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Coinbook® Privacy Policy
Updated October 8, 2018

Introduction

Thank you for visiting the Coinbook® (Coinbook, we, our, us, Platform) website. Coinbook’s privacy policy is simple: we respect your privacy and we are committed to protecting it. This Privacy Policy (together with the User Agreement) governs the collection, use, maintenance, processing, storage, and sharing of personally identifiable information (PII) under our control.

PII is any information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is “linked” or “linkable” to a specific individual.

We will not collect certain information that does not relate to your use of Coinbook (e.g. religious affiliation, political or ideological beliefs, sexual orientation, or health or biometric information). We will not sell your information to third parties for marketing purposes, and will share your information with third parties only when it is necessary to: (i) to execute financial transactions, (ii) respond to your customer service request; or (iii) otherwise fulfill our obligations to support your account.

Information you provide to us

Identity Verification

When you create a Coinbook account you will provide sufficient information for us to verify your identity. Identity verification is a critical part of complying with financial regulations. If creating a company account, you will also provide sufficient information to verify your company’s identity and status. Examples of the type of information we may collect:

- Biographical information: Legal name and aliases, physical address, date of birth, email address, phone number, social security number or other tax identification number, photographic identification, information for multi-factor authentication, and any other information you choose to provide;
- Company information: Legal name, company names in common use, physical address, organizational documents (e.g. articles of incorporation), employer identification number, and other information related to authorized account users;
- Banking information: banking institution name, routing and account numbers for linked accounts, and other information required by contractually-bound banking partners.

Customer Support

Coinbook will collect information that is necessary to satisfy customer requests or troubleshoot platform performance issues. That information may include: name, email address, machine operating system version, IP address, browser type and version, or any other information you provide.

Information we collect

We will collect nonpublic personal information as you interact with our platform. By using our Platform you consent to our use of all the information herein discussed, and all other information necessary to complete requests.

Transaction History

We will collect nonpublic information regarding your transactions as you post advertisements, send trade requests, or use linked payment accounts. Collected information will include transaction times, transaction amounts, financial details relating to the buyer and seller, machine information (see below), and other information provided in connection with the transaction.

Digital Fingerprint

Your interactions with Coinbook’s platform and services will be conducted almost exclusively through Internet-connected electronic devices. During these interactions, we may automatically collect certain information—for example, full IP addresses, hardware information, operating system and browser information, etc.—associated with your devices and online activity. This digital fingerprint may be considered personal information when combined with other information about you. To the extent this digital footprint is attributable to your identity, our Privacy Policy and the User Agreement will govern how we handle your information. Any information that is severable from your identity is considered anonymous and is not governed by the Privacy Policy’s third-party restrictions.

Session Activity

We use various technologies (i.e. cookies) to collect information about your session, including the pages you visit, the duration of your visit, and how you navigate through our site. We use this session information for a variety of purposes, including efforts to optimize website design, efficiently allocate server resources, and personalize your site experience.

Using, disclosing, and transferring your information

Using your information

Coinbook will use your PII for the purposes indicated at the time you provide such information; for purposes described in the foregoing sections; for uses, consistent with your consent, that are necessary satisfy your requests; and as otherwise permitted by law. These uses may include:

- Maintaining and personalizing your USD wallet and trading account
- Completing transactions on the Platform by sharing information with the Bank and linked payment methods;
- Sending you technical notices, updates, security alerts, and administrative messages;
- Responding to your customer service requests;
- Linking or combining information we get from essential partners to help understand your needs and provide you with better service;
- Diagnosing problems in our applications and websites; or
- As required for regulatory purposes such as verifying user identity, taxation, prevention of money laundering, fraud prevention, and other relevant legal or regulatory purposes.

Disclosing your information to third parties

As mentioned in the introduction, we will not share your information with third parties for marketing purposes. However, the proper use of your PII may require disclosure of your information to certain third parties. When this happens, any such third party (excepting regulatory or law enforcement authorities) would be contractually bound to adhere to the same security and confidentiality policies as Coinbook. Instances in which we may disclose your information include the following:

- With financial institutions to complete a trade request;
- With government entities, regulatory or investigatory, when we are required to provide information in response to a government subpoena, court order, or other applicable law or legal process (NOTE: We may not be able to inform you of disclosure in these instances due to legal restrictions);
- With identity verification and fraud prevention services, including when we have good-faith belief that such disclosure is reasonably necessary to address security threats to Coinbook’s platform, databases, systems, or infrastructure;
- With any third party for whom you provide consent;
- With financial institutions, insurance companies, or interested investment entities in the event of acquisition, merger, divestiture, or other corporate re-organization and when we notify you of such sharing of your information; or
- When we anonymize your data for statistical or marketing purposes.

Transferring your information

Coinbook is based in the United States. Information we process and transfer is protected by U.S. law.

Your rights

Access

You may access your PII via the user’s account settings page on our website. You may also access your PII and account history by submitting a written request here: Support. In response to such a request, we will share the PII we have stored, as well as the use and general disclosure of your PII. We will also give you a copy of the PII we have retained. There may be a minimal charge, to cover administrative costs, for providing you additional copies of PII.

Correction

You have the right to require the correction, updating, and blocking of inaccurate and/or incorrect data by submitting an electronic request here: Support.

Deletion

You may request the deletion or destruction of both the Account and PII by submitting a written request here: Support. Coinbook will action your request immediately, except where this is not consistent with its legal and regulatory obligations.
NOTE: To ensure the confidentiality, integrity, and availability of your information to yourself, we may request that you confirm your identity by providing identification documentation, and/or other methods, prior to assisting you in exercising any of your rights. If you refuse to prove your identity, we may decline to take actions in respect to your data.

Miscellaneous items: security, retention, updates, etc

Security

We have implemented technical and organizational security measures to ensure the confidentiality of your PII and to protect your PII from loss, misuse, alteration, or destruction. Only authorized personnel of Coinbook, and properly authorized third party personnel who adhere to our guidelines under the circumstances described above, will have access to your PII. These personnel are required to treat the information as confidential. While we will continue employing reasonable measures to secure your data, no system can guarantee absolute security. In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay.

As stated in our User Agreement, you are responsible for protecting your login information, credentials, machine information, financial information, and other systems and data. You are responsible for avoiding phishing and other email scams that are targeted to obtain your PII. If you discover what you believe is a fraudulent claim, phishing, or scam which impersonates Coinbook, please email us here: Support.

Retention

We will hold your PII only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with record-keeping activities for anti- money laundering, taxation, and company legal obligations, we will retain accounts and personal information for, at least, a period of 7 years after a user closes his account.

Once we have neither any obligation to provide you with a service you requested, nor any obligation to hold PII for regulatory or legal purposes, we will anonymize or dispose of your PII in line with acceptable industry and security standards. We will also maintain a log of which data should be deleted from archived backups.

Policy changes and updates

We will periodically update this Policy, and will provide you with notice of such changes where reasonable. You will have an opportunity to review these changes and renew your consent.

Integration

(385) 247-COIN