Company — AML Corporation Limited, сompany number 13020363, registered address 21 Ellis Street, London, London, United Kingdom, SW1X 9AL;
Personal data — any information relating to the User, which identifies or may identify the User;
Platforms — collective name that can refer to either or both the Mobile and Website Platforms;
Mobile platform — an application that is distributed by the Company through AppStore or Google Play;
1.2. The Personal data is processed according to the General Data Protection Regulation (Regulation EU 2016/679, “the GDPR”), the Data Protection Act 2018 and any other relevant legislation in respect of accepted principles of good information handling (jointly the “data protection legislation”).
1.5. We are registered with the Office of the Information Commissioner in the UK (ico.org.uk/register) as Data Protection Officer under number ZA890493.
2. INFORMATION WE COLLECT
2.1. When you engage with us, we collect and process your Personal data. The types of information we receive and collect depends on how you use our Platforms. This Personal data can be categorized as follows:
2.1.1. Biographical data, such as: name, e-mail address, phone number, country, full address, date of birth.
2.1.2. Your account activity, such as: trade activity; affiliate names, ID, links, transactions; transaction history; offer terms; offers created; account status and notifications.
2.1.3. Your account details, such as: user name, user profile information, joined date, default currency, default language, time zone.
2.1.4. Data relating to your digital asset wallet, such as: public keys, wallet balance, transactions received/sent.
2.1.5. Data collected in connection with “Know Your Customer” (KYC) compliance, “Anti-Money Laundering” (AML) compliance and “Counter-Terrorist Financing” (CTF) compliance.
2.1.6. Device and website usage data, such as: IP addresses; language preferences and other device identifiers; information relating to your access to the Platforms, such as device characteristics, date and time.
3. HOW DO WE GET YOUR PERSONAL DATA?
3.1. We collect Personal data directly from you when you use our Platforms or services, communicate with us, or interact directly with us. For example, when you complete the contact form on our Platforms or when you contact us via email.
3.3. We also may collect information about you from third-party sources, including but not limited to, the following channels:
3.3.1.marketing partners and resellers;
3.3.2. advertising partners and analytics providers;
3.3.3. public databases, credit bureaus and ID verification partners;
3.3.4. social networks (for example, Twitter).
3.4. We protect the data obtained from third parties according to the practices described in this policy and we also apply additional restrictions imposed by the source of data.
4. THE PURPOSES OF USING THE PERSONAL DATA
4.1. In the following, we explain purposes of collecting Personal data and the legal basis for such actions:
4.1.1. to enable you to use our Platforms, to create an account or profile, to process information you provide via our Platforms (including verifying that your email address is active and valid) in accordance with Article 6(1)(a) GDPR;
4.1.2. to detect and prevent potentially prohibited or illegal activity relating to the Company’s services in accordance with Article 6(1)(b),(c) and (f) GDPR;
4.1.3. to tailor content, recommendations, and advertisements we and third parties display to you, both on the Platforms and elsewhere online in accordance with Article 6(1)(a) GDPR;
4.1.4. to contact you in response to your inquiries, comments and suggestions in accordance with Article 6(1)(b) GDPR;
4.1.5. with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third-party partners in accordance with Article 6(1)(a) GDPR;
4.1.7. for internal business purposes, such as to improve our Platforms in accordance with Article 6(1)(b) GDPR;
4.1.8. to issue invoices and collect fees in accordance with Article 6(f), (b) GDPR;
4.1.9. to comply with our policies and obligations, including, but not limited to, disclosures and responses in response to any requests from law enforcement authorities and/or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order in accordance with Article 6(1)(c),(b) GDPR.
4.2. Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the purpose of delivering the requested services and improving our services.
5. PROVIDING YOUR PERSONAL DATA TO OTHERS
5.2. For behaviour statistics and business intelligence we use the service by Google LLC (“Google Analytics”), a company located in the United States. Data that we may provide to Google Analytics may include your IP address and that data is used by Google Analytics to generate information about your usage of our service.
5.6. We may share your personal data with the following third parties:
5.3.1. third-party vendors carrying out services on our behalf, including advertising, analytics, research, customer service, service support, data storage, validation, security, fraud prevention, and legal services. Such third-party vendors have access to perform these services but are prohibited from using your personal data for other purposes;
5.3.2. external services or authorities when such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests and/or the vital interests of a third-party;
5.3.3. other third parties subject to your consent.
5.4. When we disclose your Personal data to a third party, we take all reasonable steps to ensure that those third parties are bound by confidentiality and privacy obligations with respect to the protection of your Personal data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant third parties, to ensure that Personal data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.
