Privacy Policy

INTRODUCTION

This Privacy Policy governs the privacy of the users (“you”, “your”, “customer”, “user”) of the Stage Point Europe Website (“Website”) operated by us, Stage Point Europe s.r.o., registered under Czech Republic law, identification number 222 1 594, with the registered address: VIkova 532/8, Zizkov, 130 00 Prague 3, Czech Republic (“Company”, “we”, “us” or “our”), which is Data Controller and is responsible for the processing of your Personal Data.

This Privacy Policy defines what Personal Data is collected and how it is used, processed, stored, and managed by us, in accordance with applicable legislation, while you access or use our Website, our products (“Product”), and/or services (“Services”).

Before reading this Privacy Policy, we recommend that you thoroughly read our User Agreement to gain a thorough understanding of the terms and conditions that govern the use of our Website, Products, and/or Services.

This Privacy Policy also serves as a privacy notice, informing you about why and how we collect and manage your Personal Data.

If you use our Products and/or Services, you acknowledge that you have read and understood all of the terms and guidelines. By using our Products and/or Services, you expressly agree to this Privacy Policy and expressly consent to and agree to the processing of your Personal Data as set forth herein. Consent provided by you under this Privacy Policy must be explicit, informed, and given voluntarily. Such consent is treated as equivalent to written consent.

This Privacy Policy is governed, construed, interpreted, and enforced in accordance with the laws of the European Union and the Czech Republic. If any term of this Privacy Policy is found to be inapplicable or unenforceable under the law, it will have no effect on the application or enforceability of the remaining elements of this Privacy Policy. If you do not agree with this Privacy Policy, you should immediately stop using our Website, Products and/or Services.

We reserve the right to change, vary, and revise this Privacy Policy whenever lawfully required or in light of marketing, commercial, technological, or other upgrades, or as we deem necessary, in accordance with relevant legislation. Unless clearly specified differently, such revised or updated versions will take effect as of the publishing date. By using our Website, Products, and/or Services, you agree to and accept the terms of this Privacy Policy, including its modifications. If you do not agree with any revision, alteration, or update, you must discontinue using our Website, Products, and/or Services.

The Website or application programming interface necessary to access Products and Services may contain links to third-party websites, plug-ins, and apps. Clicking on those links or activating those connections may allow third parties to collect and share data about you. We have no control over these third party sites and are not responsible for their privacy statements and policies.

We only use Personal Data for the purposes outlined in our Privacy Policy. We only transfer your Personal Data to other parties if it is necessary, as described below.

PERSONAL DATA THAT COULD BE COLLECTED BY US

Depending on whether and how you use our Products, Services, and Website, we will collect, use, store, and transfer various types of your Personal Data, which are divided into the following categories.

Category of Personal Data

Types of Data

Identity Data

Email address, first name, last name, date of birth, etc.

Identity documents (national identity cards, passport, driving license or other forms of identification documents), proof of address documentation, occupation, employment industry, financial standing.

Confirmation that you are a director, board member, employee, representative, or an owner or an ultimate beneficial owner etc. of a company being our customer, information on the ownership and control structure of a customer.

Please note that we may also ask you to prove ownership or control of a particular blockchain address. We are required to ask for this information to comply with Anti-Money Laundering (“AML”), Counter-Terrorism Financing (“CTF”) requirements, and to ensure we safeguard against and report any suspicious activity.

Biometrics

Photo, video, audio of Personal Data subject, other biometric identifiers and/or biometric information of Personal Data subject

Social identity data and Preference Data

Data on referrals to you, close connections, preferences, interests, favorites, risk assessment, compliance evaluation, work address, and groups.

Your marketing and communication preferences, survey replies, and connections with others whose Personal Data we may collect or store.

Verification Data

Personal Data which we collect for the purpose of conducting customer due diligence under applicable AML/CTF laws, photo, direct video transmission recording.

Background Data

We collect Personal Data available in open source.

Transactions data

Data regarding your crypto-assets exchange, staking, transfer transactions, transactions activity logs, billing, crypto-assets and settlement details obtained by us when you use our Products and/or Services; exchange orders details, history; other details of any transactions you enter into using the Website, our Products and/or Services.

Technical Data

Domain and host from which you access the Internet, operator and carrier data, your computers or other usable devices IP address, device type, category and model, web browser type and the operating system software, unique IDs of your devices, time zone setting, location data, language data, operating system and platform, diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other data.

Profile Data

Your username and password, login data, your identification number as our customer, requests by you for Products and/or Services, communication between us and you.

Marketing and Communication data

Your preferences in receiving marketing from us or third parties, communication between us and you, your survey responses, voice record of communication between you and us.

