site visitors visit, and similar information concerning your use of the Site and the Services.
From Web Beacons. A “Web Beacon” is an object embedded in a web page, which allows website operators to check whether a user has viewed a particular web page or an email, and which typically are invisible to the user. Securitief may use Web Beacons on its Site and in its emails to count users who have visited particular pages or viewed emails, and with respect to Securitief ’s Services. Note that Web Beacons are not used to access personal information. They are used purely to compile aggregated statistics about Site and the Services usage. Web Beacons collect only a limited set of information including a Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. While you may not decline Web Beacons, you may render them ineffective by declining all Web Beacons or modifying your browser settings to provide notifications each time a Web Beacon is tendered – allowing you to accept or decline Web Beacons on an individual basis.
For Google Analytics, please visit: https://www.google.com/analytics
For Google Adwords, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
Aggregate Data. In an ongoing effort to better understand our users and the Site and the Services, we may analyze your information in aggregate form and also merge it with other data to use for our reporting, planning, development, operating, maintaining, managing, and improving the Site and the Services and for promotional purposes. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Service and the Site to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
Opt-In to Certain Onward Transfers
We will not transfer your personal information to a third party controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.
We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. You may grant such consent by contacting us at firstname.lastname@example.org.
In each instance, please allow us a reasonable time to process your response.
Disclosures to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: email@example.com. Please allow us a reasonable time to process your request.
How We Protect Your Information
We have implemented security policies, rules, and technical measures to protect and safeguard your personal information within our custody from unauthorized access, improper use or disclosure, unauthorized modification, as well as unlawful or unintended destruction or loss, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. You should keep in mind, however, that no internet transmission is 100% secure or error-free. In particular, e-mail sent to or from the Site and/or the Services may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other electronic means.
Our Site may contain links to other sites, for instance regarding our partners or clients, or media coverage of Securitief services. Other sites may also reference or link to our site. Securitief encourages you to review the privacy and security policies of any externally linked websites that may be accessed through the Site. Please note Securitief is not responsible or liable for the information collection and disclosure practices of any such external websites and for the privacy practices or content of such external sites. Please check the privacy policies of these external websites before you submit any personal information or other information to them.
Access to Personal Information
Should you choose to unsubscribe from any mailing lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Securitief communications.
Retention of Personal Information
Important Notice to All Non-U.S. Residents
Our servers are located in the US and outside of the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US or other jurisdictions. Except in the case of data transfers under the EU-US Privacy Shield, your decision to provide such data to us, or allow us to collect such data it through our Site and/or the Services, constitutes your consent to this data transfer.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Securitief via email at firstname.lastname@example.org.
In addition, Securitief does not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.
If you have any queries about the privacy statement or to report a privacy issue, please contact us in one of the following ways:Email: email@example.com
Last Updated: Jan 1, 2022
- USE OF PERSONAL INFORMATION
- COMMUNITY GUIDELINES
Securitief ’s community, like any community, functions best when its people follow a few simple rules. By accessing and/or using the Site, you hereby agree to comply with these community rules and that:
• You will comply with all applicable laws in your use of the Site and will not use the Site for any unlawful purpose;
• You will not access or use the Site to collect any market research for a competing business;
• You will not upload, post, e-mail, transmit, or otherwise make available any content that:
• infringes any copyright, trademark, right of publicity, or other proprietary rights of any person or entity; or
• is threatening, tortious, defamatory, libelous, indecent, obscene, pornographic, invasive of another’s privacy, or promotes violence; or
• discloses any sensitive information about another person, including that person’s e-mail address, postal address, phone number, credit card information, or any similar information;
• You will not “stalk” or otherwise harass another;
• You will not impersonate any person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity;
• You will not decompile, reverse engineer, or disassemble any software or other products or processes accessible through the Site;
• You will not circumvent, remove, alter, deactivate, degrade, or thwart any of the protections in the Site;
• You will not use automated means, including spiders, robots, crawlers, data mining tools, or the like to download or scrape data from the Site, directly or indirectly, except for Internet search engines (e.g., Google) and non-commercial public archives (e.g., archive.org) that comply with our robots.txt file;
• You will not use, frame, or utilize framing techniques to enclose any Securitief trademark, logo, or other proprietary information (including the images found on the Site, the content of any text, or the layout/design of any page or form contained on a page) without Securitief ’s express written consent;
• You will not use meta tags or any other “hidden text” utilizing Securitief ’s name, trademark, or product name without Securitief ’s express written consent;
• You will not take any action that imposes or may impose (in our sole discretion) an unreasonable or disproportionately large load on our technical infrastructure;
• You will not interfere with or attempt to interrupt the proper operation of the Site through the use of any virus, device, information collection or transmission mechanism, software or routine, or access or attempt to gain access to any data, files, or passwords related to the Site through hacking, password or data mining, or any other means; and
• If you find something that violates our Community Guidelines, please let us know, and we’ll review it.
We reserve the right, in our sole and absolute discretion, to deny you access to the Site, or any portion of the Site, without notice, and to remove any comments that do not adhere to these guidelines.
- INTELLECTUAL PROPERTY
The Site contains materials, such as software, text, graphics, images, sound recordings, audiovisual works, white papers, and other materials provided by or on behalf of Securitief (collectively referred to as the “Content”). The Content may be owned by us or by third parties. The Content is protected under both United States and foreign laws. Unauthorized use of the Content may violate copyright, trademark, and other laws. You have no rights in or to the Content, and you will not use the Content except as permitted under this Agreement. No other use is permitted without prior written consent from us. You must retain all copyright and other proprietary notices contained in the original Content on any copy you make of the Content. You may not sell, transfer, assign, license, sublicense, or modify the Content or reproduce, display, publicly perform, make a derivative version of, distribute, or otherwise use the Content in any way for any public or commercial purpose. The use or posting of the Content on any other website or in a networked computer environment for any purpose is expressly prohibited.