6. STORAGE AND DELETION OF PERSONAL DATA
6.1. Company will retain your Personal information for as long as we deem it necessary to enable you to use the Platforms and to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business.
6.3. The legal basis for retaining is Company’s legitimate interest under GDPR Article 6(1)(f) to protect our rights in the light of potential legal disputes during the limitation period under law.
6.4. Notwithstanding the other provisions of this Section 6, we may retain your Personal data where such retention is necessary for compliance with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person in accordance with GDPR Article 6(1)(c).
6.5. When the Company no longer needs to keep your Personal data, it will securely delete or destroy it.
7. PROTECTION OF PERSONAL DATA
7.1. Your Personal data integrity is of high concern to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. We have therefore implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to, such information, reasonably appropriate to the nature of the data concerned; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure.
7.2. We implemented a number of security measures to ensure that your information is not lost, abused, or altered, including, but not limited to:
7.2.1. Physical measures, which means that materials containing your Personal information will be stored in a locked place.
7.2.2. Electronic measures, which means that computer data containing your Personal information will be stored in the computer systems and storage media that are subject to strict log-in restrictions.
7.2.3. Management measures, which means that only authorized employees are permitted to come into contact with your Personal information and such employees must comply with our internal confidentiality rules for Personal data. We have also imposed strict physical access controls to buildings and files.
7.2.4. Technical measures.
7.3. If you suspect that your Personal information has been compromised, especially account and/or password information, please lock your account and immediately contact our Customer Support team at firstname.lastname@example.org.
8. USER’S RIGHTS
8.1. Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information:
8.1.1. the right to confirmation as to whether or not we process your Personal data and, where we do, to access the Personal data. Providing that the rights and freedoms of others are not affected, we will supply to you a copy of your Personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can view and export your Personal data under your account settings page;
8.1.2. the right to object to us processing your Personal data, citing personal reasons; however, understand that we may still process your Personal data if we have lawful grounds to do so, but only if our interests in processing your Personal data are not overridden by your rights, interests, or freedoms;
8.1.3. the right to have any inaccurate Personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal data about you completed;
8.1.4. the right to obtain and reuse your Personal data for your own purposes across different services. It allows you to move, copy or transfer Personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability;
8.1.5. the right to the erasure of your Personal data. We have described our policy for retaining and deleting Personal data above in Section 6;
8.1.6. the right to withdraw consent. To the extent that the legal basis for our processing of your Personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.2. You may exercise any of your rights in relation to your Personal data by contacting our Customer Support. You must note that prior to accessing and making changes to your Рersonal data, we will need to verify your identity properly.
8.3. If you believe that your rights have been infringed, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (the Information Commissioner’s Office via link https://ico.org.uk/global/contact-us/).
9. INTERNATIONAL TRANSFER OF PERSONAL DATA
9.1. We may need to transfer your Рersonal information to countries which are located outside the European Economic Area (“EEA”), for the purpose of providing the services to you. You may be located in a country outside of the EEA and therefore we may have no choice but to transfer your personal information outside of the EEA. Rest assured that any transfer of your personal information outside of the EEA will be subject to a GDPR-compliant guarantee (such a Model Contract Clause approved by the European Commission) that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
10. COOKIES POLICY
10.2. A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the websites again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. We use both types of cookies:
10.2.1. session cookies will only stay on your device until you stop browsing;
10.2.2. persistent cookies stay on your computer or mobile device until they expire or are deleted.
10.3. We use the following types of cookies on our Platforms:
10.3.1. Strictly necessary cookies. These cookies are essential for you to browse our Platforms and use its features. Without these cookies, some online services cannot be provided.
10.3.2. Performance cookies. These cookies collect information about how you use our Platforms. This data may be used to help optimize our Platforms and make it easier for you to navigate.
10.3.3. Functional cookies. These cookies allow our Platforms to remember choices you make while browsing and personalize your experience.
10.3.4. Third-party cookies. Third-party cookies are those placed by websites and/or parties other than our. These cookies may be used on our Platforms to improve our services or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies for these external services, for example, https://twitter.com/en/privacy.
10.3.5. Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our Platforms, what pages they find most useful, and how they arrived at https://amlbot.com/ or https://amlsafe.io/.
10.4. Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impair your overall user experience, as it will no longer be personalized to you.
10.5. In addition to cookies, we sometimes use small graphics images known as pixels (also known as web beacons, clear GIFs, or pixel tags). We use pixels in our email communications to you (if you have selected to receive such communications) to help us to understand whether our email communication has been viewed. We also use third-party pixels (such as those from Google, YouTube, and other networks) to help us provide advertising that is relevant to your interests.