- The Data Security Policy sets forth the purposes, grounds and methods of processing of personal data as well as the rights of Users directly related to the processing of personal data of GamerHash Portal Users (hereinafter referred to as: the Portal) by its operator - CoinAxe spółka z ograniczoną odpowiedzialnością (hereinafter referred to as: CoinAxe) with its registered office in Poznań.
- The Controller of Users' personal data is CoinAxe spółka z ograniczoną odpowiedzialnością with registered office in Poznań (60-771), ul. Marii Konopnickiej 16/3A (hereinafter referred to as: CoinAxe), registered in the register of entrepreneurs of the National Court Register under no: 0000702796, e-mail address: [email protected]ash.com
- CoinAxe processes personal data under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as: the GDPR)
- The processing of personal data shall mean all activities performed on personal data, in particular their collection, recording, storage, downloading, retrieval, use, transmission, erasure or destruction thereof.
SCOPE, PURPOSE AND LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
- CoinAxe processes your personal data in the following scope:
- user name, e-mail address and password in order to register the user account,
- user name, e-mail address and password in order to register the user account, profile picture including avatar, in order to register the account when using an external provider such as Facebook,
- user name, e-mail address, information regarding the time and frequency of logging onto the Portal, the type of browser used by the User, the IP number of the device used to log on, the type and parameters of the device on which the Application is installed, data regarding transactions of exchange of Cryptocurrency for Bitcoin, withdrawal of Bitcoin or conversion of Bitcoin performed under the conditions set forth in the Terms and Conditions of Use of the Portal, including the conditions of these transactions in order to maintain the user account and provide services in accordance with the provisions of the Terms and Conditions of Use (inter alia, performing the following transactions: exchange of Cryptocurrency for Bitcoin, withdrawal of Bitcoin, conversion of Bitcoin into products offered on the Portal),
- e-mail/correspondence address for the purpose of responding to a question addressed by the User to CoinAxe via e-mail or by way of traditional correspondence,
- user name, e-mail address for the purpose of registration and organization of contests, as well as adjudicating upon their results,
- e-mail address for marketing purposes, including sending information about discounts, promotions, organized contests and news provided by GamerHash,
- data stored in cookies, including data on the time and frequency of logging onto the Portal, the type of browser used by the User, the IP number of the device used to log on, the type and parameters of the device on which the Application is installed, in order to personalise the content displayed, develop the products and services offered and to compile anonymous statistics.
- Personal data are processed for the purpose of User's registration and subsequent maintenance of the User account, including transaction history, execution of transactions: exchange of Cryptocurrency for Bitcoin, withdrawal of Bitcoin, conversion of Bitcoin for products offered on the Portal, for the purpose of pursuing justified interests of CoinAxe, i.e. building up CoinAxe's image by contacting the User (User's enquiries concerning the functionalities of the Portal, reporting a technical problem, researching the Users' opinions, also after the provision of services has been completed (closing the account), as well as for the purpose of proving the correctness of transaction execution, and, in the case of a separate consent granted by the User, also for marketing purposes, sending commercial offers and organizing and adjudicating contests.
- The ground for processing personal data is:
- performance of the contract in terms of: registration and subsequent maintenance of the account, including the transaction history of the exchange of the Cryptocurrency for Bitcoin, withdrawal of Bitcoin, conversion of Bitcoin for products offered on the Portal (Article 6(1)(b) of the GDPR),
- CoinAxe's legitimate interest within the scope of: building CoinAxe's image through contact with the User (responses to Users' inquiries), improving the quality of services on the basis of surveys of Users' and former Users' opinions, demonstrating the correctness of transaction execution (Article 6(1)(f) of the GDPR),
- implementation of the legal obligation imposed on CoinAxe, i.e. in particular the settlement of contests and the transfer of personal data and information on their processing to the competent state authorities, including law enforcement and tax authorities (Article 6(1)(c) of the GDPR).
- The personal data will be processed for the period in which the person remains a registered User of the Portal, but no longer than 6 years counted from the moment of deleting the account. Personal data processed for marketing purposes, sending commercial offers, participation in contests will be processed until the consent is revoked.
- Personal data of persons who registered an account but did not use its functionalities before deletion of the account are stored for 6 months from the date of its deletion.
- Personal data collected for the purpose of maintaining contact are stored for 6 months calculated from the date of last contact.
- Information collected through cookies and similar technologies is processed for the time periods indicated in Section 05 of the Policy.
- Users' personal data will be transferred to the following categories of recipients: programmers, analysts, entities offering communication tools, entities offering marketing tools.
- Users' personal data will be transferred outside the European Economic Area, i.e. to the United States of America, as part of the transfer of personal data to recipients referred to in item 6. The transfer of data is carried out under standard contractual clauses, which means that the Recipients ensure an adequate level of protection for the personal data transferred, in particular by applying appropriate technical and organisational measures.
- The provision of personal data by the User is voluntary, however, if the User fails to provide such data, it will not be possible to register and maintain the User account, execute transactions, send marketing information and commercial offers, participation of the User in a contest, CoinAxe's feedback contact with the User. Providing personal data for the purposes of settling contests is obligatory and results from the provisions of the binding law.