This data is not exhaustive and is intended solely to offer a general overview of the potential use of the data obtained. We will maintain detailed records of the data collected, along with the specific purposes for which such data is processed, in compliance with applicable legal and regulatory requirements..

It may be impracticable to deal with you on an anonymous basis or using a pseudonym.
Please be noted, that if you directly disclose your Personal Data, or sensitive Personal Data (such as, among others, racial or ethnic origin, political opinions, religious beliefs, physical or mental health, membership in any organizations, etc.), through public features, this information may be collected and used by other persons.

We consider certain categories of Personal Data, such as racial or ethnic origin, political opinions, religious beliefs, and health data, to be special categories of personal data under GDPR. Such data requires additional safeguards (“Sensitive Data”). We will only collect, use, store, and transfer your Sensitive Data solely if there is a legal requirement and at least one of the following conditions are met:

consent: you have given consent to the processing of your Sensitive Data;
information made public by you: the Sensitive Data has become public as a result of your actions;
legal proceedings: the processing is necessary for the purpose of, or in connection with, any legal proceedings, for obtaining legal advice, or is otherwise necessary for establishing, exercising, or defending legal rights;
public functions: the processing is necessary for the exercise of any functions conferred on any person by or under an enactment.

PERSONAL DATA PROCESSING PURPOSES

For the purposes of the applicable law, we as Data Controller of your Personal Data must securely retain any data submitted by you to us and/or received by us otherwise. We may use your Personal Data, for the following purposes:

Purpose

Details

Contractual Purpose

to register you at our Website, to enter into, perform contract and deliver our Products, Services properly (which may include disclosure to relevant third parties as defined by us); to process and deliver our Products, Services and any Website, features to you, including to execute, manage and process any instructions or orders you make; to manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to us;

Analytical Purpose

to collect general and particular statistics of Website use, activities of customers, for sending communications, notices, updates, surveys; for customer service support and ancillary purposes; to collect statistics regarding use of our Website concerning visits and activities of customers, potential customers on our Website, including analytics services such as Google Analytics, etc. (this analysis helps us run our Website more efficiently and improve and personalize customer's online experience), to keep our records updated and to study how customers use our Products and Services;

Marketing and Advertising Purpose

to send you welcome email following registration procedures; to send you occasionally our Products, Services updates; to contact you for surveys purposes (you do not have to respond to such surveys); for other marketing purpose; to advertise our Products, Services to you and understand the effectiveness of the advertising we serve to you. We could use your Personal Data and decide which Products, Services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications.

Compliance Purpose

to maintain accuracy of our records; to verify your Personal Data for the purpose of managing our customer relationships and observing the Know Your Client (“KYC”) rules; to comply with legal and regulatory obligations with respect to AML/CTF, prevention of criminal activity and lawfully protect our legal interests, make relevant risk assessments and management; to use the services of financial institutions, crime and fraud prevention companies, risk measuring companies; background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and resolving them;

Communication Purpose

to contact a customer for administrative purposes such as customer service, address technical or legal issues related to the Products, Services provided, or share updates and notifications about the Products, Services. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about specific grounds for Personal Data processing by us, please contact us.

We will only use your Personal Data for the purposes for which it was collected. If we need to use it for another purpose, we will ensure that the new purpose is compatible with the original purpose and is based on a valid legal ground under GDPR. If you need an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unconnected reason, we will tell you and explain the legal basis for doing so.

We may also need to process your Personal Data in connection with or during the negotiation of any merger, financing, acquisition, business transfer, assignment, bankruptcy, dissolution, transaction, or procedure involving all or a portion of our shares, company, or assets. This will be based on our legitimate interests in carrying out the transaction or meeting our legal responsibilities.

We retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

SOURCE OF OBTAINING YOUR PERSONAL DATA

From you when you provide your Personal Data for identification, verification, and KYC purposes;
From you when you visit our Website and/or use our Products, Services;
From you when you enter into a contract with us;
From you when you submit any requests, complaints, or emails to us;
From financial institutions, other entities;
From registers;
From our partners, such as identification/verification vendors;
From other sources.

