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1.1 logicpay AG with its business address at Landstrasse 40, 9495 Triesen, Liechtenstein, registered in
the commercial register of the Commercial Court of Liechtenstein under FL-0002.605.398-9 (hereinafter
referred to as "logicpay AG" or "we"), offers via www.coinary.io (the "Website") services related to
buying and selling digital currencies. This Privacy Policy explains how personal data are processed by
logicpay AG if a person uses logicpay AG's services, the Website or otherwise interacts with logicpay AG
(such person hereinafter called "Customer"). Only persons of legal age are permitted to use the website
and to register to it.
1.2 logicpay AG is the controller and responsible person for the personal data processed via the
Website. logicpay AG is aware that the protection and careful handling of the Customer's personal data
are very important. logicpay AG will solely use the personal data provided by the Customer in compliance
with the applicable data protection requirements, this Privacy Policy and the consent of the Customer.
1.3 The Customer is obliged to keep his personal data correct and up to date.
1.4 The Privacy Policy is drafted in English and in German. In case of conflict the English version
shall be the binding version.
2.1 When using logicpay AG's services or interacting with logicpay AG the following personal data are
processed:
(a) Contact data: e.g. when creating a new user account or communicating with logicpay AG (i.e. name,
address, telephone number, email, birthdate, password in encrypted form) depending on the level of
verification.
(b) Verification data: when an account is verified (i.e. screenshots of national identity documents,
like passport, driving license ID card, and identification data from these documents, utility bill
details for residence verification)
(c) Financial data: in the course of purchase and sale transactions (i.e. bank details payment service
provider information, payment details, transaction-ID).
(d) Log data: during activities on the Website, (i.e. IP-address, transaction data, deposit and
withdrawal address, computer or mobile device information, IP-address, operating system, browser type,
device type, unique device identification number).
(e) Company details if a business account is requested (i.e. commercial register report, data of or
concerning beneficial owners, records or additional information on recent, past or planned business
activities, other data necessary to determine/validate the structure, the beneficial ownership or any
power of attorney of the company).
(f) Details to and proof of funds: i.e. banking statements or any other details provided by banks or
financial institutions, contracts of sales or contracts in general, or any other suitable data to prove
or determine the origin of funds, if exceeding the daily/monthly or general limits on logicpay AG. In
order to determine Customer's purpose for using the above-mentioned services or trading volume
additional information on recent, past or planned business or personal activities of business or private
Customers or other data to determine the Customer’s intentions, if necessary, can be processed, as
requested by logicpay AG or provided by the Customer.
(g) Personal data provided to the support team when the Customer submits a request to logicpay AG's
support team or any other member of the logicpay AG team.
2.2 The personal data are used for the purpose of performing the contract or in order to take steps at
the request of the data subject prior to entering into a contract, verification of the Customer’s
identity, prevention of fraud and misuse, risk management, payment processing and chargebacks, proof of
purchase and selling, comparison during the course of business, to respond to Customer service and
support requests, inform about important updates of logicpay AG's services and terms, and analyse and
improve the website's quality and usage experience. The personal data listed above under 2.1 a), b), c),
d), e), f) and g) are required for entering into and performance of the contract. If Customer fails to
provide such data logicpay AG will not be able to provide its services to the Customer.
The basis for such processing is contract performance compliance with legal obligations to which
logicpay AG is subject and logicpay AG's legitimate interests in measures regarding prevention of fraud
and misuse of its services (e.g. for illegal purposes) and risk management when operating its business
and interacting with Customers . Upon the Customer's prior consent the personal data may be used for
marketing, direct advertisement (see point 5 "Newsletters" below), and Website analysis and improvement
(see point 4 "Cookies" below).
2.3 If logicpay AG will ask to provide any other personal data not described above, then such data and
the purpose and legal basis for the collection and processing, will be communicated to the Customer at
the point of collecting the personal data.
3.1 The Customer agrees, that for the purpose of the identity verification, personal data will be
forwarded
to one of the following verification provider which the Customer choses:
1) IDnow GmbH, Auenstraße 100, 80469 Munich, Germany
2) WEBID SOLUTIONS GMBH, Friedrichstraße 88, 10117 Berlin, Germany.
When selecting a Verification provider, the respective companies are clearly stated as IDNow and WEBID .
Depending on the level of verification the following personal data may be transferred to the chosen
verification provider first name, surname, address, birthdate, email address, telephone number. Only for
the
verification level „Level 3“ the Customer's identity will be checked via a video-identification process.
Without providing the personal data required for the respective level the verification is not possible.
3.2 For purposes of AML (anti-money-laundering) and CFT (Combating the Financing of Terrorism) logicpay
AG
conducts - based on its legitimate interest to prevent fraud and misuse of its services - an examination
of
politically exposed persons and sanctioned persons in the course of the Know-Your-Customer process for
the
level "level 3" only. Therefore, after completion of the video verification for „level 3“ Customer's
name
and date of birth – and in case of opening a company account the company's name and its companies
register
excerpt (including name, address and birth date of its owners, representative bodies, e.g. managing
directors, and authorized proxies contained therein) For further information on the possible results and
consequences of the due diligence process please see logicpay AG's Terms and Conditions.
