Privacy Policy

  

COINZOOM UNITED STATES PRIVACY POLICY

The website, http://www.coinzoom.com/, however accessed (the “Site”), is owned and operated by CoinZoom, Inc. and its subsidiaries and affiliates (collectively, “CoinZoom”, “we”, “our”, “us”). The Site has been created to provide a marketplace for buyers and sellers to trade digital currencies (the “Services”) and we provide it to all users of the Site or the Services (“Users,” “you,” “your”), including institutional and retail investors (“investor(s)”). This Privacy Policy sets forth CoinZoom’s privacy practices with respect to information, including personally identifiable data (“Personal Data”), and other information that is collected from Site visitors and Users of the Services on the Site. This Privacy Policy explains how CoinZoom collects and protects your Personal Data. By becoming a user through the Site or by otherwise submitting Personal Data to us on the Site, you give your consent to the collection and use of your Personal Data by CoinZoom as explained in this policy.

 

What Information We Collect

The information we collect varies depending on the type of activity you are performing on our Site or how you use the Services.  At times we will collect personal information from you and in other instances our Site will collect other information in order to deliver our Services or as part of operating this Site.  For example, when you become: (i) an Investor with CoinZoom by completing the account opening process or otherwise submit Personal Data in order to receive Services, e.g., when you make a wire transfer or tell us where to send money; or (ii) an Issuer that issued or is issuing utility coins and wants to list the utility coin through the Site by completing the necessary process and providing the appropriate disclosure of information, we may collect information about you, as further described below:

 

Personal Data That You Provide Through the Site

We collect Personal Data from you when you apply for, access and use products and Services on the Site offered by CoinZoom. This information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions between or among you and our affiliated companies or others. The Personal Data that we collect may include your:

  • name
  • address
  • citizenship
  • telephone number
  • email address
  • Social Security Number
  • date of birth
  • financial related information, including assets, net worth, income, account balances, account transactions, investments and investment experience.

 

Other Information We Collect

When you interact with CoinZoom through the Site or Services, we receive and store certain information about you. Such information, which may be collected passively, may specifically identify you.

When you use our Site, we gather certain other information automatically (“Other Information”) and store it in log files. This information may include Internet Protocol (“IP”) addresses, browser type, Internet Service Provider (“ISP”), referring/exit pages, operating system, date/time stamp and clickstream data.

 

Information We Collect from Third Parties

We may collect information about you from third parties in order to meet certain legal or regulatory requirements and/or to protect against fraud.  In some circumstances, we may obtain information from global terrorist watchlists and/or information about criminal offenses or convictions.

 

How We Use Cookies

In operating this Site, we may also use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features.

 

The use of cookies by any of our affiliates or service providers is not covered by our privacy policy. We do not have access to or control over these cookies. Our partners use session ID cookies to make it easier for you to navigate our Site and use our Services. For more information about how we use cookies, please refer to our Cookie Policy.

 

How We Use Your Information

CoinZoom uses the Personal Data you provide and Other Information in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to respond to your communication. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such Services and to monitor your use of such Services.  In addition, we use your information to provide, analyze, administer, enhance and personalize our Site and Services to you, examples of how we use your information include to:

 

  • Deliver our Services as requested
  • Communicate with you about our Site or Services
  • Provide you with information about goods or services that may interest you
  • Present you with marketing relating to our Services and more relevant display advertisements, and to share promotional events
  • Research and analysis to improve our Site and Services
  • Manage our Services offerings, and assess the effectiveness of our marketing efforts
  • Analyze and improve the content and functionality of our Site and Services
  • Improve our products, services, and business
  • Prevent, detect, or investigate security concerns, including fraud
  • Comply with applicable laws, regulations, or industry requirements
  • Fulfill any other purpose for which your provide it or consent

 

If at any time you wish not to receive any future marketing communications, or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note, however, that as a User of the Service, we will send you administrative communications that are reasonably necessary to the Service, such as billing or service notifications.

 

How We Share and Disclose of Your Personal Data and Other Information

We will share Personal Data and Other Information with third parties in accordance with applicable law and in the ways that are described below:

 

  • If you give us consent or permission to share the information.
  • To those third parties who perform functions on our behalf, including support service providers, such as hosting, email and postal delivery, product and service delivery, analytics services, data maintenance and storage, ID verification, processing applications and payments and completing transactions. When we employ another company to perform a function on our behalf, we only provide them with the information that they need to perform that specific function. These companies are authorized to use your Personal Data only as necessary to provide these services to us.
  • In accordance with a business transaction—if we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, other business transaction, we may share information, including Personal Data, subject to confidentiality arrangements.
  • To prevent, detect, or investigate security concerns, including fraud.
  • To protect and defend our operations, rights, privacy, safety or property, or that of its subsidiaries, affiliates, officers, employees, contractors, agents and/or partners
  • To comply with applicable laws, regulations, or industry requirements.
  • With law enforcement if required by law or in order to prevent fraud or other potential wrongdoing.