If you violate any part of this Agreement, your permission to access and/or use the Content and the Site automatically terminates and you must immediately destroy any copies you have made of the Content.
The trademarks, service marks, and logos of Securitief(“Securitief Trademarks”) used and displayed on the Site are registered and unregistered trademarks or service marks of Securitief . Other company, product, and service names located on the Site may be trademarks or service marks owned by others (the “Third-Party Trademarks”, and, collectively with the Securitief Trademarks, the “Trademarks”). Nothing on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use the Trademarks, without our prior written permission specific for each such use. Use of the Trademarks as part of a link to or from any site is prohibited unless establishment of such a link is approved in advance by us in writing. All goodwill generated from the use of the Securitief Trademarks inures to our benefit.
Elements of the Site are protected by trade dress, trademark, unfair competition, and other state and federal laws and may not be copied or imitated in whole or in part, by any means, including but not limited to the use of framing or mirrors. None of the Content may be retransmitted without our express, written consent for each and every instance.
- COMMUNICATIONS WITH US
Although we encourage you to e-mail us, we do not want you to, and you should not, e-mail us any content that contains confidential information. With respect to all e-mails you send to us, including but not limited to, feedback, questions, comments, suggestions, and the like, we shall be free to use any ideas, concepts, know-how, or techniques contained in your communications for any purpose whatsoever, including but not limited to, the development, production and marketing of products and services that incorporate such information.
- NO WARRANTIES; LIMITATION OF LIABILITY
- EXTERNAL SITES
The Site may contain links to third-party websites (“External Sites”). These links are provided solely as a convenience to you and not as an endorsement by us of the content on such External Sites. The content of such External Sites is developed and provided by others. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or any content located on such External Sites. We are not responsible for the content of any linked External Sites and do not make any representations regarding the content or accuracy of materials on such External Sites. You should take precautions when downloading files from all websites to protect your computer from viruses and other destructive programs. If you decide to access linked External Sites, you do so at your own risk.
You agree to defend, indemnify, and hold us and our officers, directors, employees, successors, licensees and assigns harmless from and against any claims, actions, or demands, including, without limitation, reasonable legal and accounting fees, arising or resulting from: (i) your breach of this Agreement; (ii) your misuse of the Content, or the Site; and/or (iii) your violation of any third-party right, including without limitation any copyright, trademark, property, or privacy right.
- COMPLIANCE WITH APPLICABLE LAWS
The Site is based in the United States. We make no claims concerning whether the Content may be downloaded, viewed, or be appropriate for use outside of the United States. If you access the Site, or the Content from outside of the United States, you do so at your own risk. Whether inside or outside of the United States, you are solely responsible for ensuring compliance with the laws of your specific jurisdiction.
- TERMINATION OF THE AGREEMENT
We reserve the right, in our sole discretion, to restrict, suspend, or terminate this Agreement and your access to all or any part of the Site, at any time and for any reason without prior notice or liability. We reserve the right to change, suspend, or discontinue all or any part of the Site at any time without prior notice or liability.
- DIGITAL MILLENNIUM COPYRIGHT ACT
Securitief respects the intellectual property rights of others and attempts to comply with all relevant laws. We will review all claims of copyright infringement received and remove any Content or user submissions deemed to have been posted or distributed in violation of any such laws.
Our designated agent under the Digital Millennium Copyright Act (the “Act”) for the receipt of any Notification of Claimed
Infringement which may be given under that Act is as follows:
ATTENTION: LEGAL DEPARTMENT
If you believe that your work has been copied on the Site in a way that constitutes copyright infringement, please provide our agent with notice in accordance with the requirements of the Act, including (i) a description of the copyrighted work that has been infringed and the specific location on the Site where such work is located; (ii) a description of the location of the original or an authorized copy of the copyrighted work; (iii) your address, telephone number and e-mail address; (iv) a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent or the law; (v) a statement by you, made under penalty of perjury, that the information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf; and (vi) an electronic or physical signature of the owner of the copyright or the person authorized to act on behalf of the owner of the copyright interest.
This Agreement is governed by the internal substantive laws of the State of New York, without respect to its conflict of laws provisions. Except for proceedings commenced by Securitief to protect its intellectual property or confidential information which may be brought in any court of competent jurisdiction, the parties mutually agree that any and all disputes arising hereunder shall be resolved exclusively by state or federal courts located in the State of New York. If this Agreement is terminated in accordance with the Termination provision above, such termination shall not affect the validity of the following provisions of this Agreement, which shall remain in full force and effect: “Intellectual Property,” “Communications with Us,” “No Warranties; Limitation of Liability,” “Indemnification,” “Termination of the Agreement,” and “Miscellaneous.” You may not assign this Agreement. Our failure to act on or enforce any provision of the Agreement shall not be construed as a waiver of that provision or any other provision in this Agreement. No waiver shall be effective against us unless made in writing, and no such waiver shall be construed as a waiver in any other or subsequent instance. You may not assign this Agreement. Except as expressly agreed by us and you in writing, this Agreement constitutes the entire Agreement between you and us with respect to the subject matter, and supersedes all previous or contemporaneous agreements, whether written or oral, between the parties with respect to the subject matter. The section headings are provided merely for convenience and shall not be given any legal import. This Agreement will inure to the benefit of our successors, assigns, licensees, and sublicensees.