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Stibits Privacy Policy

This Privacy Policy explains how Stibits (“Stibits”) collects, uses, shares, and protects user information obtained through the Binance.com website. The terms “we,” “us,” and “our” refer to Stibits and its affiliates. When we ask for certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with this non-required information; you may not be able to access or utilize all of our Services if you choose not to.

By using the Site, you consent to the data practices described in this Privacy Policy. On occasion, Stibits may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. If material changes are made to this Privacy Policy, the changes will be announced by posting on the site. We will ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.

The latest privacy policy has incorporated elements from the General Data Protection Regulation (GDPR).

1. PERSONAL INFORMATION WE MAY COLLECT

Personal Information

While providing our Services, we may collect Personal Information, namely:

  1. An information necessary for registration. In order to access the full functionality of the Service, you need to register. When you go through the registration process, you shall provide an e-mail address and create a password. You may also choose to log in via supported third-party service provider (for example, Twitter, Facebook and Google+).
  2. Transaction Information. For all personal user accounts, we collect transaction information including transaction history.
  3. An information, which we may collect through automated means. Through your use of our Services, including exchange tools, we also monitor and collect tracking information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Us or through third party services.
  4. Sometimes you decide or we require (for example in case of KYC procedure) to share with us some other Personal Information, we may collect it as well.

Information collected automatically

We may collect information about Users whenever they interact with our Service, for example, through the use of cookies. Such information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as IP address, location, date and time of connection, the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. Learn more about the way our Site may use cookies in our Cookie Policy.

2. WHY WE COLLECT INFORMATION

To provide and maintain our services

We use the information collected to deliver our services and verify user identity.

We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without data like identification, contact information and transaction-related information.

To protect our users

We use the information collected to protect our platform, users’ accounts and archives.

We use IP addresses and cookie data to protect against automated abuse such as spam, phishing and Distributed Denial of Service (DDoS) attacks.

We analyze trading activity with the goal of detecting suspicious behavior early to prevent potential fraud and loss of funds to bad actors.

To comply with legal and regulatory requirements

Respect for the privacy and security of data you store with Stibits informs our approach to complying with regulations, governmental requests and user-generated inquiries. We will not disclose or provide any personal information to third party sources without review from our legal case team and/or prior consent from the user.

To measure site performance

We actively measure and analyze data to understand how our services are used. This review activity is conducted by our operations team to continually improve our platform’s performance and to resolve issues with the user experience.

We continuously monitor our systems’ activity information and communications with users to look for and quickly fix problems.

To communicate with you

We use personal information collected, like an email address to interact with users directly when providing customer support on a ticket or to keep you informed on log ins, transitions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.

To enforce our Terms of Use and other agreements

It is very important for us and our customers that we continually review, investigate and prevent any potentially prohibited or illegal activities that violate our Terms of Service. For the benefit of our entire user base, we carefully enforce our agreements with third parties and actively investigate violations of our posted Terms of Use. Stibits reserves the right to terminate the provision of service to any user found engaging in activities that violate our Terms of Use.

3. HOW WE COLLECT INFORMATION

(A) 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 finalization 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.

(B) Service Use.

This may encompass all of the data categories namely, Identity, Contact, AML and KYC Data, Enhanced KYC Data and Transaction Data).

(C) Direct Interactions.

You may also give us your Identity, Contact, Financial, AML/KYC 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.

(D) 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. 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.

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.

(E) Third Parties or Publicly Available Sources.

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

We may 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;
    • advertising networks;
    • search information providers.
  • Identity, Contact, AML / KYC Data from publicly available sources such as public court documents, the RoC 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).

4. HOW WE PROTECT YOUR INFORMATION

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers;

Transmission of information to us by email Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

5. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal data when law allows us to. Most commonly, we will use your 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. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of DataLawful Basis for Processing (including Basis of Legitimate Interest)
(i) To conduct due diligence checks on you (following your application to open and register an account).
(ii) To determine if we will enter into a relationship with you and, if positive, to register your account and on-board you as a new customer.		(a) Identity;
(b) Contact;
(c) Financial;
(d) AML / KYC Data;		(a) Performance of a contract with you.
(b) Necessary for compliance with our legal obligations
(c) Necessary for our legitimate interests, including to establish and verify:
  • your identity and suitability for our Platform,
  • the existence of any risks that you may present as a prospective customer,
  • your ability to meet financial commitments,
  • and ultimately, to enable us to take an informed decision on whether we should enter into a relationship with you.
(i) To establish and verify your identity.
(ii) To fulfil our other internal KYC policies and requirements.
(iii) To fulfil any external mandatory reporting obligations that we may have to the FIAU, the MFSA, the RoC, the Police and any other (including overseas) public, regulatory, law enforcement or tax authority.		(a) Identity;
(b) Contact;
(c) AML / KYC Data;
(d) Transaction;
(e) Enhanced KYC Data.		(a) Necessary to comply with a legal obligation.
(b) Necessary for our legitimate interests (for risk assessment purposes, to prevent and mitigate against fraud, to safeguard the reputation of our business).
To provide the Services, in particular:
(i) to match any orders for virtual financial assets in order to find an appropriate trade with another registered user;
(ii) manage payments, fees, charges and subscription costs; and
(iii) collect and recover money as may be appropriate; and
(iv) investigate any suspected fraudulent transactions		(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Portfolio		(a) Performance of a contract with you
(b) Necessary for our legitimate interest to collect and recover debts and prevent fraudulent transactions
For legal, tax and accounting purposes (e.g. reporting to tax authorities, and accounting record requirements).(a) Financial; and
(b) Transaction.		Necessary to comply with a legal obligation.
To detect, prevent and report fraudulent or suspicious orders/transactions.(a) Identity;
(b) Contact
(c) Applicant
(d) AML / KYC Data
(e) Enhanced KYC Data;
(f) Financial;
(g) Portfolio;
(h) Transaction.		Necessary for our legitimate interests, including in particular to:
  • protect the reputation of our business;
  • avoid any complicity or association with fraud;
  • report fraudulent or otherwise suspicious orders that we receive (or which later came to our knowledge) to relevant public authorities.
To manage our relationship with you, including in particular to:
(i) notify you about changes to our terms and conditions or privacy notices;
(ii) inform you about changes to our Platform (including the addition of new virtual financial assets that are available to trading);
(iii) deal with your inquiries, requests, complaints or reported issues;
(iv) provide you with customer support and assistance;
(v) contact you in relation to your account, portfolio and other related matters;
(vi) ask you to participate in a survey;
(vii) request feedback from you;
(viii) advise you of industry and legislative updates;
(ix) inform you about our events;
(x) provide you with information about our Platform;
(xi) administer your account;
(xii) provide you with any other information or materials that you have requested to receive from us;
(xiii) manage disputes with you or other players;
(xiv) to identify and correct issues with the Platform and/or the Site.		(a) Identity;
(b) Contact;
(c) Financial;
(d) Account;
(e) Portfolio;
(f) Transaction;
(g) Usage;
(h) Profile;
(i) Marketing and Communications.		(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (for ‘customer care’ and service matters, to study how clients use our Platform, to assess our operations, to develop them and grow our business).