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GSX Group Privacy Policy

Welcome to the GSX Group PrivacyPolicy.

The Global Blockchain Exchange (“GBX”) incorporated as GBXOÜ, a private limited liability company registered in Estonia under register code 14687762 forms part of the GSX Group. GSX Group respects this Privacy Policyand is committed to protecting your personal data. This Privacy Policy will inform you as to how GSX Group look after your personal data.

1. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how the GSX Group collects and processes your personal data through the use of this website, including any data you may provide through this website when you login, register, contact Us or sign up to Our newsletter.

This website is not intended for minors and We do not knowingly collect any data relating to minors.

It is important that you read this Privacy Policy together with Our Cookies Policy and any other Privacy Policy We may provide on specific occasions when We are collecting or processing personal data about you.

2. CONTROLLER

GSX Group is made up of different legal entities, details of which can be found here:

https://www.gsxgroup.global

This Privacy Policy is issued on behalf of the GSX Group so when We mention ”Company”, “We”, “Us” or “Our” in thisPrivacy Policy, We are referring to the relevant Company in the GSX Group responsible for collecting and processing your data. GSX Group is the controller and responsible for this website.

We have appointed a Data Protection Officer(“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

3. CONTACT DETAILS

If you have any questions about this websitePrivacy Policy or Our privacy practices, please contact Our DPO in the following ways:

Email address:[email protected]

Postal address: Suite 741, Europort, Gibraltar

Complaints:You have the right to make a complaint at any time to the competent supervisory authority.). The contact details of the EU supervisory authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en.

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact Us in the first instance.

4. CHANGES TO THE WEBSITE PRIVACY POLICYAND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.

We keep OurPrivacy Policyunder regular review. This version was last updated on 21 January 2020.

5. THIRD-PARTY LINKS

This Privacy Policyapplies to information collected by GSX Group websites and the websites of Our companies, however, Our websites may contain links to third-party websites, plug-ins and applications.

Please be aware that, by clicking on those links or enabling those connections, it may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave Our website, We encourage you to read the Privacy Policyof every website you visit.

6. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which We have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth, selfie and nationality.
  • Contact Data includes residential address, email address and telephone numbers.
  • Financial Data includes bank account details.
  • Transaction Data includes details about payments to and from you, other details of services you have purchased from Us and payments and trade data conducted on the Company’s platform.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types/versions, operating system/platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, survey responses and feedback.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from Us and Our third parties and your communication preferences.
  • Compliance data includes passport copy, selfie, source of funds, and proof of address (telephone bill/utility bill).

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

However, for compliance checks, We do collect information about criminal convictions and offences.

7. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where We need to collect personal data by law, or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into. In this case, We may have to cancel a product or service you have with Us, but We will notify you if this is the case at the time.

8. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions

You may give Us your identity, contact, financial, compliance data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for Our services;
  • partake in the deposit / withdrawal settlement processes;
  • create an account on Our website;
  • perform a trade(s);
  • subscribe to Our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • send Us feedback or contact Us.

Automated technologies or interactions

As you interact with Our website, We will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using Cookiesand other similar technologies. Please see Our Cookie Policy for further details.

Third parties or publicly available sources

We may also employ the services of third party service providers to help Us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information We will remain responsible for the use of your personal information.  We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that We do.

We may from time to time be required to disclose your personal information to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order.

9. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows Us to. Most commonly, We will use your personal data in the following circumstances:

  • Where We need to perform contractual obligations;
  • where it is necessary for Our legitimate interests (or those of a third party) if your interests and fundamental rights do not override those interests; and
  • where We need to comply with a legal obligation.

Contact Us to find out more about the types of lawful bases that We will rely on to process your personal data.

Generally, We do not rely on consent as a legal basis for processing your personal data, although We will seek your consent before sending any third party or direct marketing communications to you via email or text message.You have the right to withdraw consent to marketing at any time by contacting Us.

10. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

PURPOSE OF PROCESSINGCATEGORY OF DATALAWFUL BASIS FOR PROCESSING
To register you as a new customer(a) Identity (b) Contact (c) CompliancePerformance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Compliance(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions or website Privacy Policy (b) Asking you to leave a review or take a survey(a) Identity (b) Contact (c) Profile (d) Marketing and Communications(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our).
To enable you to partake in a prize draw, competition or complete a survey(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business)
To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity (b) Contact (c) Technical (d) Compliance(a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) TechnicalNecessary for Our legitimate interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy)
To use data analytics to improve Our website, products/services, marketing, customer relationships and experiences(a) Technical (b) UsageNecessary for our legitimate interests (to define types of customers for Our products and services, to keep Our website updated and relevant, to develop Our business and to inform Our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications(a) Necessary for our legitimate interests (to develop Our products/services and grow Our business)
(b) Consent

11. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from Us

You will receive marketing communications from Us if you have requested information from Us or services from Us and you have not opted out of receiving such marketing.

Third-party marketing

We will get your express opt-in consent before We share your personal data with any third party for marketing purposes.

Opting out

You can ask Us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting Us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

12. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy.

13. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which We collect it, unless We reasonably consider that We need to use it for another purpose and that purpose is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.

If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.

Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

14. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal information within the GSX Group (GSX Group will act as controllers, joint controllers or processors and who are based in the UK, Hong Kong and Singapore) in order to provide you with Our services.  Access to your personal information is limited to those employees, agents and contractors of the GSX Group who need access to it in order to provide you with Our services and to carry out legal or regulatory obligations.

We may also employ the services of third party service providers to help Us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information, We will remain responsible for the use of your personal information. We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that We do.

We may from time to time be required to disclose your personal information to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.

We may have to share your personal data with third parties to whom We may choose to sell, transfer or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use your personal data in the same way as set out in this websitePrivacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Our instructions.

15. CROSS-BORDER TRANSFERS OF YOUR PERSONAL INFORMATION

We share your personal data within the GSX Group of companies. This will involve transferring your data outside the European Economic Area (EEA).

Some of Our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever We transfer your personal data out of the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is applied:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where We use certain service providers, We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where We use providers based in the Us, We may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

By providing Us with your personal information, you expressly consent to Our transferring your personal information to countries or jurisdictions which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.

Please contact Us if you want further information on the specific mechanism used by Us when transferring your personal data out of the EEA.

16. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions and they are subject to a duty of confidentiality.

We have 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.

17. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as is reasonably necessary in order that We may fulfil the purposes We collected it for and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you.

To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We apply a general rule of keeping your personal information for as long as is required in order that We may fulfil the purposes for which it was collected.  However, in some circumstances, We may retain personal information for longer periods of time (for instance, where We are required to do so in accordance with legal, tax or accounting obligations).

In specific circumstances, We may also retain your personal information for longer periods of time so that We have an accurate record of your dealings with Us in the event of any complaints or challenges.

We maintain a retention procedure which We apply to records in Our care.  In all cases, where your information is no longer required We will ensure it is disposed of in a secure manner and, where required by applicable law, We will notify you when such information has been disposed of.

In some circumstances, you can ask Us to delete your data.

In some circumstances, We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

18. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:

Data subject access request. This will enable you to receive a copy of the personal data We hold about you and to check that We are lawfully processing it.

Request correction of the personal data that We hold about you. This will enable you to have any incomplete or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new data you provide to Us.

Request deletionof your personal data. This will enable you to request Us to delete or remove personal data where there is no good reason for Us continuing to process it. You also have the right to request Us to delete or remove your personal data where you have successfully exercised your right to object to processing. This may occurin instances where We may have processed your information unlawfully or where We are required to erase your personal data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to request Us to suspend the processing of your personal data in the following scenarios:

  • If you want Us to establish the data’s accuracy.
  • Where Our use of the data is unlawful but you do not want Us to erase it.
  • Where you need Us to hold the data even if We no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with your request in these circumstances.

What We may need from you

We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.

19. GLOSSARY

Lawful basis

Legitimate Interest means the interest of Our business in conducting and managing Our business to enable Us to give you the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for Our legitimate interests. We do not use your personal data for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on you in respect of specific activities by contacting Us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that We are subject to.