C-Patex Privacy Notice
- 1. Why Do You Need this Privacy Notice?
- 2. Where Can You Find the Definitions?
- 3. Who Are We and How to Reach Us?
- 4. What Personal Data Do We Collect?
- 5. How Do We Use Personal Data?
- 6. How Long Do We Process Your Data?
- 7. How Do We Share Your Data?
- 8. Do We Transfer Your Personal Data to Third Countries?
- 9. What Are the Features of Blockchain Data Processing?
- 10. Are You Subject to Automated Decision-Making?
- 11. What About Interacting with Third-Party Links?
- 12. What About Securing Your Personal Data?
- 13. What Data Subject Rights Do You Have?
- 14. Do We Process Children’s Personal Data?
- 15. Can We Modify and Update this Privacy Notice?
1. Why Do You Need this Privacy Notice?
We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with your access to and use of the Services. In this Privacy Notice, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual. In this Privacy Notice we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.
2. Where Can You Find the Definitions?
Unless otherwise provided in this Privacy Notice, capitalized terms used in this Privacy Notice have the meaning determined in the (the
Terms). We encourage you to read the Terms carefully as they affect your obligations and legal rights.
3. Who Are We and How to Reach Us?
When we say
our, we mean UAB «C-Patex», a company, established under the laws of Lithuania, having registered address at Žalgirio g. 88-101, Vilnius, Lithuania, and DLT Swap Technologies Ltd, a company, established under the laws of Seychelles, having registered address at House of Francis, Room 303, Ile Du Port, Mahe, Seychelles.
We process your personal data in accordance with this Privacy Notice and we endeavor to comply with the applicable data protection legislation.
If you have any questions regarding this Privacy Notice or the processing of your personal data, do not hesitate to contact us via the following contact details:
4. What Personal Data Do We Collect?
The categories of personal data we collect depend on how you interact with us, use the Services, and the requirements of the applicable laws. We collect and process the following types of personal data as outlined below. Please note that we may also collect certain other information, which may be required under the applicable laws.
5. How Do We Use Personal Data?
|Category of Data||Description||Lawful Basis for Processing|
|Account Data||To create and register a User Account in order to access and use certain Services.||To take steps at your request prior to entering into a contract, and, further, to perform a contract with you.|
|If you act on behalf of a legal entity 一 our legitimate interest to ensure the access and use of the Services by the legal entity you represent.|
|Verification Data||To identify you as an individual and verify your identity.||Our legitimate interest to prevent money laundering, financing of terrorism, or other illegal activities in relation to the Services, and to comply with the applicable sanctions, administered or enforced by any country, government or international authority, including the EU, OFAC, United Nations Security Council, but not limited to the above.|
|To enable you to use certain functionality of the Services, such as Withdrawal.|
|Payment Data||To carry out certain Transactions, arising out and in connection with your use of the Services.||To perform a contract with you.|
|Our legal obligation to keep and retain the financial records to comply with the applicable laws.|
|Our legitimate interest as well as the interests of other Users to prevent and detect fraud and abuse, and protect the security of our Users.|
|Application Data||To enable you to apply for the listing on the Exchange.||Our legitimate interest to ensure the access and use of the Services by a project you represent.|
|Technical Data||To ensure the operation of the Services.||To perform a contract with you.|
|To ensure the security of your User Account, for instance by identifying suspicious activities.|
|To provide a better user experience by improving functionality, usability, user flow and interface of the Services.||Our legitimate interest to ensure the security of your User Account, improve the Services functionality and user experience, detect fraud and respond to requests from authorities.|
|Analytical, Statistical, and Marketing Data||Google Products: After collecting the personal data, Google creates reports about the use of the Services, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other users. We use the reports to collect statistics with respect to the use of the Services and to improve the Services (user flow, interface, etc).||Your consent.|
Meta Pixel: We use the Meta Pixel for the following purposes:
(a) Meta Custom Audiences. We use the Meta Pixel for the remarketing purposes to be able to contact you again within 180 days. This allows us to display interest-based advertisements (Meta Ads) to the Platform visitors when they visit Meta products or other third-party websites also using the Meta Pixel tool. In this way, we pursue the interest in displaying advertisements that are of your interest in order to promote us and make the Platform or its content more interesting for you.
