Unless otherwise defined herein, all capitalized terms defined in the Terms of Service shall have the same meaning herein.
DATA WE COLLECT
1. We respect the privacy of our Applicants, and We are committed to protect the Personal Data that they share with Us. Note that those aspects of this Policy which are mandated by the EU General Data Protection Regulation (“GDPR”), any rights (such as data subject rights detailed below) and duties conferred by GDPR, will apply only to the extent that GDPR applies. In this context, We are the “data processor” of Personal Data on behalf of our Applicant’s, the “data controllers”, as these terms are defined under the GDPR.
2. In order to use our Services, you must first complete and submit a “case creation” form by completing the required information. By completing this form, you are requested to disclose personal information in order to enable the Company to provide the Services.
3. We collect the following categories of personal data. Such data is typically collected and generated through your interaction with our Services, through automatic means, directly from you or through third parties (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):
3.1. Information We collect from you- The Applicant Account details and the Applicant’s Information. Including:(a) full name; (b) verification information (such as passport number, driver’s licence number or Government-issued identity card number); (c) residential address and contact details (e.g., email address, telephone number etc); and (d) password, when applicable; and (e) Financial account information and/or credit card details, including information about your source of funds, assets and liabilities, trading account balances and trading activity or access to view these details from your account provider.
3.2. Information We collect about you “automatically”- When you use our Platform We may collect, record, or generate technical data about you. We may collect information from you through automatic tracking systems on your device or API or other web and mobile analysis software. We may also receive specific usage data, such as your IP address and referral source. We may use this information for providing the Services and/or for our legitimate business interests. for example: (a) Financial account information and credit card details, including details about your source of funds, assets and liabilities, Trading account balances, trading activity; and (b) Browser Information – Information that is automatically collected via analytics systems providers from your browser, including your IP address and/or domain name and any external page that referred you to Us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform; and (c) Direct interactions and communications with us – including recordings and transcripts of your calls, chats and emails with us.
3.3. Information We receive about you from other sources- We may receive information about you from third parties such as through publicly available sources. For example:
OFAC information and Media publications.
4. We collect and process your Personal Data in order to provide our Services (so as to perform our contractual obligations). The use of your personal data is necessary for Us to verify your crypto assets related financial activity and to analyse its AML/CFT related risks.
5. During the time when We perform the Services, We may collect, receive, process, and transfer any information, including your Personal Data and other details submitted, shared, or exchanged in connection with the Platform. By applying to our Services, you consent to Us collecting, receiving, processing, and transferring your personal information for the following purposes: (a) providing the Services; (b) enhance the performance of our Platform and/or Services; (c) to comply with our legal and contractual obligations; (d) protecting and securing you and ourselves.
6. If you wish to revoke such consent, please contact Us by email at [email protected].
7. We may store and retain data outside of Israel as long as necessary, following our reasonable business needs and under legal obligations.
8. When We provide Services for and/or on behalf of the Financial Institution, We will delete the Personal Data in the following scenarios:
8.1. When We have collected and analyzed the data and provided a report to the Financial Institution.
8.2. When the Applicant will not finalize the request process within four (4) weeks from the initiating the request for a report from the Company.
8.3. In cases where the Applicant will specifically ask Us to do so, as long as he does so prior to the submission of a report by Us to the Financial Institution.
9. When We provide the Services to the User (as defined in the End-User License Agreement), We will retain the Personal Data for up to seven (7) years from the conclusion of the Services to the User.
10. Your Personal Data will be kept according to the above mentioned and will be stored in the company’s database subject to the provisions of the Privacy Protection Law, 1981-1981. Please note that except as required by applicable law or our specific agreements with you, We will not be obligated to retain your Personal Data for any period, and We are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you.
11. If you have any questions about our data retention policy, please contact Us by e-mail at [email protected].
12. The Company will not disclose your Personal Data to a third party, except in the following events: (a) to the extent that We are legally compelled to do so; (b) if We believe in good faith that our legitimate business interests require disclosure and may protect the rights, property, or personal safety of FRNZX; (c) according to our Terms of Service; (d) at your request or with your consent or to those described in this Policy.
14. You can enable or disable cookies in your internet browser or delete them. However, if you choose to delete them, you may lose any information that allows you to access our Platform more quickly and efficiently.
HOW WE PROTECT YOUR INFORMATION
15. In order to protect your Personal Data held with Us, We are using reasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of our Platform. However, please be aware that regardless of any security measures used, We cannot and do not guarantee the absolute protection and security of any Personal Data stored with Us or with any third parties.
16. Where GDPR and other local laws apply, such laws stipulate data subjects’ various rights over their data. These rights may include the following, depending on the circumstances: rights to rectify data, rights to object to processing, and the right to erase data. It is hereby clarified that after We process the information to the Financial Institution, some of the rights will not be available for the Applicants.
17. If you wish to exercise your rights under any applicable law– please contact Us by e-mail at [email protected].
DO NOT TRACK NOTICE (“DNT”)
18. DNT is a privacy preference that users can set in certain web browsers. The DNT, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. We do not currently respond to or recognize DNT feature signals.
19. Please note that We may update and amend this Policy from time to time. When We make material changes to this Policy, We will post it on our Platform. The amended version of the Policy will be effective as of the date it is published. Your use of the Services and/or the Platform constitutes your acceptance of the amended Policy.
Effective Date: 24.5.23