Personal data means personal data that can be linked to an identified or identifiable person. Personal data does not include information that does not identify a specific User. The personal data that we may request from you include your first and last name, address of permanent residence, telephone number, e-mail address, Telegram nickname.
If you have questions about personal data, you can contact us by email at email@example.com.
Within our services, you can manage your privacy in various ways. At the same time, you always have the opportunity to use your rights arising from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of persons in the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (general regulation on data protection) (“Regulation”) and Act no. 18/2018 Coll. on the protection of personal data and on the amendment of certain laws (“the Law”).
- Collected data and how we use it
The purpose of registering the User as a data subject is the provision of data and information services by the Provider on the Website or through a public or private account on Telegram, which consist in the use of software functionalities (monitoring of selected trading pairs and sending information and notification about the conditions on the given trading pairs) based on User-specified requests.
The legal basis is the Civil Code and the contract itself (Article 6, paragraph 1, letter b) of the Regulation, or § 13 par. 1 letter b) of the Act) – processing is necessary for the performance of a contract to which the affected person is a party, or to carry out measures prior to the conclusion of the contract based on the request of the affected person.
Other legal bases include the fulfillment of our legal obligations, your and our legitimate interests, and your consent to the processing of personal data. If we process your personal data based on your consent, you are entitled to revoke this consent at any time.
The data provided is processed electronically through the Web, to which employees have different access rights, in relation to their job classification.
Personal data provided by the User as a data subject is processed not only by us, but also by our external providers, contractual partners, with whom we have properly entered into contractual relations regarding how your data is processed. This is mainly a server provider, accounting processor, IT administration, etc.
- What personal data we collect
We may collect information about you when you visit our Website and/or use the Services, including the following:
- Registration information – Before you create an Account, we may ask you to provide us with your Telegram nickname, i.e. Your account registration data with a partner – Telegram – an application operated by Telegram UK Holdings Ltd (71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
- Conclusion of the contract for the provision of Services – In order to conclude and fulfill the contract for the provision of Services, we may request your name and surname, address of permanent residence, telephone contact and email address.
- Transaction and Experience Information – When you use the Premium Services, we may collect transaction information as well as other information related to the transaction, such as payment information, such as a payment card number or other financial information. This information may include your digital wallet address, Internet Protocol (IP) address, cookie identifiers, mobile carrier identifiers, mobile advertising identifiers, MAC address, details about your browser or device, geographic location information, ISP, pages you have previously visited. Information about the use of the Services and other information about how you use the Services. This information will be collected to facilitate the provision of the Services.
- Information about you from third-party sources – We may obtain information from third-party sources, such as Your nickname created on Telegram (registration data), public databases, ID verification partners and credit history, if permitted by law. Such information may include your name, account number and/or customer ID with a third party, address, job title, public employment profile, credit history, status on any sanction lists maintained by public authorities and other relevant data.
- Other information we collect in connection with your use of the Services – We may collect additional information, including your email address, phone number, from or about you when you communicate with us, contact our customer support teams. Such information will be collected to maintain contact with you and provide services.
4. How we process personal data
We may process your data for the following purposes:
- To administer your Website Account and provide the Services, including:
- generally manage individual information and accounts,
- verify access to your Account,
- communicate with you about your Account and your transactions,
- provide a customized experience and implement the preferences you request,
- keep your Account information up to date and process transactions.
For this purpose, we therefore obtain your personal data because we provide you with our service, freely chosen by you in accordance with our Terms & Conditions governing the provision of the chosen service. By accepting our Terms & Conditions governing the provision of your chosen service, a contract is concluded between us.
II. To manage our business needs, such as monitoring, analyzing and improving the Services and the performance and functionality of the Website; ensuring quality control and employee training; develop new products and services; and enforcing our agreements with third parties;
III. To manage risk and verify your identity. We may use Personal Data to increase security, monitor and verify access to the Services, combat spam or other malware or security risks; prevent potentially prohibited or illegal activities; and enforce our Terms & Conditions.
IV. To promote the services and products and services of non-affiliated businesses to you. We may also process your personal information to uniquely tailor marketing content, advertisements and offers and certain services or Website experiences to better match your interests on the Website.
V. To provide personalized services. We may use your personal data and other information collected in accordance with this Policy to provide you with a targeted display, functionality, or delivery of targeted offers based on your communication preferences.
VI. To uphold our obligations and enforce our Terms & Conditions, including compliance with all applicable laws and regulations.
VII. To provide customer support, such as responding to your requests, resolving disputes, and troubleshooting.
VIII. To fulfill legal obligations:
Special legal regulations may impose various obligations on us as a Service Provider, for the purpose of which the processing of your personal data is necessary. For example, in accordance with the Civil Code and regulations in the area of consumer protection, we process your personal data also for the purpose of processing possible complaints. Another example when the purpose of personal data processing is the fulfillment of legal obligations is the accounting law, according to which we are obliged to store certain data for paid services for the period specified in this law.