(b) Meta conversion. We also use the Meta Pixel to ensure that our Meta Ads match the potential interest of users and are not irritating. With the Meta Pixel, we can track the effectiveness of the Meta Ads. This is necessary for statistical and market research purposes by seeing whether users were redirected to the Platform after clicking on the Meta Ads.
|Referral Data|| |
To enable you to participate in our referral program.
|To perform a contract with you.|
To count you as a User, who shares a referral link and invites others to use the Services.
To accrue the relevant referral remuneration to you, if any.
|To count the invited user.||Our legitimate interest to ensure the participation in our referral program by the respective User, who invited you to use the Services.|
|Contact Data||To respond to your inquiry.||Our legitimate interest to respond to your inquiry and to respond to requests from government authorities.|
|Subscription Data||To provide you with marketing and newsletter emails concerning the Services, our projects, as well as general updates.|| |
Your consent. This notwithstanding, we may provide current Users, that are not subscribers, with marketing and newsletter emails due to our legitimate interest to notify them about updates, available functionality, and/or opportunities regarding the Services as well as to enable the Users to take advantage of them.
You may revoke your consent and/or unsubscribe from receiving marketing and newsletter emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing and newsletter email.
In such a case, we will delete your email address from the respective marketing database.
Please note that administrative or service-related communications (security alerts, email verifications, maintenance notifications, etc.) are not considered marketing and such communications may not offer an option to unsubscribe.
6. How Long Do We Process Your Data?
As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:
- to meet our legal obligations under the applicable law;
- in relation to anticipated or pending legal proceedings; or
- to protect our rights and legitimate interests or those of third parties.
7. How Do We Share Your Data?
General. We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, applicable legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary:
- to provide you with access to the Services and performance of our undertakings with you;
- for compliance with the applicable laws and regulations; or
- for our legitimate interest to maintain, improve and develop the Services, detect fraud or breach of law.
Please note that if we share any portion of your personal data with third persons, we will endeavor to secure such transfer using appropriate legal, organizational, and technical measures.
Recipients. Given the purposes outlined above, your personal information is shared with the following categories of recipients:
- support and technical teams;
- verification service providers;
- email delivery service providers;
- hosting service providers;
- payment processors and payment service providers;
- government authorities, upon their request or if necessary to comply with our legal obligations;
- another entity if we sell or otherwise transfer the Services or their part; and
- other third-party solutions, which may be from time to time integrated in relation to the Services.
8. Do We Transfer Your Personal Data to Third Countries?
Sometimes we may transfer your personal data to countries that may not offer the same level of data protection as the laws of your country. In this case, we will endeavor to put in place suitable safeguards and take reasonable steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Notice and provided for in the applicable legislation. This paragraph does not apply to the transfer of the data on or through a blockchain, since such data is publicly available. Please consider the “What Are the Features of Blockchain Data Processing?” section of this Privacy Notice below.
9. What Are the Features of Blockchain Data Processing?
Please note that Addresses, Wallet addresses, and information about Transactions associated therewith interact with public decentralized blockchain infrastructures and blockchain-based software, including smart-contracts, that work autonomously. When we say that a blockchain is decentralized we mean that there is no single person, including us, who controls the blockchain or stores data available thereon, and when we say “public” we mean that the access is available for anyone and cannot be restricted. The data entered in a public decentralized blockchain is distributed via the nodes that simultaneously store all records entered into the blockchain.
By design, blockchain records cannot be changed or deleted and are said to be “immutable”. Please be aware that any Transaction within a blockchain is irreversible and information entered into a blockchain cannot be deleted or changed. Therefore, your ability to exercise certain data protection rights or abilities may be limited.
