NBV International and/or parent company Earn Bits Ltd. (both companies, jointly and severally, shall be referred to as "us", "we" or "Company") respect the privacy of our users (each, "you" or "User") and are committed to protect the privacy of Users who access, visit, use or engage with our website or any other online services we provide (collectively: the "Services").
· What type of information we collect
· How we use the information
· With whom we share the information and for what purpose
· International transfer
· Your privacy rights
· For how long we retain the information
· How we protect your information
· Marketing Minors
· How to contact us
“Personal Information” means information that we directly associate with a specific person or entity, which may include without limitations, name, addresses, telephone numbers, email address, payment information, unique device ID (the “UDID”), device location, IP address, Website usage date, etc.
2. What type of information we collect
We may collect two types of data and information from our Users.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:
· Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. You may register to the Services directly through our website.
· Registering through our website: When you register to the Services through our website, we may collect from you the following information: full name, email address, phone number, full home address (country, state/province, zip code, city, street, house number), gender, date of birth, ID information (issuing country, number, expiry date, etc.), images of identification documents, images of proof-of-residence (utility bills, bank/credit card statements, government-issued letters), images of yourself (selfie photos), information required for our compliance with regulatory Know Your Customer requirements (e.g., contents of KYC Questionnaire and Service Applicant Declaration Form [estimated amount of intended activity, purpose of buying virtual currency, source of the funds used to buy virtual currency, employment status, profession and job title or position, field of activity of employing company or own business, name of employing company or own business, URL to the website of employing company or own business, signature sample, ultimate beneficiary of purchased virtual currency], etc.), as well as any other information you agreed to share with us.
· Voluntarily Provided Information: We may collect information which you provide to us voluntarily. For instance, when you share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.
· Communication Information: We may collect information from your communications with us. For example, when you communicate with us, or respond to communications from us, via email, chat, audio or video calls ("Communications"). We may record and keep all the Communications.
· Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers, as well as other information which relates to your activity through the Services.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
3. How we use the information
· To set up your account and to provide the Services;
· To identify and authenticate your access to certain features of the Services;
· To authenticate your identity for the purpose of compliance with regulatory Know Your Customer requirements;
· To communicate with you and to keep you informed of our latest updates;
· To market our website and the Services;
· To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
· To support and troubleshoot the Services and to respond to your queries;
· To investigate and resolve disputes in connection with your use of the Services;
· To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
4. With whom we share the information and for what purpose
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
5. Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.
6. International transfer
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to Personal Information, including through adequate contractual measures. You hereby consent to the transfer of Personal Information to countries outside the European Union.
7. Your privacy rights
We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we cease any further use of your Personal Information (for example, you may ask that we stop using or sharing your Personal Information with third-parties) or that we remove your Personal Information (subject to any other legal obligation that may require us to keep the information).
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at [email protected].
If you are not satisfied with our response or believe we are collecting or processing your Personal Information in discordance with the laws, you can file a complaint with the applicable data protection authority.
8. For how long we retain the information
We retain the information we collect for as long as needed to provide the Services (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements (unless we are instructed otherwise).
We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.
9. How we protect your information
We take great care implementing and maintaining the security of the Services and your information. We aspire to continuously employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied, or otherwise, that we will manage to prevent such access.
If you feel that your privacy was treated in discordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at [email protected].
Your Personal Information, such as your full name, email address, etc., may be used by us, or by our third-party subcontractors to provide you with promotional materials, concerning our Services.
Out of respect to your right to privacy, within such marketing materials, we provide you with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word "remove" to [email protected].
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
11. Corporate transaction
The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not use the Services or provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that an individual under the age of 18 has shared any of their information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].