 

We do not share your personal information with third parties for their direct marketing purposes.

 

Your California Privacy Rights/ Do Not Track

California residents visiting our Site may request that we not automatically gather and track information pertaining to their online browsing movements across the Internet.  We do not track users through cookies or other tracking technologies across the internet.    Third parties may collect information about you across different websites, including our website.  We do not currently utilize the capability to respond to web browser do not track signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of this information.

 

California Law also permits California residents to opt-out of our disclosure of personal information to third parties for their direct marketing purposes or to learn the categories of recipients and information disclosed.  We do not share your personal information with third parties for their marketing purposes.

 

Your Access to and Control Over Your Information

We enable you to have access to and control over the accuracy of your Personal Data.   You can access, correct, update, amend, delete or request deletion of your Personal Data by emailing our Customer Support at Support@CoinZoom.com or by contacting us at the contact information listed below. We will respond to your request within 30 days.

We will retain your Personal Data for as long as your account is active or as needed to provide you Services. Moreover, we will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Security

The security of your Personal Data is important to us. To protect your Personal Data from unauthorized access and use, we use administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These measures include computer safeguards and secured files and buildings. When you enter sensitive information (such as financial or personal information) on our website, we encrypt the transmission of that information using secure socket layer technology (SSL). We also use third party ID verification to ensure our Users’ true identities are validated.

We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at Support@CoinZoom.com.

 

Children Under 13 Years Old

This Site is not directed to or intended to be used by children under 13 years old.  CoinZoom does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Site.

 

Links to Other Web Sites

This Privacy Policy applies only to the Site. This Site may contain links to other web sites or third party services not operated or controlled by CoinZoom, including social media features, (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from this Site do not imply that CoinZoom endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

 

Changes to CoinZoom's Privacy Policy:

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. The date the Privacy Policy was last revised is identified at the top of the page.  Your continued use of this Site after we email you or indicate that we made changes to the Privacy Policy is deemed to be acceptance of those changes.

 

Contacting CoinZoom:

Please feel free to contact us if you have any questions about CoinZoom's Privacy Policy or the information practices of this Site:

CoinZoom, Inc. Support@CoinZoom.com

4640 S. Holladay Village Plaza, Suite #206, Salt Lake City, Utah 84117

 

COINZOOM AUSTRALIA / GLOBAL PRIVACY POLICY

This Australia / Global Privacy Policy (below) is applicable to CoinZoom users located outside of the United States.  To the extent that the Policy below contradicts the United States Privacy Policy, the terms of this Australia / Global Privacy Policy control for users located outside of the United States.  Additionally, please see the GDPR Addendum (further below) applicable solely and exclusively for users located in the European Union.

The website, http://www.coinzoom.com/ (the “Site”), is owned and operated by CoinZoom, Inc., the parent company of CoinZoom Australia Pty Ltd” and its subsidiaries and other affiliates (collectively, “CoinZoom”, “we”, “our”, “us”).   The Site has been created to provide a marketplace for buyers and sellers to trade digital currencies (the “Services”) and we provide to all users of the Site or the Services (“Users,” “you,” “your”), including institutional and retail investors (“investor(s)”).

This Privacy Policy explains how CoinZoom collects and protects your Personal Information and outlines how it complies with its obligations to manage and protect personal information under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). By becoming a user through the Site or by otherwise submitting Personal Information to us, you give your consent to the collection and use of your Personal Information by CoinZoom as explained in this policy.

In this Policy:

Personal Information means information or an opinion relating to an individual, which can be used to identify that individual.

Sensitive Information is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and includes health information.

What Information We Collect:

When you become: (i) an Investor with CoinZoom by completing the account opening process or otherwise submit Personal Information in order to receive Services, e.g., when you make a wire transfer or tell us where to send money; or (ii) an Issuer that issued or is issuing utility coins and wants to list the utility coin through the Site by completing the necessary process and providing the appropriate disclosure of information, we may collect information about you, as further described below:

Personal Information That You Provide Through the Site: We collect Personal Information from you when you apply for, access and use financial (and related) products and Services offered by CoinZoom whether in person, by telephone or by providing information to us in hard copy or electronic form.  We may verify this information or get additional information from consumer or investigative reporting agencies, credit reporting agencies or public sources.  This information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions between or among you and our affiliated companies or others.  The Personal Information that we collect may include your name, address, citizenship, telephone number, email address, and date of birth, as well as details about your professional affiliations, assets, net worth, income, account balances, account transactions, investments and investment experience.  In addition, Web tools are used on our Site to help us monitor traffic patterns and to see how the User navigates through our Site, including using cookies.