In addition, due to the blockchain’s nature, the information that was entered in a blockchain will be publicly available and we will neither control such information nor manage access to it. Once you start carrying out Transactions, certain data, which may be considered personal, will become publicly available on a blockchain. The ultimate decision whether to transact on a blockchain or carry out any Transactions rests with you.
10. Are You Subject to Automated Decision-Making?
Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. It is mandatory for you to provide the Verification Data in order to be eligible and authorized to access and use certain functionality of the Services. When you provide us with your Verification Data, the verification systems will process it automatically and report to us whether you are eligible to use certain functionality of the Services. If the verification systems notify us that you are not eligible to use certain functionality of the Services, you will be automatically refused from using the respective Services functionality.
In addition, we may also automatically block Users based on their geographical location. This is necessary to restrict access to the Services for the Users from prohibited jurisdictions (meaning the jurisdictions in which the use of the Services or its functionality is prohibited by applicable laws or regulations, the Terms, or our rules and policies).
If you do not agree with the outcomes of automatic decisions, you may: (a) request us to manually review the respective information and provide you with the outcomes of the review and/or (b) express your point of view and provide additional information or documents in order to contest the decision.
11. What About Interacting with Third-Party Links?
12. What About Securing Your Personal Data?
We strive to do our best to keep your personal data secure. We always review and update appropriate technical and organizational measures to (i) keep your personal data secure in accordance with the applicable legislation, our internal policies and procedures regarding the storage of, access to, and disclosure of personal data; and (ii) protect you against unauthorized or unlawful processing of personal data and accidental loss or destruction of, or damage to them. We endeavor to implement and maintain technical and organizational measures, which are appropriate to the harm that might result from the unauthorized or unlawful processing or accidental loss, destruction, or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures. Your personal information may undergo anonymisation, pseudonymisation, and/or encryption to ensure safe transfer and/or processing.
13. What Data Subject Rights Do You Have?
General. According to the applicable legislation, you may have the rights outlined below. In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.
Blockchain Data Processing. Please note that when you interact with a blockchain, we may not be able to exercise certain rights that you may have pursuant to the applicable legislation with respect to the Addresses, Wallet addresses and information about Transactions associated therewith. For instance, we may not be able to ensure that such personal data is deleted, corrected, or restricted. You may learn more above in the “What Are the Features of Blockchain Data Processing?” section of this Privacy Notice.
How to Exercise Your Rights. To exercise your rights as outlined in this Section, you must contact us at email@example.com Please note that requests sent to other contact details may not be processed.
Data Subject Rights. According to the applicable legislation, you may have the following rights:
|Right to access your personal data||This enables you to ask us whether we process your personal data. If we process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you, and check that we are lawfully processing it.|
|Right to rectification of the personal data||This enables you to have any incomplete or inaccurate data we hold about you completed or rectified, though we may need to verify the accuracy of the new data you provide to us.|
|Right to erasure of your personal data (commonly known as a “right to be forgotten”)|| |
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), 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 or technical reasons which will be notified to you, if applicable, at the time of your request.
|Right to object to processing of your personal data||This enables you to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts 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.|
|Right to restrict the processing of your personal data||This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) 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, (iv) 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 (commonly known as a “right to the data portability”)||We will provide to you, or 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|
|Right to withdraw consent||You may withdraw your consent at any time where we are relying on consent to process your personal data.|
|Right not to be subject to automated decision-making||If and to the extent applicable, you reserve the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you.|
|Right to file a complaint||You may file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable legislation. The relevant supervisory authority will particularly depend on where you are located.|
14. Do We Process Children’s Personal Data?
The Services are not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children.
If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.
15. Can We Modify and Update this Privacy Notice?
We keep our Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice regularly to check for the updates. If we make substantial changes to the way we treat your personal information, we will either (i) display a notice on the Platform, or (ii) notify you by email prior to the change becoming effective.