The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when a purchase order is created, the contact form is used, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.
The collection and use of data from a variety of sources are essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering, and other harmful activity.
2. Data We Collect
a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a customer goes through the verification steps, a Customer makes payments, a person responds to Bitrush emails or surveys. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
- Contact details, such as name, telephone number, email address;
- Financial and Transaction Data, such as credit or debit card number, and bank account information;
- Company Data, such as a company’s legal structure, and company records; and
- Other Personal Data, such as date of birth, citizenship, IP address.
b. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data from a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our website, and the use of our Services generally. Other Data that we may collect include:
- Browser and device data, such as IP address, language, country, referrer URL, and affiliate URL;
- Transaction data, such as purchases, purchase amount, date of purchase, payment method, payout method, cryptocurrency address; and
- Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data.
3. How We Use Data
a. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Customers, and Bitrush; and (iv) promote, analyze and improve our service. Examples of how we may use Personal Data include:
- To verify an identity for compliance purposes;
- To conduct manual or systematic monitoring for fraud and other harmful activity;
- To respond to inquiries, send service notices and provide customer support;
- To process a payment, communicate regarding a payment, and provide related customer service;
- For audits, regulatory purposes, and compliance with industry standards;
- To develop new products;
- To send marketing communications;
- To improve or modify our Services; and
- To conduct aggregate analysis and develop business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of, our business.
b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments.
4. How We Disclose Data
Bitrush values your privacy and we make careful decisions to balance Your privacy and fraud prevention. We aim to prevent your information falling into the hands of third parties. However, we do share Your Personal Data with trusted third parties, including:
a. To Identity Verification Services. We share Data with third-party identity verification services in order to prevent fraud. This allows Bitrush to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services;
b. To Financial Institutions. We share Data with financial institutions that help us deliver the Services. Financial institutions help us with matters such as payment processing (iDEAL, credit card), payout processing (i. e. SEPA, PayPal), and our fraud prevention efforts;
c. To Communication Service Providers. We share Data with communication service providers who help us provide the Services. Communication service providers help solve communication challenges by serving emails and SMS messages on our behalf; and
d. Safety, Legal Purposes, and Law Enforcement. We share Data with law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our terms and conditions.
5. Cryptocurrency Transactions
When using cryptocurrencies you should realize that all cryptocurrency transactions are stored within the blockchain (public ledger) in order to ensure that they are publicly visible and traceable at all times. Cryptocurrency transactions are traceable and in theory can be traced back to Bitrush. However, the owner’s identity cannot be determined on the basis of their cryptocurrency address.
The following data is made publicly available through the blockchain: transaction amount, transaction date, cryptocurrency address, transaction ID.
We may use third-party advertising companies to serve advertisements regarding our service that may be of interest to You when You access our websites, based on Data relating to Your access to and use of our websites on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see.
7. Choice and Access
You have choices regarding our use and disclosure of Your Personal Data:
a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.
b. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by contacting us.
If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request.
8. Retention Period