Privacy Policy

GENERAL

This Privacy Policy, together with our Terms of Use, governs Bitmove’s collection, processing and use of your Personal Data. As used in this Privacy Policy, “Bitmove”, “we” refers to Bitmove Exchange S.A., a Payment Institution, Bitmove S.A. Limited is incorporated in Luxembourg with the company number 199541 and with its registered office at 145 Rue du Kiem, 8030 Strassen, Luxembourg are data controllers under this Privacy Policy, which sets out the manner in which all the companies, as data controllers, may use your Personal Data. Bitmove S.A is in partnership with Swedish Tech & Design AB organisation number 556976-8251.

 

“DP Law” means data protection law as applicable to Bitsmove, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts. “Personal Data” has the meaning set forth in DP Law. This notice covers our use of your Personal Data arising from use of the Bitmove website (www.bitmove.net) as well as registering, subscribing, buying and using our products and Services. If you have any questions or need any further clarification please get in touch. Contact details are set out below in the Contact Us section.

Capitalised items in this Privacy Policy have the meaning set out in the Definitions section below.

Bitmove is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

  • The types of Personal Data we collect and how it may be used;
  • Our use of cookies and similar technology;
  • How and why we may disclose your Personal Data to third parties;
  • The transfer of your Personal Data within and outside of the European Economic Area (“EEA”);
  • Your statutory rights concerning your Personal Data;
  • The security measures we use to protect and prevent the loss, misuse or alteration of Personal Data; and
  • Bitmove’s retention of your Personal Data.

COLLECTION AND USE OF PERSONAL INFORMATION

  1. Personal Information We Collect

We collect the Personal Data which you provide directly to us or which we generate when you open a Bitmove Account, perform any transactions on the Bitmove Platform, or use other Bitmove Services or our website. This may include:

  • Contact information, such as name, home address and email address;
  • Account information, such as username, password, Account settings and preferences;
  • Financial information, such as bank account numbers, bank statement and trading information;
  • Identity verification information, such as images of your government-issued ID, passport, national ID card or driving licence. Note: US residents may be asked to provide their social security numbers;
  • Residence verification information, such as utility bill details or similar information;
  • Image in photo or video form (where required as part of our know-your-customer checks);
  • Records of our discussions, if you contact us or we contact you (including records of phone and video calls);
  • Information regarding the way in which you use our Services, such as when you used our Services, and the specific Services used; and
  • Other information relating to communications with us, whether through the Bitmove website or via e-mail, over the phone or via any other medium.

We also automatically collect certain computer, device and browsing information when you access the Bitmove website or use Bitmove 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:

  • Computer or mobile device information, including IP address, operating system, network system, browser type and settings;
  • Website usage information.

Finally, we may collect Personal Data from third-party partners and public sources, which include:

  • Reputational information;
  • Financial information;
  • Business activities of corporate customers.

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money-laundering/counter-financing-of-terrorism/know-your-customer obligations. If this information is not provided we may not be able to provide a Service for you. Your Personal Data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of legal claims. We will not delete Personal Data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

It is important to note that the Personal Data we collect on you when you create an Account will be retained for the mandatory retention period set forth by applicable law as it is necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated financial sector professionals, even if your Account has not been successfully activated (e.g. if Account verification has not been completed) or no transaction has been made using it. 

  1. Use of Cookies and Similar Technology

The Bitmove website uses 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.

Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and what difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

We use one or more third-party Service providers, to assist us in better understanding the use of our Site. Our Service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Site, what products are browsed and general Transaction information. Our Service provider(s) will analyse this information and provide us with aggregate reports. The information and analysis provided by our Service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our Service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our Service provider(s) is/are contractually restricted from using the information they receive from our Site for any other purpose than to assist us.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of our website or Services, such as logging in to your Bitmove Account or making Transactions.

For more information about cookies, the types of cookies we use and how we use them please see our Cookie Policy.

  1. How We Use Your Personal Information

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract – for example, your contact and payment details. Some information processing is required by law due to our anti-money laundering and anti-fraud screening obligations. Where we process special categories of personal data (for example, your biometric data during the verification process), we may ask for your consent, but may also, as permitted by law, rely on substantial public interest (regulatory requirements, preventing fraud, terrorist financing and/or money laundering) or our right to establish, exercise or defend legal claims.

