Privacy Policy

INTRODUCTION

BITVAULT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (trading as RENVERX) is a private company incorporated in the Republic of Poland with KRS 0001030740 and NIP 7252330396 having its registered address at UL. PIOTRKOWSKA 116 / 52, 90-006 ŁÓDŹ, (hereinafter referred to as “BITVAULT”, “RENVERX”, “Company”, “we”, “us”, “our”). RENVERX has entered into Polish Register of activities in the field of virtual currencies on 24th April 2023 with registration number RDWW-725.

GENERAL PURPOSE

This Privacy Policy governs collection, processing and use of your personal information that you provide us when accessing or using the website renverx.com (hereinafter referred to as “Website”), exchange platform and other related services provided by the Company via the website (hereinafter referred to as “Services”).

The purpose of this Privacy Policy is to describe:

• The types of Personal Information we collect and how it may be used;
• How and why we may disclose your personal information to third parties;
• The transfer of your personal information;
• Your right to access, correct, update, and delete your personal information;
• The security measures we use to protect and prevent the loss, misuse, or alteration<>of personal information;
• Company’s retention of your personal information;
• This Privacy Policy also covers some basics of our use of cookies, however, formore details please see also our Cookies Policy.

DEFINITION

“Personal information” is any information relating to an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by an identifier such as name, identification number, location data, online identity or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of functions that are performed on personal data or sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Company is committed to protecting and respecting your privacy. We control the ways of collecting your personal information, and determine goals for which we use personal information. We are a “data controller” within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”) and other applicable European laws pertaining to data protection.

PERSONAL INFORMATION WE COLLECT

We collect the next personal information:

• Contact information, such as name, home address, phone number and email address;
• Account information, such as username and password;
• Financial information, such as bank account numbers, bank statement, trading activity and history, commissions charged, etc.;
• Identity verification information,such as images of your government issued ID, passport, national ID card, driving license or other documents requested by our Compliance team;
• Residence verification information, such as Utility bill details or similar information;
• Other information, obtained during our KYC procedures, such as information about your financial state and source of funds.

We also may collect certain computer, device, and browsing information when you access the website or use our services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

• The information about the computer or mobile device you use to access our website, including the hardware model, operating system and version, the web browser you use, IP addresses and other device identifiers.
• Website usage information,the server login formation,which may include(but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at our website and the websites you visit just before and just after our website.
• The bandwidth upload, download speeds and other statistics about your device.

We may automatically capture, store and otherwise process information about you even if you abandon the completion of an online application or registration form.

USE OF COOKIES

The website is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Our website uses cookies to enable you to use the website, the services we offer and the materials on the website. Cookies are also used to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website and services.

USE OF PERSONAL INFORMATION

We may use your personal information to:

• Process your transactions. We will process your personal information only for the purpose(s) for which it has been provided to us;
• Fulfill our legal or regulatory requirements;
• Verify your identity in accordance with the applicable legislation and the Company’s AML & KYC policy, as well as address other law enforcement needs. We also may share your information with other financial institutions and with tax authorities if such actions are required from us due to any applicable legislation;

• Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
• Protect our rights and property;
• Personalize your services experience;
• Analyze website usage, and improve our website and website offerings;
• Analyze and track data to determine the usefulness or popularity of certain content and to better understand the online activity of our website users;
• Help us respond to your client service requests and support needs, answer your inquiry or respond to a communication from you;
• Contact you about our services;
• The email address you provide may be used to communicate information and updates related to your use of our services;
• We may also occasionally communicate technical notices, support or administrative notifications, company news, updates, promotions, and related information about services provided by Company;
• Link, connect or combine personal information we collect from or about you with other personal Information;
• Carry out any other purpose or reason for which the Information was collected.

If you wish to stop receiving marketing communications from us, please contact us at [email protected] to opt-out.

