Privacy Policy

    This Privacy Policy (also referred as ‘Policy’) constitutes the Agreement between Binaryx Protocol DAO LLC (hereinafter also referred as the ‘Company’) and User to set out rules under which we can operate with Your personal data in order to provide You with our Services. The Company takes Your personal data security and privacy seriously and we do all actions to ensure transparency and high-security level in processing your personal information. You must understand that using our Services is inevitably lead to acceptance of our Terms of Service, Anti-Money Laundering and Terrorist Financing Policy,  Cookie Policy and this Privacy Policy. Together these documents are the rules which thoroughly describe requirements, processes, risks and details of the Services, obligations and rights of the Company and You. Please, read all documents carefully, and if you fully or partly disagree with any of them, leave our Website and stop using any of our Services. If you have any questions regarding this Policy, other Policies, or any part of them, please, contact us at [email protected]
     DISCLAIMER: The Company will do as much as possible to help you with all issues, questions and complaints, but we need time to examine your request and do actions to respond to it. Company needs enough time, but no more than one calendar month to solve your problem. If you are dissatisfied with our response or measures we take, you have the right to send the complaint to competent authorities:
  1. For Users from the European Union.
  2. For Users from California, US.

LEGISLATION BASE

To ensure that all rights and obligations in this Policy are developed under the law, and to provide you with a high level of data processing, different legislation. Our relations undergo rules of following jurisdictions:
  1. If you are a Californian resident — California Consumer Privacy Act (CCPA).
  2. For all Users except mentioned above — General Data Protection Regulation (GDPR).
DISCLAIMER: We DO NOT provide our Services for Customers from the USA and Canada. Canadian and Californian legislation were mentioned only to inform you that you have such rights related to some types of data that we may collect unintentionally by Cookies. You can read more about Cookies in our Cookie Policy.

Rights of the User

Under the GDPR, User has the following rights related to his personal information:
  • Right to be informed: Your right to be informed is met by the provision of this privacy notice, and similar information when we communicate with you directly – at the point of contact.
  • Right of access: You have the right to obtain a copy of personal data that we hold about you and other information specified in the GDPR, although there are exceptions to what we are obliged to disclose.
  • Right to rectification: You have the right to ask us to rectify any inaccurate data that we hold about you.
  • Right to erasure (‘right to be forgotten’): You have the right to request that we erase personal data about you that we hold. This is not an absolute right, and depending on the legal basis that applies, we may have overriding legitimate grounds to continue to process the data.
  • Right to restriction of processing: You have the right to request that we restrict processing of personal data about you that we hold. You can ask us to do this for example where you contest the accuracy of the data.
  • Right to data portability: This right is only available where the legal basis for processing under the GDPR is consent, or for the purposes of a contract between you and the Company. For this to apply the data must be held in electronic form. The right is to be provided with the data in a commonly used electronic format.
  • Rights in relation to automated individual decision-making including profiling: You have the right to object to being subject to a decision based solely on automated processing, including profiling. Should we perform any automated decision-making, we will record this in our privacy notice, and ensure that you have an opportunity to request that the decision involves personal consideration. 
  • Right to complain to the Information Commissioner: You have the right to complain to the Information Commissioner if you are not satisfied with any aspect of how the Company processes your personal data or believe that we are not meeting our responsibilities as a data controller. 
     Please note that mentioned rights are not absolute and may be limited in order to complete regulatory requirements and Company`s legal interest. If you have any questions about rights above, please contact us at [email protected]
     Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.

Rights of the User under the CCPA (only for California residents)

     According to the California Consumer Privacy Act of 2018 (CCPA), User who is a California resident can exercise the list of right related to their private data, including:
  • The right to know about the personal information of Users the Company collects about them and how it is used and shared, which means that you may request that the Company disclose to you what personal information they have collected, used, shared, or sold about you, and why they collected, used, shared, or sold that information. Specifically, you may request that businesses disclose:
        a. The categories of personal information collected
        b. Specific pieces of personal information collected
        c. The categories of sources from which the business collected personal information   
        d. The purposes for which the business uses the personal information
        e. The categories of third parties with whom the business shares the personal information

        The categories of information that the Company sells or discloses to third parties. The Company will  provide you this information for the 12-month period preceding your request and  free of charge.
  • The right to delete personal information collected from You (with some exceptions);
        a. You may request that we delete personal information we collected from you and to tell our service providers to do the same. However, there are many exceptions that allow us to keep your personal information.
  • The right to opt-out of the sale of your personal information;
        a. You may request the Company stop selling your personal information (“opt-out”). With some exceptions, Company cannot sell your personal information after we receive your opt-out request unless you later provide authorization allowing us to do so again. The Company must wait at least 12 months before asking you to opt back into the sale of your personal information.
  • The right to non-discrimination for exercising your CCPA rights.