We use different methods to collect information from and about you, including through:

Direct collection. You may provide us with Personal Data by directly communicating with us, such as by filling out forms, uploading a visual image of yourself to the service, sending an email, or otherwise. This includes Personal Data you supply when you apply for Services or Products, visit our Website, use our Services or Products, provide feedback or contact us, respond to advertisements sent to you, or participate in a poll, including through social media channels. We also collect Personal Data when we provide assistance or support to customers or potential customers regarding our Products or Services.
Automated technologies. When you connect with us through our Website, we will automatically collect your Personal Data. We collect this Personal Data using cookies, server logs, and other methods. Though such information is not submitted by a customer, it relates to you and is considered Personal Data under Article 4(1) of the GDPR. It has two subtypes: 1) Static (once created, this information usually remains constant. For example, an internal user id. 2) dynamic (this subtype fluctuates depending on the activities you conduct).
Publicly available sources or indirectly collected Personal Data. We also obtain information about you from third parties or publicly available sources, or when a customer does not provide it directly (e.g., an IP address).

LEGAL BASIS FOR PERSONAL DATA PROCESSING

Processing is necessary for the entry into or performance of a contract between you and us (GDPR article 6 (1) (b)), for performance of the contract to which our customer is a party. We are processing Personal Data for contractual and communication purposes, for entering into or for performing a contract (User Agreement) entered into between us and you;
Processing is necessary for compliance with a legal obligation to which we are subject (GDPR article 6 (1) (c)), for compliance with a legal obligation to which we are subject, including, but not limited to, AML and CFT requirements;
Processing is necessary for the purposes of the legitimate interests pursued by us (GDPR article 6 (1) (f)). We are processing Personal Data for purposes set forth above under legitimate interest. As part of this, we must maintain and develop our Website, technical systems and IT-infrastructure, technical and organizational solutions that may also use your Personal Data, in order to provide you with adequate Products, Services. We also process your Personal Data for protection of your or another person vital interests;
A consent to the processing of Personal Data (GDPR article 6 (1) (a)). We are processing Personal Data for marketing purpose under customer’s consent, meaning freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of Personal Data relating to you;
another basis prescribed by the law.

PERSONAL DATA THAT COULD BE COLLECTED BY US

Data security is extremely important to us, and we organize and implement all necessary and relevant procedures and technology to safeguard and secure your Personal Data collected by us. Security measures are implemented to protect Personal Data from involuntary or unauthorized processing, disclosure, or destruction.

Depending on the nature of the risks presented by the proposed processing of your Personal Data, we will have in place the following appropriate security measures:

organizational measures (including but not limited to personnel training and policy development);
technical measures (including but not limited to physical protection of data, encryption);
securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of Personal Data are held).

Unless we are required or permitted by law to do so, and subject to our relevant third-party business relationships (our partners, service providers, contractors, agents, financial institutions, social media etc.), we will not disclose your Personal Data to any irrelevant third parties for security purposes.
We also restrict access to Personal Data to just those personnel, contractors, advisors, and auditors who need it to perform their job or service tasks. Personal Data is only accessible to our personnel and contractors that require it for their work. We conduct periodic evaluations to verify that appropriate information processing rules and procedures are understood and followed. All of our physical, electronic, and procedural precautions are intended to follow applicable laws and regulations.
To utilize all of the features and functions of our Website, you may be asked to submit certain Personal Data, including your password(s). You are responsible for keeping your password(s) confidential and secure.
While we strive to protect your Personal Data, please keep in mind that the transfer of any information over the Internet is not completely secure and is done at your own risk and discretion. We cannot, therefore, guarantee the security of your Personal Data transmission to our Website when it is outside our reasonable control.

You undertake to notify us immediately of any unauthorized access or use of your account, or any other breach of security, via e-mail: [email protected], , and we will notify you in the event of a data breach, which can result in severe personal health and financial damages.
While there is an inherent risk in sharing data over the Internet, we have implemented suitable security measures to protect your Personal Data from being mistakenly lost, used, damaged, or accessed in an unauthorized or unlawful manner, altered, or disclosed.

PERSONAL DATA SUBJECT RIGHTS

We need to make you aware of your rights. The rights you have depend on the reason we are processing your Personal Data.