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION

We may disclose your personal Information to third parties and legal and regulatory authorities, and transfer your personal Information as described below:

• Disclosures to Third Parties.
  In processing your transactions, we may share some of your personal information with our third-party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide services or as required by law. By using website or services you consent to the disclosure of your personal information as described in this Privacy Policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Company’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws.
• Disclosures to Legal Authorities.
  We may share your personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

• Compelled by subpoena, court order, or other legal procedure;
• We believe that the disclosure is necessary to prevent physical harm or financial loss;
• Disclosure is necessary to report suspected illegal activity;
• Disclosure is necessary to investigate violations of this Privacy Policy or any our agreement with you.
• International Transfers.

We store and process your personal information in data centers around the world, wherever Company facilities or service providers are located. As such, we may transfer your personal information between such data centers. Such transfers are undertaken in accordance with our legal and regulatory obligations and are performed only via protected channels.

d. Other Circumstances for Disclosure.
We also can disclose your Personal Information in the following circumstances:

• With your consent or at your instruction. Certain information you may choose to share may be displayed publicly, such as your username and any content you post when you use interactive areas of our website;
• With our current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices internationally. We ensure that listed parties will be bound by terms not less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws;
• If the sharing of personal information is necessary for protection of our rights and property, or rights and property of the above listed current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices.

CUSTOMER RIGHTS

You are able to exercise the following rights if this does not contradict the legal requirements in relation to the prevention of money laundering and terrorist financing laws, our record keeping obligations, etc.:

• The right to be informed about the fact that we’re processing your personal Information and which data exactly we are processing;
• The right to data portability. In certain circumstances, you have the right to obtain all your personal information we store in a machine-readable format;
• The right to object the processing of your personal information;
• The right to access your personal information, to correct, update, and block

  inaccurate and/or incorrect data;

• The right to withdraw your consent of personal information processing;
• The right to erase your personal information from our servers upon your justified request;

To exercise these rights, contact us at [email protected]. We reserve the right to request additional information from you, that may be necessary in order to provide a duly response to your request in accordance with applicable legislation and you agree with such our right. Also, if you wish to correct, update, and block inaccurate and/or incorrect data, we have a right to request a confirmation of correct data from you, for example, official documents containing such data. Please note that if we are unable to verify your identity by e-mail messages, website etc., or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity, including by personal appearance in our office. This is the only way we can avoid disclosing your personal information to a person who can perpetrate your identity. In some cases, we will not be able to change your personal information. In particular, such case can include the event when your personal information has already been used during the execution of any agreement or transaction, or is specified in any official document, etc. You have the right of withdrawal of consent to personal data processing. Please be advised, that in case of realization of your right of withdrawal of consent to personal data processing or right to be forgotten, we will may not be able to provide you our products or services, and we have a special right to terminate all our current agreements with you with the application of legal consequences of such termination, and you irrevocably acknowledge such our right. Furthermore, in this case, for the purposes of safety, we may request you to present your ID document, including directly at our office.

RECORDING OF ELECTRONIC COMMUNICATION

The Company records, monitors and processes any telephone conversations and/or electronic communications between the Company and you such as through phone, fax, email, social media, electronic messages, either initiated from the Company’s side or your side. All such communications are recorded and/or monitored and/or processed by the Company, including any telephone conversations and/or electronic communications. The content of relevant in person conversations and/or communications with you may be recorded by minutes or notes.

SECURITY

We use a variety of security measures to ensure the confidentiality of your personal information, and to protect your personal information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

• Password protected directories and databases;
• Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely;
• Limited access to hosting servers using 2FA and traffic encryption;
• All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database;
• Only authorized Company personnel are permitted access to your personal information, and these personnel are required to treat the information as highly confidential;
• The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

BREACH AND SECURITY INCIDENTS

Breach of security leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. The Company is responsible for ensuring immediate action in the event of a security incident or personal data breach. The Company has in place procedures to deal with any suspected personal data breach and will notify you and the relevant competent regulator of a breach where the Company is legally required to do so. If you require further information on how the Company deals with a Data Breach, please contact us at [email protected].

RETENTION OF PERSONAL INFORMATION

We retain personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain account and other personal information for at least five years after termination of respective agreement.

UPDATES TO PRIVACY POLICY

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at our sole discretion. Should any changes to this Privacy Policy occur, the amended Privacy Policy will be available on our website.

ADDITIONAL INFORMATION

If you have any specific questions or concerns about privacy, please contact [email protected].