1.1 Payzet Oy ("we") are committed to safeguarding the privacy of our data-subjects ("you" or "user); in this policy we explain how your personal data, meaning any information relating to you as an identified or identifiable natural person, that we may hold about you, is collected, used, stored, disclosed, and removed (each and all referred to as "processing").
1.2. We do not collect any personally identifiable information from children under the age of 16. If you believe that a child under the age 16 has provided us with personally identifiable information, please contact our customer support.
1.3. This Policy only applies to information we process. It does not apply to the practices of companies that we don't own or control, or employees that we don't manage. Information on our services’ may contain links to third party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites' responsibility to protect any information you give them, so we can't be held liable for their wrongful use of your personally identifying information.
1.4. We may update this policy from time to time and will notify you of changes to this policy affecting your rights by email and/or by posting on our website at Payzet.com.
2. Your Personal Data and How We Use It
2.1. In this Section 2 we set out:
- the general categories of data and types of personal data that we may process;
- the source of that personal data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
2.2. We may process your registration data ("registration data"). Registration data may include your username and email address. The source of the registration data is you. Registration data is required in order for you to be able to use the service. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract;
2.3. We may process your account data (account data"). Account data may include your full name, email address, username, country and telephone number. The source of the account data is you. The account data may be processed for the purposes of providing our services, ensuring the security of our users and services, and communicating with you. Users may need to set their full name to their user profile before buying Cryptocurrency online from some traders. Full name is only shown to Cryptocurrency sellers with whom user has opened trades. Verifying the full name helps protecting users against fraudulent payments, increase user’s trustworthiness, and provides an alternative way to access user’s Payzet wallet in case the password is lost or the account is hacked. Phone number is used for notification purposes and is an alternative mechanism to identify users in case the password is lost or account gets hacked. The legal bases for this processing are consent; the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; and our legitimate interests, namely the operation of our business model.
2.4. We may process your identity documents ("ID data"). Verifying account with an ID is currently mandatory to all advertisers and users whose trading volume exceeds certain limit. ID may contain your full name, country, date of birth, social security number and gender. The purpose for ID data is to protect our users from fraud and helps us to prevent, detect and investigate fraud, money laundering, criminal activity or other misuse of our service. Moreover, by requiring all advertisers to ID verify will help us to provide a more trustworthy, safe and reliable trading experience for our customers. ID creates a strong assumption about the ownership of the account and thus ensures that we can return access to your account in case your account is hacked. Legal bases for this processing are consent and legitimate interests of ours and/or by third-parties, namely to prevent, detect and investigate fraud, criminal activity or other misuse of the services and to prevent security issues.
2.5. We may process data about your use of our website and services ("usage data"). Usage data is primarily non-personally-identifying information of the sort that web browsers, servers, and services like Google Analytics typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other non-identifying information that we might have access to includes how you use the service (e.g. search queries), your approximate location, cookies set by our site, etc. Usage data may include: 1) Data that we collect mainly for behaviour statistics, business intelligence and email campaigns ("analytics data"). We gather website traffic data with the help of Google Analytics. We gather event based tracking data with the help of Mixpanel, and this data may also contain your email address, IP address and country code. 2) Data that we collect mainly for technical, security and/or fraud prevention reasons or for tracking errors ("technical data"). We gather data on website errors with the help of Sentry which may occasionally contain usage data. We also log certain events from your actions on our site. The legal basis for this processing is our legitimate interests of ours and/or by third-parties, namely to monitor service quality and improve our website and services as well as to prevent, detect and investigate fraud, criminal activity or other misuse of the services and to prevent security issues.
2.6. We may process data relating to your trades that you conduct through our website ("trade data"). The trade data may include trade ID, initiated trades, payment method, advertisement information, buyer username, seller username, trade value (in fiat), trade value (in Cryptocurrency), Cryptocurrency price, currency, timestamps of trade and trade chats as well as possible merchant invoice information and ATM trade data. The source of the trade data is you and your trading partner. The legal bases for this processing are consent; the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the operation of our business model.
2.7. We may process data relating to Cryptocurrency transactions in and out of your bitcoin wallet ("bitcoin transaction data"). Information stored on received transactions may include timestamp, Cryptocurrency amount, deposit address (unique) and transaction ID and other publicly available data from the bitcoin blockchain. Withdrawal transactions may include data such as timestamp, bitcoin amount, sent address, transaction ID, and description. The source of the trade data is you and/or your trading partner. The legal bases for this processing are consent; the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the operation of our business model.
2.8. We may process information contained in or relating to any communication that you send to us or what you generate through the use of our service ("communication data"). Communication data includes 1) all your messages, requests and other communication with our customer support which may happen during the dispute review process or via support tickets, emails, or by means of any other communication tool; and 2) all your communication and file attachments that you generate when conducting trades with other users ("trade chat messages") or other data that you generated mainly by communicating to other users. Communication data may include, email address, username, IP address, full name, audio and video files and in the case of manual ID verification: photo of the user’s personal ID, photo of the user, and photo of the user’s utility bill or related document. The communication data may be processed for the purposes of communicating with you, record-keeping, in order to review and resolve disputes, serve our customers better and improve our service. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.9. We may process information that you provide to us for the purpose of subscribing to our email notifications, SMS notifications and/or newsletters ("notification data"). The notification data may include your email address, phone number, username and full name. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. You can unsubscribe at any point by contacting us or by clicking the unsubscribe link in the email.
2.10. In connection with the activities described above, we may conduct profiling based on your interactions with and content that you provide to our service, and/or information obtained from external services (described in Section 4). In limited cases, automated processes may restrict or suspend access to our service if such processes detect activity that we think poses a safety or other risk to our service, our users or third parties. We process this information given our legitimate interests in protecting our service and brand; preventing, detecting and investigating fraud, criminal activity or other misuse of the services; optimizing the products and services offered and/or complying with applicable laws.
2.11. We may process any of your personal data when necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or outside the court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.13. All the aforementioned general categories of data may contain data that by itself does not identify you and is therefore not deemed as personal data.
2.14. Please try to avoid supplying any unnecessary personal data to us.
3. Information You Choose to Display Publicly on Our Services
4. Providing Your Personal Data to Others
5. International Transfers of Your Personal Data
6. Retaining and Deleting Personal Data
7. Your Rights
7.1. In this Section 7, we have summarised the principal rights that you have under data protection law. Some of the rights are complex, might contain restrictions depending on the legal basis for processing the data and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2. Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to object to processing;
(e) the right to data portability;
(f) the right to complain to a supervisory authority;
(g) the right to withdraw consent.
7.3. Without prejudice to the aforementioned, if we have reasonable doubts concerning the identity of a user exercising his/her rights referred to in Section 7.2 or if we otherwise due to security reasons deem it necessary, we may request the provision of additional information and otherwise use all reasonable measures necessary to confirm the identity of the user.
7.4. You may exercise any of your rights in relation to your personal data by contacting our customer support. Concerning "Right to erasure" users are also able to request the deletion of their account through our site.
(a) What are cookies
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
For more general information on cookies see the Wikipedia article on HTTP Cookies.
(b) Cookies that we use
(c) Cookies used by our service providers
(d) Managing cookies
9. How to Contact Us
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