Types of Data We Collect

    According to our Anti Money Laundering and Counter Terrorist Financing Policy, during the Due Diligence Processes and to serve you in a most appropriate way, avoiding technical and legal obsticles, we will need further data from you in order to provide you with our services:
  • full name (full legal name), email address, home address (registered or business address), date of birth and gender, nationality, phone number;
  • documents national identity cards, passports, driving licenses or other forms of identification documents, tax ID number, visa information, utility bills, proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners, and/or any other documents deemed necessary to comply with our legal obligations under financial or anti-money laundering laws;
  • transaction history, and/or tax identification, source of funds and related documentation, other information that is needed to complete CDD procedures;
  • address of your wallet;
  • nature and details of employment;  
  • the customer’s source of funds, i.e. where the funds or assets that will be used for the business relationship or transaction were derived (e.g. income, business profits, investments, dividends, inheritance, property sale, business sale, etc.);  
  • the customer’s source of wealth, i.e. how the customer derived his or her or its wealth, particularly in higher risk scenarios (e.g. income, business profits, investments, dividends; inheritance, property sale, business sale, etc.) and level of wealth (i.e. the total value of a applicant for business’ or customer’s wealth);  
  • data, whether the customer has a criminal record or is a known associate of criminals or criminal organizations; and  
  • whether the customer is a PEP. 
  • chat messages with Customer Support, chat attachments which may include screenshots, photos, videos etc., survey responses.
  • data, whether the customer has a criminal record or is a known associate of criminals or criminal organizations; and  
    Please, take into account that the volume of documents which include information about the types of data mentioned above, will be determined depending on results of  our risk assessment before entering into business relationships with You.
Please take into account, in case of rejecting Company’s request on receiving additional information from Customer, Company may not provide Customer with Services. As Company adds new features and Services, Customers may be asked to provide additional information.
    Also, the Company collects some sort of information automatically while you are using our Services and interacting with our Website to the extent permitted by applicable legislation. This information can be set in following categories:
  • Usage data: information about how you use the Website and Services, and other offerings made available by us, including:
        - device download time,
        - install time,
        - interaction type and time,
        - event time, name and source.
  • Marketing data: your preferences in receiving marketing from us or third parties.
  • Online Identifiers: geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
    We may also automatically receive and record the following information on our server logs:
  • how you came to our Website and use the Services;
  • device type and unique device identification numbers;
  • device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
  • how your device interacts with our Website and Services, including pages accessed and links clicked;
  • broad geographic location (e.g. country or city-level location); and
  • other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
  • chat messages with Customer Support, chat attachments which may include screenshots, photos, videos etc., survey responses.
  • data, whether the customer has a criminal record or is a known associate of criminals or criminal organizations; and  

Ways of Gathering Personal Data

    Usually, User personally provide us with their data by directly interacting with Company via: 
  • visiting our Website or Services;
  • applying for our Services;
  • creating an account;
  • making use of any of our Services;
  • requesting marketing to be sent to User, for example by subscribing to Company’s newsletters;
  • giving us feedback or contact us.
     We will also use third parties and/or publicly available sources to obtain data related to you. We may use the following sources:
  • fraud and crime prevention agencies;
  • publicly available information on the Internet;
  • public blockchain.

Data Processing

     In order to process your data as fast as we can, we have the right to use services of third parties. The Third Party in this case will be Sum And Substance Ltd (UK) (“SumSub”). SumSub is a trusted partner of the Company for collecting and processing Customers data on behalf of the Company (please, follow the link to learn more about them). SumSub is an experienced identity verification company that will process data of Customers for the purposes of the necessary KYC/AML procedures.
     In order to serve You and your counteragent in a most appropriate way, we can use services of, who are responsible for legal, economic and property checking (real estate agents and other parties, which conduct such expertise) in order to eliminate any chances of decisive behavior between parties of a future property contract. Company is not responsible for the ways of processing your data by real estate agents and other specialists. To avoid legal dispute between You and the Company, please, check their Privacy Policies.
     Company keeps your personal data for as long as it remains necessary for the identified purpose or as required by applicable law, which may extend beyond the termination of our relationship with you. The Company may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. 

Disclosure

     Company may share User’s personal data with third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates in order to complete tasks and provide the Services to User on Company’s behalf. 
     Company may share your personal data with: 
  • companies that we plan to merge with or be acquired by (should such a combination occur, we will notify you and will require that the newly combined entity follow this Privacy Policy with respect to your personal data);
  • 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 Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;
  • identity verification agencies to undertake required verification checks;
  • fraud or crime prevention agencies to help fight against crimes including fraud, money-laundering and terrorist financing;
  • our vendors and agents, hired by us to provide you with the Services;
  • transaction processors (for the purpose of ensuring transaction performance and their operation).
     Our Website may, from time to time, contain links to and from the website of our partner networks, advertisers, transaction processors, etc. If you follow a link to any of these websites, please note that these websites that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any information, including personal data that may be collected through these websites, such as contact and location data. Please check these policies before you submit any information or personal data to these Website/Apps or use these Services.

Changes

    Company reserves the right to modify this Privacy Policy at any time. All Changes will be shown on our Website, which will be indicated by changing the date at the top of this page. If you do not accept a new edition of the Privacy Policy, you must stop using the Website and Services.
    In case of including material changes to this Policy, Users will be asked to agree with new terms of this Policy in order to let the Company provide its Services. If User disagrees to accept a new version of Policy, they shall immediately stop using Company’s Services.