Right to Access (GDPR, Article 15) – right to ask us to provide a copy of user’s Personal Data which we process, access to your Personal Data, which enables you to obtain confirmation of whether we are processing your Personal Data. You have the right to request the following additional information concerning your Personal Data:
- the purposes of the processing;
- the categories of Personal Data concerned;
- the recipient(s) or category(ies) of recipient to whom/which Personal Data have been or will be disclosed;
- the criteria determining the period for which Personal Data will be stored etc.
Right to Rectification (GDPR, Article 16) – user has the right to ask us to rectify Personal Data in case the data is incorrect or incomplete.
Right to Erasure (GDPR, Article 17) (sometimes called Right-to-be-forgotten) - user has the right to ask us to erase Personal Data, unless we are is obliged to continue processing a user’s Personal Data under law or under a contract between the user and us, or in case we have other lawful grounds for the continued processing of Personal Data.
- You may amend or remove any portion of your Personal Data at any time by using Website interface, or contacting or emailing us at [email protected] Such amendment or removal of certain Personal Data may lead to limiting or cessation of your access to Services, Products.
- Your Personal Data will not be erased immediately; it will be stored at our facility to comply with statutory obligations, including GDPR regulations, AML and CFT requirements. As required by the AML and CFT requirements, we must store any collected information within a fixed term from relationship termination. This period may be further extended in certain cases if so provided by and in accordance with the applicable legislation. Biometrics is processed and stored so long as the other Personal Data as set forth in this Privacy Policy. Your Personal Data will be removed from our records after this period has passed.
Right to Restriction (GDPR, Article 18) – user has the right to ask us to restrict the processing of the Personal Data in case the data is incorrect or incomplete or in case their Personal Data is processed unlawfully.
- Upon amendment or removal of your Personal Data, it is archived and safekept separately from processed Personal Data. Such restricted Personal Data is processed purely for storing purposes and cannot be accessed automatically or by unauthorized personnel. Restricted data may only be used or restored only in select ways prescribed by law or legal proceeding. Upon expiry of storage term, restricted Personal Data is deleted.
- Your Personal Data is stored for as long as their storage is required for appropriate purposes for the processing of Personal Data, as well as in accordance with the applicable laws. Personal Data may be stored in an electronic form and/or in paper format, provided always that your Personal Data will be stored securely and protected against unauthorized or unlawful processing and against loss or destruction, using appropriate technical and organizational measures. When assessing the length of the storage of Personal Data, we take into account existing regulatory requirements, aspects of contractual performance, your instructions, and our legitimate interests. If your Personal Data is no longer needed for the purposes specified, we will delete them or destroy.
Information Availability (GDPR, Article 19) – you have the right to receive Personal Data concerning you provided to us, in a structured, commonly used and machine-readable format. We are obliged and have provided all the information which you have right to receive.
Right to Data Portability(GDPR, Article 20) – user has the right to ask us to provide the user or, in case it is technically feasible, a third party, her/his/its Personal Data, which the user has provided to us and which is processed in accordance with the user’s consent or a contract between the user and us. Note that this right only applies to the automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to Object (GDPR, Article 21) – user has the right to object to processing her/his/its Personal Data in case there is a reason to believe that we have no lawful grounds for processing the Personal Data and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.
Right to Withdraw Consent for Data Processing (GDPR, Article 7) – user is entitled to withdraw the consent granted for the processing of Personal Data at any time. Withdrawal does not affect the lawfulness of the processing conducted before the withdrawal. If you withdraw your consent, we may not be able to provide certain Services, Products to you, but we will advise you if this is the case at the time you withdraw your consent.
Right to File a Complaint – user has the right to file complaints regarding his/her/its Personal Data. In addition, user has a right to lodge a complaint with the respective supervisory body.

TRANSFER OF PERSONAL DATA TO THIRD PARTIES

We may transfer your Personal Data to the following third parties:

Regulatory authorities to whom we are obligated to disclose your Personal Data under the law, AML and CFT requirements; agencies that deal with law enforcement; entities in cases of fraud or collusion prevention, identity verification, payment processing, credit reference; banks/financial institutions; courts.
Our related entities, personnel, officers, agents, contractors, designated representatives, and other companies that provide services to us.
Third parties to satisfy the purposes for which the information was collected or for another purpose, if that other purpose is closely related to the primary purpose of collection and a natural person would reasonably expect us to disclose the information for that secondary purpose.
Third parties who help us analyze the information we collect to administer, support, improve, or develop our business and services.
Identification and verification service providers engaged by us for your verification and performance of AML and CFT requirements, as well as other software service providers who assist us in providing products and services.
Our professional advisers, such as consultants, bankers, professional indemnity insurers, brokers, and auditors, to meet regulatory obligations and improve our business.
Server hosts that store our data and communication service providers that help us stay in touch with you.
Third parties in the blockchain and fintech industry, marketing, and advertising sectors, to inform you about products and services that may interest you in accordance with GDPR.
Banking and financial service providers.
Debt recovery agencies that assist with recovering debts owed to us.
Entities facilitating the sale of all or a substantial part of our assets or business, potential merger companies, or companies proposing to acquire us and their advisers.
Other third parties whose services or facilities we use to provide products and services, ensure website operation, and comply with internal procedures and legal requirements.

We have taken steps to guarantee that third parties which process your Personal Data have appropriate technological and organizational safeguards in place to secure this Personal Data, and we will also ensure that they are GDPR compliant. We have taken precautions to guarantee that third parties contracted by us preserve the confidentiality and security of Personal Data, and that Personal Data is handled exclusively for the purposes set forth in this Privacy Policy.

