PRIVACY POLICY
Last updated: 31 Oct 2018

Bitginko (“we”, “us” and “our”) respect and protect the privacy of visitors to our websites and our customers who use our services. To ensure transparency, this Privacy Policy describes our information handling practices when you access content we own or operate on the websites located at bitginko.com, or any other websites, pages, features, or content weown or operate and/or when you use other related services (referred tocollectively hereinafter as "Services").

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Notice, please contact usat support@bitginko.com.

ACCEPTANCE OF PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure ofyour personal information as described further below. Bitginko may provide additional "just-in-time" disclosures or additional information about the data collection, useand sharing practices of specific Services. These notices may supplement orclarify SK’s privacy practices or may provide you with additional choices about how Bitginko processes your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy.

OUR RELATIONSHIP TO YOU

Bitginko is a private limited company incorporated in Hong Kong.

As data controllers, we determine the means and purposes of processing data. If you have any questions about your Bitginko Account, your personal information or this Privacy Policy, please direct your questions to support@bitginko.com.

THE PERSONAL INFORMATION WE COLLECT

Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you.

You may be asked to provide personal information anytime you are in contact with any Bitginko companies. The Bitginko companies may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services,and content.

Except as described in this Privacy Policy, Bitginko will not give, sell, rent or loan any personal Information to any third party.

PERSONAL INFORMATION COLLECTED

We collect personal information to provide you with our Services. When were quire certain personal information from users it is because we are required bylaw to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.

For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for a Bitginko event. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Policy.

We collect the following types of information:

  • Personal Identification Information: Full name, date of birth, age,nationality, gender, signature, utility bills, photographs, phone number, homeaddress, and/or email.
  • Formal Identification Information:Tax ID number, passport number,driver’s license details, national identity card details, photograph identification cards, and/or visa information.
  • Financial Information:Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
  • Transaction Information:Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Employment Information:Office location, job title, and/or description of role.
  • Online Identifiers:Geo location/tracking details, browser finger print, OS, browser name and version, and/or personal IP addresses.
  • Usage Data:Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, userID, click-stream data and other data collected via cookies and similar technologies.

For institutional Customer, the information we collect, verify, and authenticate includes but not limited to:

  • Institution legal name.
  • Employer Identification Number or any comparable identification number issued by a government.
  • Full legal name of controlling person.
  • Email address of controlling person.
  • Mobile phone number of controlling person.
  • Address (principal place of business and/or other physical location).
  • Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument, or other comparable legal documents as applicable).
  • Contract information of owners, principals, and executive management (as applicable).
  • Proof of identity (e.g., driver’s license, passport or government-issued ID) for of controlling person or individual beneficial owner that owns 25% or more of the institutional customer entity.
HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with asecure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

To maintain legal and regulatory compliance: Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, Bitginko must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we may use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records or we do it internally. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements. EEA Residents: For individuals who reside in the European Economic Area(including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) orany equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.
To enforce our terms in our user agreement and other agreements: SK handles very sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our terms.
To provide SK’s Services: We process your personal information in order to provide the Services to you.
To provide Service communications: We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues orupdates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
To provide customer service: We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to trouble shoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
To ensure network and information security: We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations.The threat landscape on the internet is constantly evolving, which makes itmore important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legal obligations.
For research and development purposes: We process your personal information to better understand the way you use and interact with SK’s Services. In addition, we use such information to customize, measure, and improve SK’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest. EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To enhance your website experience: We process your personal information to provide a personalized experience, and implement the preferences you request. EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To facilitate corporate acquisitions, mergers, or transactions: We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes. EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.
To engage in marketing activities: Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage ofour Services and your contact information to provide marketing communications. You can opt-out of our marketing communications at anytime. EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy on your consent.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Bitginko Services may not be available to you.

WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. Bitginko will never sell or rent your personal information. We will only share your information in the following circumstances:


  • We share your information with third party identity verification services inorder to prevent fraud. This allows Bitginko to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
  • We may share your information with service providers under contract whohelp with parts of our business operations such as bill collection, marketing,and technology services. Our contracts require these service providers toonly use your information in connection with the services they perform for us,and prohibit them from selling your information to anyone else.
  • We share your information with financial institutions with which we partner to process payments you have authorized.
  • We may share your information with companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
  • We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, orsimilar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss.

If you establish a Bitginko Account indirectly on a third party website or via a third party application, any information that you enter on that website or application(and not directly on a Bitginko website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is, which is why Bitginko maintains (and requires its service providers to maintain) appropriate physical, technical andadministrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in Hong Kong and else where in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, oralteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address listed at the end of this Privacy Policy.

SPECIFIC CONSENT BY USERS IN SINGAPORE

If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in Hong Kong, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.

Hong Kong may not have protections in place for personal data as extensive as those within Singapore. However, we require our service providers to treat your personal information in strict confidence and use appropriate security measures to protect it. We also require them to uphold all of our other obligations under this Privacy Policy.

You may revoke your consent to this section at any time by emailing support@bitginko.com with the subject line "revoke Singapore data consent".

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.

If you close your Bitginko Account, we will mark your account in our database as "Closed," but will keep your account information in our database for a period of time described above. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

RIGHTS IN RELATION TO THE USE OF YOUR PERSONAL INFORMATION

Rights of access, correction and deletion

You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

Right to object

You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing ofsome or all of your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact us as set out below.

RETENTION OF PERSONAL INFORMATION

We store your personal information securely throughout the life of your Bitginko Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.


  • Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression listin definitely.
  • Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
  • Recording of our telephone calls with you may be kept for a period of up to six years.
  • Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
CHILDREN'S PERSONAL INFORMATION

We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Bitginko will require the user to close his or her account. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us at support@bitginko.com, or by writing to us at:

Bitginko