Some information is processed because you have given your consent, which can be withdrawn. Other information we collect and use because we have legitimate business interests to do so, having taken into account your rights, interests and freedoms.

We may use your Personal Information to:

  • Create and administer your Bitmove Account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract) and for compliance with legal obligations to which we are subject;
  • Process your Bitmove transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
  • Verify your identity in accordance with applicable know-your-customer, money-laundering and other financial sector legislation or regulations, including those required for compliance with the Bitmove Anti-Money Laundry Policy, as well as address other law enforcement needs as described in our Terms of Use, and generally as required for compliance with legislation and regulations applicable to Bitmove. With respect to US residents, we also may share your information with other financial institutions, as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act (“FATCA”), to the extent that this statute may be determined to apply to Bitmove. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
  • Prevent fraud and other financial crimes. Related processing operations are necessary for compliance with legal obligations to which we are subject and for purposes of our legitimate interests (that is, developing and improving our anti-fraud system and meeting our legal responsibilities);
  • Personalise your Bitmove Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our Services);
  • Analyse Bitmove website usage and improve our website and website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our Services);
  • Help us respond to your customer Service requests and support needs. Related processing operations are necessary for the performance of a contract with you and for purposes of our legitimate interests (that is, improving our Services and offering you the best experience);
  • Contact you about Bitmove Services. The email address you provide may be used to communicate information and updates related to your use of Bitmove Services.
  1. Marketing

We may also occasionally communicate company news, updates, promotions and information relating to similar products and Services provided by Bitmove. We may also administer a contest, promotion, survey or another site feature as is further explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under DP Law in pursuit of our legitimate interests (that is, promoting our Services).

We may share Personal Data with third parties to help us with our marketing and promotional projects, or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, posts and other forms of communication from us (or our promotional partners), which you might receive in accordance with this section, you can choose one of the following ways:

  • Log into your Account and update your profile in Account settings;
  • Click “unsubscribe” at the bottom of an email we sent you; or
  • Contact us at dpo@bitmove.net and request to opt out.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as Account status and activity updates, survey requests in respect of products and Services we have provided to you after you have opted out, reservation confirmations or respond to your inquiries or complaints, and similar communications.

DISCLOSING AND TRANSFERRING PERSONAL DATA

We may disclose your Personal Data to third parties and legal and regulatory authorities and transfer your Personal Data outside the EEA, as described below.

  1. Disclosures to Third Parties

There are certain circumstances where we may transfer your Personal Data to employees, contractors and to other parties.

  • We may share information about you with other members of our group of companies so we can provide the best Service across our group. They are bound to keep your information in accordance with this Privacy Policy;
  • We may use a processor to process personal and formal identification data for the purpose of verifying the identity of our users by using ID document verification and facial biometrics technologies. The processor may collect your full name, nationality, date of birth, gender, social security number, tax ID number, email address, phone number, IP address, passport details, driver’s license details and national identity card details. Additionally, the processor may collect a photograph or video of you to perform a facial or liveness check. Your biometric data will be destroyed immediately after the completion of the identity verification process;
  • We may also share your information with certain contractors or Service providers. They may process your Personal Data for us, for example, if we use a marketing agency. Other recipients/Service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres. Our suppliers and Service providers are required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in relation to the performance of their function;
  • We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or Services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.

Your Personal Data may be transferred to other third-party organisations in certain scenarios:

  • If we are discussing selling or transferring a part or all of our business – the information may be transferred to prospective purchasers under suitable confidentiality terms;
  • If we are reorganised or sold, information may be transferred to a buyer who can continue to provide Services to you;
  • If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example law enforcement; and
  • If we are defending a legal claim, your information may be transferred as required in relation to defending such claim.

Your Personal Data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be Personal Data.

Your information will not be sold, exchanged or shared with any third parties without your consent, except to provide Bitmove Services or as required by law.

Bitmove’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 complying with DP Law.

  1. Disclosures to Legal Authorities

We may share your Personal Data with law enforcement, data protection authorities, government officials and other authorities when:

  • Compelled by court order or other legal procedure;
  • Disclosure is necessary to report suspected illegal activity; or
  • Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use. 