Personal Data shall not be processed (or cause to be processed) in a country that has not been designated by the European Commission as providing an adequate level of data protection unless it has put in place such measures as are necessary to ensure such transfer is in compliance with personal data protection laws, except where otherwise required by applicable law. However, when collected Personal Data is transferred outside of the EEA, we must guarantee that the appropriate safeguards, such as standard contractual clauses and data processing agreements, are in place.

On our Website, we include or may include references or links to third-party websites. External links can be clickable text, banners, or picture connections to other websites, with no restrictions. We have no control over outbound websites and are not responsible for their content, terms of service, or policies. This Privacy Policy applies only to this Website and does not cover your use of other websites, including those of our partners and service providers, social media, and so on. We recommend that you review the privacy policies of other websites before using them.

PERSONAL DATA USE IN COMMUNICATION AND MARKETING

We may contact you via phone, email, SMS, or push notification to advise you about current and new Products and Services that may be of interest to you.

We shall guarantee that any email we send as marketing conforms with the GDPR and includes an 'unsubscribe' button so that you may opt out of any future marketing communications. You can deny marketing messages delivered via push notifications by declining the applicable permission in your phone or tablet settings, but this will prevent you from receiving further messages from us via push notification. You may also opt out of receiving marketing communications from us by using the contact information provided below.

You can also contact us and request that your information be removed from our marketing list. We will make every effort to remove your information from our marketing list within a reasonable time frame.

Our marketing list may be managed by software and servers located overseas, and your Personal Data may be transported overseas as part of our marketing efforts.

We will also send communications that are required or necessary to send to users of our Website that contain information about important changes or developments to or the operation of the Website or as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.

PERSONAL DATA USE IN COMMUNICATION AND MARKETING

HOW LONG DO WE STORE PERSONAL DATA

We store Personal Data within the term of its processing by us, third parties engaged by us for Services, Products providing, and additionally 10 after termination of a business relationship with the customer, other cases set forth in the law, unless longer term is required by the applicable law.

COMPLAINTS AND REQUESTS

If you have any queries in relation to this Privacy Policy, you wish to access or correct the Personal Data we hold about you, or make a complaint, please contact us at:

Email: [email protected] (our Data Protection Officer)

We aim to acknowledge receipt of all privacy complaints from you within 5 working days and resolve all complaints within 30 business days. Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay as well as advising the time by which we expect to resolve the complaint.

In order to disclose information to you in response to a request for access we may require you to provide us with certain information to verify your identity. GDPR may prescribe exceptions which may affect your right to access your Personal Data.

If you believe that there has been a breach of GDPR, we invite you to contact us as soon as possible.

If we become aware of a security breach, we may seek to notify you electronically so that you can take appropriate preventive measures. If a security breach occurs, we may make a notice on the Website.

When Personal Data breach is anticipated to result in a high risk to customers, your rights and freedoms, we will inform you.

If you are not satisfied with our handling of a complaint or the outcome of a complaint you have the right to lodge a complaint with an appropriate authority:

The Personal Data Protection Office

Phone

+420 234 665 800 (GDPR infoline)
+420 234 665 111 (Phone)

WWW:

http://www.uoou.cz

E-mail:

[email protected]

Address:

The Office for Personal Data Protection
Pplk. Sochora 27
170 00 Praha 7
Czech Republic

Should we lawfully receive your Personal Data from a third party, you will have the same rights regarding information in question as related to information you provided to us directly or we have collected during cooperation with you.

Our Website uses Cookies (“Cookies”), small text files saved to your computer or device in order to customize and improve your experience while visiting and using our Website, according to our Cookies Policy. Our Website uses a Cookies choice reservation allowing you to accept/enable or refuse/disable the use and saving of our Cookies on your computer or another usable device.

You can read more about Cookies by visiting our Cookies Policy.

CHANGES TO PRIVACY POLICY

Our Privacy Policy is reviewed and updated on a regular basis to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into account, as well as that it remains abreast of the changing regulatory environment. Any Personal Data we store will be subject to our most recent Privacy Policy.

If we decide to update our Privacy Policy, we will post those changes here and other places we deem necessary.

DEFINITIONS

The following terms has the meaning as defined below:

Data Controller of your Personal Data means a legal entity that determines the purposes, conditions and manner of any processing activities that it carries out.
GDPR means the General Data Protection 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, as amended, replaced, or superseded and in force from time to time, and as transposed into member-state legislation.
Personal Data means any information which relates to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).

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