By voluntarily providing us with Personal Information and by using the Site, you are consenting to our use of your Personal Information in accordance with this Privacy Policy.  If you provide Personal Information, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of CoinZoom and the authorized third parties referred to herein, including those that are in the United States.

Non-Identifiable or Aggregated Information: When you interact with CoinZoom through the Site or Services, we receive and store certain information about you.  Such information, which may be collected passively, may specifically identify you.

As is true of most web sites, we gather certain information automatically and store it in log files.  This information may include Internet Protocol (“IP”) addresses, browser type, Internet Service Provider (“ISP”), referring/exit pages, operating system, date/time stamp and clickstream data.  CoinZoom may store such information itself or such information may be included in databases owned and maintained by CoinZoom’s affiliates, agents or service providers, including those located in the United States and other locations outside Australia such as Amazon Web Services and Identity Mind.  This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ internet service providers, and how our users use and interact with the Services.  Furthermore, in an ongoing effort to better understand and serve the users of the Services, CoinZoom often conducts research on its customers’ demographics, interests and behavior based on the Personal Information and other information provided to CoinZoom by Users.

This research may be compiled and analyzed on an aggregate basis. CoinZoom may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally.  CoinZoom may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

In operating this Site, we may also use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Information except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.  We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features.

The use of cookies by any of our affiliates or service providers is not covered by our privacy policy. We do not have access to or control over these cookies. Our partners use session ID cookies to make it easier for you to navigate our Site and use our Services.

 

How We Use Your Information:

CoinZoom uses the Personal Information you provide in a manner that is consistent with this Privacy Policy.  If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided.  For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or resolve your problem.  Also, if you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide you with access to such Services and to monitor your use of such Services.  We also may obtain information about you from third party sources to verify your identity, so we can properly process your requests, comply with our obligations under anti-money laundering and counter-terrorism financing law and prevent fraud.  By accessing our Site and using our Services, you hereby explicitly consent and agree that we may use your submitted Personal Information for such purposes.

We may also use your Personal Information and other personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to better understand our Users and to improve the Services.  CoinZoom may use this information to communicate with you regarding the Services or to tell you about Services we believe will be of interest to you.  If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.  Note, however, that as a User of the Service, we will send you administrative communications that are reasonably necessary to the Service, such as billing or service notifications.  If CoinZoom intends on using any Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to such actual use.  CoinZoom may only use or disclose your Sensitive Information for direct marketing if you consent to the use or disclosure of the information for that purpose.

If the personal information we request is not provided, we may not be able to provide you with our services or meet your needs appropriately. CoinZoom does not give individuals the option of dealing with us anonymously, or under a pseudonym, because doing so is impractical and would breach CoinZoom’s legal obligations under anti-money laundering and counter-terrorism financing laws.

Our Disclosure of Your Personal Information and Other Information:

We will share personal and other information with third parties only in the ways that are described in this privacy policy.  We consider this information to be a vital part of our relationship with you.  There are, however, certain circumstances in which we may share your Personal Information and other information with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Related Companies: CoinZoom may also share your Personal Information with its subsidiaries and other affiliates for purposes consistent with this Privacy Policy, including those located in the United States.

Agents, Consultants, Service Providers and Related Third Parties: CoinZoom, like many businesses, may hire other companies to perform certain business-related functions.  Examples of such functions include mailing information, maintaining databases, ID verification, processing applications, shipping and fulfillment, processing payments and completing transactions.  When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.  These companies are authorized to use your Personal Information only as necessary to provide these services to us.

Legal Requirements: CoinZoom may disclose your Personal Information if we believe that disclosure is required by applicable law, rules, or regulations to (i) cooperate with law enforcement or regulatory or self-regulatory organizations, (ii) comply with a legal obligation, (iii) protect and defend the rights or property of CoinZoom, (iv) act in urgent circumstances to protect the personal safety of users of the Site or the public against fraud or other harm, (v) enforce our customer and other agreements, or (vi) protect against legal liability.

Overseas recipients: CoinZoom may disclose your Personal Information to entities located overseas, including (i) our related bodies corporate located in the United States; (ii) data hosting and IT service providers; and (iii) other third parties, including those located in the United States. We take reasonable steps to ensure that overseas recipients of personal information do not breach the privacy obligations relating to your personal information.

Your Personal Information:

If your Personal Information changes, or if you no longer desire our Service, you may correct, update, amend, delete or request deletion by emailing our Customer Support at Support@CoinZoom.com or by contacting us at the contact information listed below.  We will respond to your request within 30 days.

We will retain your Personal Information for as long as your account is active or as needed to provide you Services.  Moreover, we will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about Services we believe will be of interest to you.  Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at Support@CoinZoom.com.