 

YOUR STATUTORY RIGHTS

You have certain rights concerning your Personal Data under DP Law, as mentioned below, and can exercise them by contacting us at dpo@bitmove.net . 

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold on you and certain other information about it to check that we are processing it lawfully. We process a large quantity of information and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.

Correction: you are entitled to request that any incomplete or inaccurate Personal Data we hold about you is corrected.

Erasure: you are entitled to ask us to delete or remove Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure; for example, where the Personal Data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain parts of your Personal Data; for example, if you want us to establish its accuracy or disclose the reason for processing it.

Transfer: you may request the transfer of a certain part of your Personal Data to another party.

Objection: where we are processing your Personal Data based on a legitimate interest (or that of a third-party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legally or similarly significant effect and ask for it to be reconsidered.

Where you have given consent to a particular processing, you have the right to withdraw such consent by email at dpo@bitmove.net . Note that such withdrawal will only be effective for the future and that, according to DP Law, it does not affect the lawfulness of processing based on consent given before such withdrawal.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union where you are habitually resident, where we are based or where an alleged infringement of Data Protection Law has taken place. In Luxembourg, you can make a complaint to the Luxembourg data protection authority (Commission nationale pour la protection des données, Tel: 00352 26 10 60 1 or atwww.cnpd.public.lu).

RESIDENTS OF THE STATE OF CALIFORNIA (USA)

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information.

Bitmove will not discriminate against any customer that asserts their rights under the CCPA. We will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you a different level of qualify of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

If you are a California resident, you have the right to request certain information from us regarding our information-sharing practices with third parties for direct marketing purposes. To the extent that we share your personal information for direct marketing purposes, you may receive the following information: (1) the categories of information and sources of information that we disclosed to third parties for direct marketing purposes during the preceding year; and (2) the names and address information of third parties that received such information, or if the nature of their business cannot be determined from the name, the examples of the products or services marketed.

To the extent that Bitmove sells your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You also have the right to direct us not to sell your personal information.

California residents may also designate an authorized agent to make a request to access or delete on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 through 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

If you are a California resident, you may exercise your rights by contacting us at the addresses and numbers provided below.

SECURITY OF PERSONAL DATA

We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorised 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; and
  • PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised Bitmove personnel are permitted access to your Personal Data, 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.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other form communication that we use to contact you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or Services is operated by Bitmove. If you do receive a suspicious request, do not provide your information and report it by contacting one of our Service representatives as set in this Privacy Policy.

You are responsible for keeping your Account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us as soon as possible (see Contact Us).

RETENTION OF PERSONAL DATA

We retain Personal Data for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. The criteria we may use to determine the retention period for certain categories of data include:

  • How long you have been a Bitmove member;
  • Whether there are contractual or legal obligations that exist that require us to retain the data for a certain period of time;
  • Whether there is any ongoing legal or financial claim that relates to your relationship with us;
  • Whether any applicable law, statute or regulation allows for a specific retention period; and
  • What the expectation for retention was at the time the data was provided to us.

In accordance with our record-keeping obligations, we will retain Account and other Personal Data for at least five years (in some cases up to ten years, as required by applicable law) after an Account is closed.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy was last revised on November 5, 2020. We may change this Privacy Policy from time to time, so it is advisable to review it frequently. Changes to this Privacy Policy will be announced on our website or through similar means for a reasonable length of time prior to and following the change taking effect. 

DEFINITIONS

Personal Data. Information that identifies an individual, such as name, address, e-mail address, trading information and banking details. Personal Data does not include anonymised and/or aggregated data that does not identify a specific user;

Service(s). The technological platform, functional rules and market managed by Bitmove to permit Sellers and Buyers to perform purchase and sale transactions of Bitcoins.

Transaction. Includes the following:

  • The agreement between Buyers and the Sellers to exchange Bitcoins through the Service for currencies at a mutually agreed rate;
  • The conversion of currencies into Bitcoins deposited by members on their Accounts;
  • The transfer of Bitcoins among members;
  • The transfer of currencies among members; and
  • The purchase of ancillary products.



 

CONTACT US

Please contact us with questions, comments or concerns regarding our Privacy Policy and/or practices at dpo@bitmove.net  

You may also contact us at:

  • Luxembourg: +352 27 87 25 06