Last updated: 17 January 2024
This Privacy Policy (“Policy”) describes how CLICKBIT CHAIN (also “CLICKBIT CHAIN”, “we”, “our” or “us”) collects, protects, and processes your personal data on our Token Buyer Portal (https://clickbit.cash, the “Portal”). This Policy is not necessarily a comprehensive description of our data processing. It is possible that other privacy policies, terms and conditions, forms or other notices may apply to specific circumstances. We use the word “data” here interchangeably with “personal data”.
If you provide information to us about any person other than yourself, contact person of your organization, your employees, counterparties, your advisers or your suppliers, you must ensure that the data is accurate and that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
This Policy, along with our Terms of Use, AML Policy and Risk Disclaimer, sets the legal framework for your interaction with the Portal. We are committed to protecting your privacy and ensuring a transparent understanding of how your data is managed.
This Policy is aligned with the EU General Data Protection Regulation (“GDPR”) and the Swiss Data Protection Act (“FADP”). However, the application of these laws depends on each individual case.
The responsible person for processing your data under this Policy (“Controller”) unless we tell you otherwise in an individual case is:
CLICKBIT CHAIN
c/o MJP Partners AG
Bahnhofstrasse 20
6300 Zug
Switzerland
You may contact us regarding data protection matters and to exercise your rights at: dataprotection@clickbit.cash.
We collect data from you, our clients, business partners, and individuals with whom we have a business relationship. We also collect data from users while operating the Portal.
The processing of data is limited to the data required for the functioning of the Portal and the provision of its content, products and services. We process data based on agreed purposes or legal grounds. The specific data we process about you depends on the reason and purpose of the processing.
The categories of data you provided us directly and the categories of data we receive about you from third parties include, but are not limited to:
As part of our business relationship, it is necessary for you to provide us with information that is necessary for the establishment and performance of the contractual relationship. In general, there is no legal obligation to provide us with this information. However, without this information we may not be able to enter into or continue the contract with you or the entity/person you represent. In addition, certain information, such as an IP address, is required to enable traffic on the website.
The main use of the collected data is to ensure the functionality of the Portal and to conclude and process contracts with you, clients and business partners. We also process data to fulfil our legal obligations, both domestically and internationally.
In addition, in accordance with applicable law and where appropriate, we may process personal data, including that of third parties, for the following purposes, which are considered to be in our legitimate interest or in the legitimate interest of third parties:
Where we asked for your consent, we process your data based on such consent. You may withdraw your consent at any time with effect for the future by providing us written notice (email sufficient). Withdrawal of your consent does not affect the lawfulness of the processing that we have carried out prior to your withdrawal, nor does it affect the processing of your data based on other processing grounds.
Where we did not ask for your consent, we process your data on other legal grounds, such as a contractual obligation, a legal obligation, a vital interest of the data subject or of another natural person, to perform a public task or a legitimate interest, which includes compliance with applicable law, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.
Our Portal use “cookies” to help personalise your online experience. Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). Session cookies are temporary cookies that are used during your visit to the Portal, and they expire when you close the web browser. Persistent cookies are used to remember your preferences within our Portal and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Portal.
Cookies may be set by the Portal (“first-party cookies”), or by third parties, such as those who provide analytics services on the Portal (“third party cookies”). These third parties can recognize you when you visit our Portal and also when you visit certain other websites.
We use the following types of cookies:
However, depending on the purpose of these cookies, we may ask for your express prior consent before they are used. You can access your current settings by clicking on the “Change Your Cookies”-button at our Portal and you can withdraw your consent under the same link at any time. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking.
In order to perform our contracts, fulfil our legal obligations, protect our legitimate interest and the other purposes and legal grounds set out above, we may disclose your data to third parties, in particular to the following categories of recipients:
As we have explained in the Section above, we disclose data to other parties, not all of them located in Switzerland. Your data may be processed in the European Economic Area (EEA) and in exceptional circumstances also in countries outside the EEA and around the world, which includes countries that do not provide the same level of data protection as Switzerland or the EEA and are not recognized as providing an adequate level of data protection. We only transfer data to these countries when it is necessary for the performance of a contract or for the exercise or defence of legal claims, or if such transfer is based on your explicit consent or subject to safeguards that assure the protection of your data, such as the European Commission approved standard contractual clauses (adapted to Switzerland, if applicable).
We only process your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of complying with legal retention requirements and where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. Upon expiry of the applicable retention period we will securely destroy your data in accordance with applicable laws and regulations.
We take appropriate organisational and technical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, we and your personal data can still become victims of cyber-attacks, cybercrime, brute force, hacker attacks and further fraudulent and malicious activity including but not limited to viruses, forgeries, malfunctions and interruptions which is out of our control and responsibility. We have also 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.
You have various rights in relation with our processing of your personal data, depending on the applicable data protection law: right of access, right to rectification, right to erasure, right to restriction, right to data portability, right to withdraw consent, complaints and the right to object.
Please be aware that we reserve the right to enforce statutory restrictions as required, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights would entail expenses for you, we will provide advance notification. We have already mentioned the option to withdraw consent above. It is important to note that exercising these rights could potentially conflict with your contractual obligations and result in consequences such as early contract termination or associated costs. If this situation arises, we will inform you beforehand, unless it has already been agreed upon in the contract.
If you like to exercise the above-mentioned rights, please contact us at dataprotection@clickbit.cash or the contact details provided above unless otherwise specified or agreed. Please note that we need to identify you to prevent misuse, e.g. by means of a copy of your ID card or passport, unless identification is possible otherwise.
Furthermore, every data subject has the option to assert its in a court of law or file a complaint with the appropriate data protection authority. In Switzerland, the relevant data protection authority is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
Due to continuous development of the Portal and the contents thereof, changes in law or regulatory requirements, we might need to change this Policy from time to time at our discretion. When we do, we will revise the updated date at the top of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
presale@clickbit.cash