Security:

The security of your Personal Information is important to us.  To protect your Personal Information from unauthorized access and use, we use security measures that comply the Privacy Act the APPs.  These measures include computer safeguards and secured files and buildings.  When you enter sensitive information (such as financial or personal information) on our website, we encrypt the transmission of that information using secure socket layer technology (SSL).  We also use third party ID verification to ensure our Users’ true identities are validated.

We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee its absolute security.  If you have any questions about security on our Site, you can contact us at Support@CoinZoom.com.

Unsolicited information:

CoinZoom may receive unsolicited personal information about individuals. CoinZoom’s employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy all unsolicited personal information.

 

Social Media Features:

Our Site includes Social Media Features such as Like, Follow, Share, and Twitter button.  These Features are interactive mini-programs and may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly.  Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site.  Your interactions with these Features are governed by the privacy policy of the company providing it. Personal Information we collect from your use of these features we be managed in accordance with this Privacy Policy.

Links to Other Web Sites:

This Privacy Policy applies only to the Site.  This Site may contain links to other web sites not operated or controlled by CoinZoom (the "Third Party Sites").  The policies and procedures we describe here do not apply to the Third Party Sites.  The links from this Site do not imply that CoinZoom endorses or has reviewed the Third-Party Sites.  We suggest contacting those sites directly for information on their privacy policies.

Other Terms and Conditions:

Your access to and use of this Site is subject to the Terms of Use.

Changes to CoinZoom's Privacy Policy:

We may update this privacy policy to reflect changes to our information practices.  Any updated version of this Policy will be posted on our website.  We encourage you to periodically review this page for the latest information on our privacy practices.

Access to Personal Information:

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information which CoinZoom holds about you by contacting the CoinZoom Privacy Officer.  If we refuse to provide the information to you, we will provide reasons for the refusal, including any exceptions relied upon under the Privacy Act.

Complaints handling:

If you would like to make a complaint about the treatment or handling of your personal information, you can lodge a complaint with the CoinZoom Privacy Officer using the details listed below under the heading “Contacting CoinZoom”.  All complaints will be handled in accordance with our complaints handling process which involves (i) identifying (and addressing) any systematic/ongoing compliance problems; (ii) increasing consumer confidence in our privacy procedures; and (iii) helping to build and preserve our reputation and business.

If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner:

1300 363 992

Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001

Enquiries@oaic.gov.au

 

Contacting CoinZoom:

Please feel free to contact us if you have any questions or concerns about CoinZoom's Privacy Policy, our handling of your Personal Information or the information practices of this Site:

CoinZoom, Inc.

Support@CoinZoom.com

4640 S. Holladay Village Plaza, Suite #206, Salt Lake City, Utah 84117

 

 

 

COINZOOM GDPR ADDENDUM

Definitions

GDPR means the General Data Protection Regulation.

Responsible Person means

Charles A. Christofilis, Acting Data Privacy Officer.

Register of Systems means a register of all systems or contexts in which personal data is processed by CoinZoom.

  1. Data protection principles

CoinZoom is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
  7. General provisions
  8. This policy applies to all personal data processed by CoinZoom for users located in the European Union.
  9. The Responsible Person shall take responsibility for CoinZoom’s ongoing compliance with this policy.
  10. This policy shall be reviewed at least annually.
  11. CoinZoom shall register with the Information Commissioner’s Office as an organization that processes personal data.
  12. Lawful, fair and transparent processing
  13. To ensure its processing of data is lawful, fair and transparent, CoinZoom shall maintain a Register of Systems.
  14. The Register of Systems shall be reviewed at least annually.
  15. Individuals have the right to access their personal data and any such requests made to CoinZoom shall be dealt with in a timely manner.
  16. Lawful purposes
  17. All data processed by CoinZoom must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
  18. CoinZoom shall note the appropriate lawful basis in the Register of Systems.
  19. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  20. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in CoinZoom’s systems.
  21. Data minimization
  22. CoinZoom shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  23. Accuracy
  24. CoinZoom shall take reasonable steps to ensure personal data is accurate.
  25. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
  26. Archiving / removal
  27. To ensure that personal data is kept for no longer than necessary, CoinZoom shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  28. The archiving policy shall consider what data should/must be retained, for how long, and why.
  29. Security
  30. CoinZoom shall ensure that personal data is stored securely using modern software that is kept up to date.
  31. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
  32. When personal data is deleted this should be done safely such that the data is irrecoverable.
  33. Appropriate back-up and disaster recovery solutions shall be in place.
  34. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, CoinZoom shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office (ICO), the independent regulatory office in charge of upholding information rights in the interest of the public.

 

END OF POLICY