IX .To evaluate, maintain and improve our services and develop new services:
Based on your information, we ensure that our services work as you expect them to, for example, we monitor outages or eliminate problems that you report to us. With the help of your information, we also try to innovate our services – for example, when, based on your suggestions, we determine the need to improve the quality of the service or register a demand for a new service or evaluate the need for higher user protection, etc. The information we collect as part of existing services helps us develop new services.
X. Other uses. We may use personal information for any other purpose that will be notified to you at the time you provide such information or otherwise with your consent.
Session Cookies – These are cookies that allow our website to collect information about what you do during your browsing session each time you visit the website. When connecting to our server, your device will be assigned a session ID, which allows our server to identify your device during the session and facilitates the use of the website. These cookies are temporary and are set to be deleted when you leave the website;
Persistent Cookies – These are cookies that your internet browser stores for more than one session and whose validity expires within a defined time period. Persistent cookies allow us to remember your settings and information so you don’t have to re-enter them every time you visit our website. They also measure how you use and interact with the website and allow us to personalize the website. For example, they may allow us to change the rotation of images on the website so that different images are displayed on your next visit;
First-Party Cookies – These are cookies that we store and access on your device as the administrator of your personal data when you visit our website. They may include cookies related to third-party service providers, provided that we review and determine the purposes and means of processing your personal data recorded by these cookies. As a result, first-party cookies may record user personal data that is accessible to third parties and processed by third parties on our behalf and at our direction;
However, please note that this may render some features of our website inoperable or difficult to use. Depending on the Internet browser you use, you may be able to specifically reject third-party cookies. However, please note that third parties may still have access to your personal information to the extent that this information is recorded through first party cookies.
- How the Provider shares and discloses personal data about you
I. The Provider may share information about you with our business partners due to the purposes stated in these Principles and the impossibility of securing them in-house (such as accounting, programming services, the server used, IT security, etc.). The most common reasons for sharing data with intermediaries:
- necessary to include a third-party service provider to simplify, secure or extend our services,
- the impossibility of securing their own activities,
- it is required by a court order or a legal or regulatory requirement of a regulation, performance of a contract,
- the company is sold or transferred,
- to enforce compliance with our Terms & Conditions,
- the safety of our customers and employees and third parties must be ensured,
- must protect our rights and property, and the rights and property of our landlords, employees, and third parties
II. With other parties as permitted or required by law and regulation: We may share information about you with other parties if we need to do so to comply with law, legal process or regulation; or as required by law enforcement, regulatory authorities, government officials or other third parties in connection with a subpoena, court order or other legal process or request under applicable law or regulation; or when we believe, in our sole discretion, that disclosure of personal information is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate a breach of contract or to comply with regulatory requirements that apply to the provision of our services.
- Data Retention
I. We will not keep information and data about you longer than is necessary for the performance of the contract or for legal requirements. Please note, however, that we may retain some information even after e.g. you file an objection with us, for example if it is necessary to fulfill our legal obligations, such as storing information for tax and accounting purposes, or proving legal claims.
II. If we process your personal data on a legal basis – the fulfillment of legal obligations, then we process your personal data for the period specified by law. If we process your personal data on a legal basis – our legitimate interest or the legitimate interest of third parties, we process your personal data for the duration of the legitimate interest. If we process your personal data on a legal basis – your consent, we process your personal data for the period for which you have given us your consent to process your personal data.
- What are your rights related to the processing of personal data
You can exercise your rights by sending an email to firstname.lastname@example.org or by sending a post notification to the address of BN Group.
I. The right of access to personal data
This right means that you are entitled to request confirmation from us as to whether personal data relating to you is being processed. Therefore, if we process such personal data about you, you have the right to obtain access to your personal data and information about:
- why we process your personal data (purpose of personal data processing),
- what data we process about you (category of personal data),
- to whom they can or your personal data will be provided (identification of recipients or circle recipients),
- how long will we keep your personal data (personal data retention period),
- that you have the right to request from us the correction of personal data, their deletion as well as the limitation of their processing or that you have the opportunity to object to the processing of personal data,
- that you have the right to file a proposal to initiate proceedings on the protection of personal data according to the Act or the right to file a complaint with the supervisory authority according to the Regulation, which is the Personal Data Protection Office of the Slovak Republic,
- where your personal data comes from (information about the source), unless you have provided us with personal data directly,
- whether we use automated individual decision-making, including profiling according to § 28 par. 1 and 4 of the Act; especially about the procedure used, as well as about the meaning and expected consequences of such processing of personal data for you,
- about adequate guarantees regarding the transfer, in case we transfer your personal data to a third country or an international organization.
