Date of Last Revision: 24 May 2018
The security of your Personal Information is essential to us. VinChain has safeguards set up to ensure the security of your Personal Information with us. This policy describes how we may collect, use, disclose, process and manage Personal Information.
PERSONAL INFORMATION WE COLLECT
Section 326 of the USA PATRIOT ACT requires all financial institutions to obtain, verify, and record Personal Information that identifies each person who opens an account. This federal requirement applies to all new customers. This Personal Information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities. What this means for you: when you open an account, we ask you for your name, address, date of birth, and other identifying Personal Information.
In addition, we are a global company and thus may conduct business and collect Personal Information from individuals and institutions located within the European Economic Area (“EEA”). We are required to protect Personal Information processed in the EEA in accordance with the General Data Protection Regulation (“GDPR”). To understand more about how we protect the data we collect from individuals and institutions located within the EEA, please see the “Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the EEA” section below.
Personal Information we collect may include the following:
Individual Customer - We attempt to collect, verify, and authenticate the following:
Mobile phone number;
Full legal name;
Date of birth (“DOB”);
Proof of identity (e.g., driver’s license, passport or government-issued ID);
Home address (not a mailing address or P.O. Box); and
Additional Personal Information or documentation at the discretion of our Compliance Team.
Institutional Customer - We attempt to collect, verify, and authenticate the following:
Institution legal name;
Employer Identification Number (“EIN”) or any comparable identification number issued by a government;
Full legal name (of all account signatories and beneficial owners);
Email address (of all account signatories);
Mobile phone number (of all account signatories);
Address (principal place of business and/or other physical location);
Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument, or other comparable legal documents as applicable);
Contract information of owners, principals, and executive management (as applicable);
Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more of the institutional customer entity, as well as all account signatories; and
Personal Information for each entity beneficial owner that owns 10% or more of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Information we collect for individuals).
You will be allowed to access, review, correct, and ensure the accuracy of the Personal Information you have provided from time to time. We will also do our part to ensure the accuracy of your Personal Information.
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the EEA, your Personal Information will not be retained without your consent.
HOW WE USE AND SHARE PERSONAL INFORMATION WE COLLECT
We may use Personal Information that we collect on an aggregate or de-identified basis for various business purposes, where permissible under the applicable laws and regulations.
We will ask the User’s separate consent before using the collected Personal Information for purposes that are not listed herein.
We store the collected Personal Information for as long as it is necessary to provide Services to you. We for the most part store Personal Information on your transactions for five years. Personal Information associated with your account will be kept until the point when your record is erased unless we no longer need the data to provide Services.
Disclosing Your Personal Information
We will not sell or trade your Personal Information unless we provide you with advance notice. We may share Personal Information about you as follows:
With current and future VinChain partners, affiliates, subsidiaries, and other companies under common control and ownership in the course of delivering our Services to you;
With affiliates, consultants, and other service providers when we trust it will improve the Services and products we can give to you, or for legal and routine business reasons, so long as those parties agree to keep this information confidential
We may also release information when its release is appropriate to comply with the law, enforce our Website policies, or protect our or others' rights, property or safety. This does not include website hosting partners and other parties who assist us in operating our
Website, conducting our business, or serving our users;
With your consent or at your direction.
We may also share aggregated or de-identified Personal Information, which cannot reasonably be used to identify you.
CHILDREN UNDER THE AGE OF 18
VinChain Services are not intended or directed at individuals under the age of 18. Therefore, individuals under the age of 18 may not create an account or otherwise access or use the Services.
ACCESS, CORRECTION, AND DELETION OF PERSONAL INFORMATION
You have the right to ascertain whether we hold your accurate and current Personal Information, to obtain a copy of your Personal Information that you submitted as permitted by law, and to correct any of your data that is inaccurate. You may also request that we inform you of the type of Personal Information we hold with regard to you, subject to restrictions on our providing copies of certain data pursuant to our obligations under BSA and AML regulations and/or data provided to our legal counsel in defense of a claim against us. You may also request that we delete your Personal Information, subject to the restrictions on data deletion pursuant to relevant data retention and destruction restrictions under applicable laws and regulations, such as those related to the BSA and AML. For data access, correction, or deletion requests, please contact firstname.lastname@example.org.
When handling a data access, correction, or deletion request, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you. We will provide you with an opportunity to opt-in to such communications and will only send them to you if you consent.
We will not provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent.
CHANGES TO THE PRIVATE POLICY
We may revise this arrangement every once in a while to guarantee that this policy is reliable with any improvements to the way VinChain uses your Personal Information. IT can also be amended to be aligned with any progressions to the laws and controls pertinent to VinChain. In the event that we do, we will let you know by appropriate means, such as by posting the revised policy on our Website with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise.
We provide you with access to your Personal Information. You may update or delete Personal Information at any time at your own discretion. We won't keep outdated or deleted Personal Information unless we have to do so for legitimate business purposes or in accordance with legislative or regulatory requirements.
WHAT ARE COOKIES
Email that you provide for us will be used for notifying about product development updates only.
PRIVACY STATEMENT FOR DATA SUBJECTS WHOSE PERSONAL INFORMATION MAY BE COLLECTED IN OR FROM THE EEA
While customers who are located in the EEA are customers of our US entity, we recognize and, to the extent applicable to us, adhere to relevant EEA data protection laws.
COLLECTION AND TRANSFER OF DATA OUTSIDE THE EEA
As outlined above, we may collect Personal Information from Data Subjects located in the EEA. To facilitate the services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Information from the EEA to the US. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use VINchain and our services. You will have the ability to withdraw Digital Assets and fiat currency; however, all other functionality will be disabled.
LAWFUL GROUNDS TO PROCESS AND OBTAIN CONSENT
We process the Personal Information of Data Subjects who are located in the EEA for one or more of several lawful purposes, including:
With your explicit consent:
To provide you with VINchain and our services, including customer service support;
To optimize and enhance VINchain for all customers or for you specifically;
To comply with legal obligations:
To conduct anti-fraud and identity verification and authentication checks (you authorize us to share your Personal Information with our third-party service providers, who may also conduct their own searches of publicly available Personal Information about you);
For our legitimate business purposes:
To monitor the usage of VINchain, conduct automated and manual security checks of our service, to protect our rights and perform our lawful obligations.
Data Subjects in the EEA may withdraw consent at any time where consent is the lawful basis for processing their Personal Information. Should a Data Subject withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, a Data Subject may be unable to avail him or herself of the services we provide.
We do not engage in automated decision-making.
NON-DISCLOSURE OF PERSONAL INFORMATION
Our employees are prohibited, either during or after their employment, from disclosing Personal Information to any person or entity outside of our company, including family members, except under the circumstances described above. An employee is only permitted to disclose the Personal Information of a customer to such other employees who need access to such information in order to deliver our services to that customer.
OUR CONTACT INFORMATION FOR PERSONS LOCATED WITHIN THE EEA
If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your Personal Information, you may contact us at: email@example.com.
If, as an EEA Citizen, you believe that we have not adequately resolved any such issues, you have the right contact the EU supervisory authority.
Hopefully, that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not, it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information, then you can contact us through one of our preferred contact methods.
If any of your information that we hold is incorrect, you can change it by contacting us at firstname.lastname@example.org