USERS’ RIGHTS CONNECTED WITH PERSONAL DATA PROCESSING
- In particular, the User has the right to:
- access data,
- rectify personal data,
- limit processing,
- object to processing,
- personal data portability with the proviso that the right to data portability shall only apply to data which have been processed by automated means.
- Where processing of the User's personal data is based on the User's consent, the User may revoke the consent at any time, without prejudice to the processing of personal data prior to the revocation of consent.
- CoinAxe may refuse to comply with a request for data erasure in cases provided for by law, in particular if further processing is necessary for compliance with a legal obligation requiring processing under EU or national law, or for the establishment, redressing or defence of claims. Data erasure is not possible, in particular, if a person remains a registered user of the Portal and still wants to use the functionalities of the Portal.
- The User can delete their account at any time, but deleting the account is not equivalent to data erasure. In the event of account deletion, CoinAxe processes personal data for further 6 years counted from the date of such deletion, in order to comply with legal obligations and possible redressing or defence of claims, which applies to users who have made cryptocurrency exchanges, among others.
- Promptly upon the received request to delete data, CoinAxe deletes the data of users who registered an account but did not use any of its features, as well as individuals who were not users of the service but contacted CoinAxe.
- In case of infringement of the User's personal data, the User has the right to lodge a complaint with the relevant supervisory authority.
- The request to exercise the rights referred to in items 1-2 hereinabove shall be sent by the User to the following e-mail address: [email protected].
PERSONAL DATA PROCESSING RULES
- The processing of Users' data is carried out in accordance with the principles of adequacy, expediency and minimalism, to the extent necessary for the proper functioning of the Portal and the Application, including the enhancement of their functionality, the proper performance of the mutual agreement concluded between the User and CoinAxe in connection with the downloading of the Application, the proper execution of the transaction of exchange of Cryptocurrency for Bitcoin, withdrawal of Bitcoin or conversion of Bitcoin, and in order to properly safeguard the rights and interests of CoinAxe and the Users.
- CoinAxe takes the utmost care to ensure that the data processed are factually correct and up-to-date. The factual correctness and validity of the data depends largely on the Users. The Users shall immediately inform CoinAxe of any changes to their data.
- The processing of Users’ data is carried out with the utmost care for their security, with the use of appropriate organisational and technical measures. Due to the development of modern technologies and the possibility of third parties taking unlawful actions and violating the interests of the Users, it is not possible to ensure complete security, inviolability and integrity of data. The Users are aware of these risks and accept them.
- Personal data are processed by automated means using CoinAxe software. Automated processing is performed to optimize the results of Cryptocurrency acquisition by the Device on which the Application is installed.
- Cookies are IT data, in particular text files, stored on Users' devices and intended for use on the websites. These files allow for recognition of the user's device and appropriate display of the website tailored to the user's individual preferences. The default parameters of Cookies allow the information they contain to be read only by the server that created them. Cookies usually contain the name of the website where they originate from, duration of their storage on the user's device and their unique number.
- Cookies are used to adjust the content of a website to User's preferences and to optimise it. Moreover, Cookies are used to create anonymous, collective statistics, thanks to which it is possible to check how the User uses the website, which makes it possible to improve the content and structure of the Portal, excluding the personal identification of the User.
- With regard to the purpose of collecting Cookies, the following are distinguished:
- necessary Cookies: necessary for the proper functioning of the service - files processed on the basis of the legitimate interest of the controller (Article 6(1)(f) of the GDPR);
- statistics Cookies: they allow us to study website traffic, learn about our users' preferences, analyse their behaviour on the site and enable interactions with external networks and platforms - files processed based on the user's voluntary consent (Article 6(1)(a) of the GDPR);
- marketing Cookies: they allow us to tailor the advertising and content displayed to our users' preferences and to conduct personalized marketing campaigns - files processed based on the user's voluntary consent (Article 6(1)(a) of the GDPR).
- Cookies are stored for the following period:
- necessary Cookies: from 1 day to 29 days;
- statistics Cookies: from 1 day to 2 years;
- marketing Cookies: these are session files (deleted when the window is closed) and stored for 3 months.
- The service also collects third-party Cookies, which originate from external servers, including those of CoinAxe's cooperating providers, and which allow us to customize advertisements to individual preferences of the User.
- The gamerhash.com website uses, among other things:
- Google Analytics services - detailed information on how Google uses the data collected during the use of our partners' websites and applications is available at https://google.com/policies/privacy/partners/
- Facebook services - detailed information on how Facebook uses the collected data is available at https://www.facebook.com/business/help/560982207646475
- Algolia services - detailed information on how Algolia uses the collected data is available at www.algolia.com
- Data are collected using Cookies only to perform specific functions for the User. The data are encrypted so that unauthorized persons cannot access them.
- Cookies can be managed from the level of a web browser.
CONTACTThe appropriate contact for all matters related to the Users' data, including the provisions of the Data Security Policy, is the e-mail address: [email protected].
AMENDMENTS OF THE DATA SECURITY POLICY
- CoinAxe has the right to amend the Data Security Policy with the proviso that the amendments shall be made with the utmost care to maintain the security of the personal data processed, in particular by applying technical and organisational measures adequate to the data security risks identified by CoinAxe.
Last update: 18/10/2021