For you, this right of access also means the possibility to obtain personal data that we process about you. We will provide you with a copy of your personal data that we process about you. However, if you repeatedly request the provision of your personal data, we may ask you for a reasonable administrative fee in connection with your request for a copy of your personal data.
II. The right to correct personal data
As part of the Terms & Conditions we ask you to provide us with correct information. However, if it still happens that we process incorrect data about you, the right to rectification of personal data means that you are entitled to request that we correct incorrect personal data concerning you. Also, taking into account the purpose of personal data processing, you also have the right to have your incomplete personal data supplemented.
III. The right to erasure of personal data (the so-called right to be forgotten)
You have the right for us to delete personal data relating to you if at least one of the following reasons is met:
- your personal data is no longer necessary for the purpose for which we obtained it or otherwise processed it,
- you have withdrawn your consent to the processing of personal data, on the basis of which we process your personal data, and at the same time there is no other legal basis for their further processing,
- you object to the processing of personal data, which is carried out on the legal basis of public interest or legitimate interest and no legitimate reasons for their processing prevail,
- your personal data was processed illegally,
- your personal data must be deleted, as it is necessary to fulfill an obligation under the law of the Slovak Republic or the law of the European Union,
- your personal data was obtained in connection with the offer of information company services according to § 15 par. 1 of the Act.
However, your right to erasure of personal data may not be granted in a specific case with regard to specific circumstances, if the processing of personal data is necessary for:
- to exercise our right to freedom of expression or right to information,
- to fulfill a legal obligation,
- to exercise our legal claim,
- for the purpose of archiving, for the purpose of historical research or for statistical purposes, if it is likely that the right to erasure would make it impossible for us to achieve the goals of such.
IV. The right to restrict the processing of personal data
You have the right to have us limit the processing of personal data concerning you and at least one of the following reasons is met:
- during the period allowing us to verify the correctness of your personal data, you object correctness of your personal data,
- it will be an illegal processing of personal data, you will object to the deletion of personal data and will request a limitation of the processing of personal data instead of deletion,
- we will no longer need your personal data for any of the processing purposes, or you will need them to prove, exercise or assert your legal claims,
- you will object to the processing of personal data until the verification period, whether our legitimate interests prevail over your legitimate interests.
V. The right to portability of personal data
If our right to process your personal data is based on your consent or on the fulfillment of obligations arising from the contract, we have concluded with you, you have the right to request the transfer of data relating to you that you have provided to us to another personal data controller.
VI. The right to withdraw consent
If we process your personal data on a legal basis – the consent of the person concerned, you have the right to revoke this consent at any time, even before the expiration of the period for which this consent was granted. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
VII. The right to invalidate automated individual decision-making, including profiling
You have the right to request that automated individual decision-making, including profiling, be ineffective against you.
VIII. The right to object
If you have reasons for doing so related to your specific situation, you have the right to object to the processing of your personal data if the legal basis for such processing is our legitimate interest. However, if our legitimate interest in processing exceeds your personal interest, we may continue to process your data, despite your objection to processing. We are also entitled to continue processing your data, if this is necessary for proving, exercising or defending our legal claims.
Direct marketing (including analyzes carried out for the purposes of direct marketing):
You have the opportunity to object to the processing of your personal data for the purposes of direct marketing. The objection also relates to analyzes of personal data (so-called profiling) that are carried out in connection with direct marketing. If you object to direct marketing, we will stop processing your personal data for this purpose, as well as for the purpose of all types of direct marketing actions.
Of course, you can simply opt out of receiving messages and personal offers on specific channels. For example, you can only receive offers from us by e-mail, but not via SMS messages.
You can change your settings on the website at any time. You can also change your settings via email, SMS or a combination of these.
- Information security
BN Group applies appropriate security measures to protect your personal information, which is under our control, from unauthorized access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers and protected against unauthorized access.
- Internet transmissions
Given that the Internet is a global environment, the use of the Internet to collect and process personal data inevitably involves the transfer of data on an international scale. Although we generally store all personal data that we collect about you through local records, company software, local storage (server), it is possible that your personal data will be transferred to entities outside your region (outside the Slovak Republic), but still within the EU, where EU Regulation 2016/679 applies (for example, for foreign clients in the European Economic Area, etc.). If such a transfer takes place, we ensure that it takes place in accordance with contractual or other measures to protect such personal data obtained.
If you are not satisfied with our answer, or if you believe that we are processing your data illegally, you can complain to the supervisory authority, which is the Personal Data Protection Office of the Slovak Republic. You can find further information about the supervisory body of the Slovak Republic and the procedure for submitting complaints on its official website: www.dataprotection.gov.sk.