3.3 In case Customer uses the "logicpay AG support tool" provided by Zendesk Inc, 1019 Market St., San
Francisco, CA 94103, USA, or submitting a support request to "support@logicpay AG.com" Customer's
personal
data (e-mail address, name, IP-address and the additional data submitted directly by the Customer to
handle
the support request) are transferred to and processed by Zendesk, Inc in the USA. Zendesk, Inc is
certified
under the EU/US Privacy Shield. The USA is a country for which an adequate level of data protection has
not
been determined. Subject to local provisions Customer's personal data may be accessed by authorities of
such
country in accordance with local laws and regulations.
3.4 Further, logicpay AG may share the personal data with
(a) third party services providers and partners who provide data processing services to logicpay AG, or
who
otherwise process personal information for purposes that are described in this Privacy Policy or
notified to
Customer. A list of logicpay AG's current service providers and partners is available here:
Bank Frick & Co. AG,Landstrasse 14, 9496 Balzers, Liechtenstein
mPAY24 GmbH, Grüngasse 16, 1050 Vienna, Austria
MASTERPAYMENT GmbH, Petersbrunner Str. 1B, 82319 Starnberg, Deutschland
(b) affiliate marketing partners if Customer registers to the "logicpay AG Affiliate Program". In the
context of the registration Customer is informed about the affiliate partners to whom the personal data
(first name, last name, company name, web URL, address, contact number, email address, and any other
personal data directly transferred to the affiailite partner by the Customer) will be sent. Without the
transfer of the information to the affiliate partner the participation in the affiliate program is not
possible.
(c) to any competent law enforcement body, regulatory, government agency, court or other third party
where
disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or
defend our legal rights, or (iii) to protect your vital interests or those of any other person;
(d) to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger
or
acquisition of any part of logicpay AG's business. The Customer's personal data may be transferred to
the
new owners so that the services may continue to be provided to Customer provided that logicpay AG
informs
the buyer it must use personal data only for the purposes disclosed in this Privacy Policy;
(e) to any other person with Customer's consent to the disclosure.
4.1 During the use of the Website, personal data may be collected through automatic data collection
methods,
such as cookies. Cookies are small data files which are saved to the Customer's computer or device and
allow
an analysis of the Customer’s usage behaviour on the Website. The personal data collected are computer
or
device information, including IP address, operating system, browser type, device type, unique device
identification number, and data which represent the usage behaviour on the Website (e.g. the time spent
on
the Website, which pages were accessed or links clicked). These data are collected by logicpay AG to
analyse
and evaluate the effectiveness of Website and to improve its quality for a better Customer experience.
4.2 Further, logicpay AG uses the services of the data processor Hotjar Limited, in Malta, to analyse
and
better understand Customer's needs and to optimize the Website's service and experience. Hotjar is a
technology service that helps logicpay AG better understand the Website experience (e.g. how much time
user
spend on which pages, which links they choose to click, what users do and don’t like, etc.) enabling to
improve the services. To this end Hotjar's cookies are stored that collect data on the Customers'
Website
behavior and their devices (in particular device's IP address (captured and stored only in anonymized
form),
device screen size, device type (unique device identifiers), browser information, geographic location
(country only), preferred language used to display the Website). Hotjar stores this information in
pseudonymized form. Neither Hotjar nor logicpay AG will use this information to identify individual
users or
to match it with further data on an individual Customer. For further details, please see Hotjar’s
privacy
policy by clicking on this link (https://www.hotjar.com/legal/policies/privacy). Customer can opt-out
from
Hotjar's cookies by following this opt-out link (https://www.hotjar.com/legal/compliance/opt-out).
4.3 Further, logicpay AG uses Google Analytics, a web analytics tool by Google LLC., 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies. The stored information
of
the use of the Website (e.g. pages visited, users activities on Website, time spent on the Website)
which is
generated by the cookies is transmitted and saved on a server by Google in the USA. This Website uses
the IP
anonymization on, whereby the IP address of the Customer is shortened by Google within the European
Union
and the European Economic Area. Only in exceptional cases the whole IP address is first transferred to a
server of Google in the USA and then shortened.
4.4 On behalf of logicpay AG, Google will use this information to evaluate the usage of the Website for
reports about the Website activity and to fulfil further services towards the Website owners concerning
the
activity on the Website and internet. The Customer's IP address acquired from Google Analytics, will not
be
merged with other data from Google.
4.5 By clicking on the "OK"-button in the Website's cookie banner the Customer agrees to the use of
cookies.
The consent can be withdrawn at any time by deleting the cookies form the terminal device and browser
and
adjusting the browser settings; this, however, may compromise the functionality of the Website. The
withdrawal of the consent does not affect the lawfulness of processing based on consent before its
withdrawal.
4.6 The Customer can disable cookies to be saved with specific browser settings; thereby the Customer
might
not be able to use all the offered functions on the Website to their full extent. Furthermore, the
Customer
can disable the collected website specific data (IP address) through cookies to be send and processed by
Google, by downloading and installing the following browser plugin
(http://tools.google.com/dlpage/gaoptout?hl=de).
5.1 Upon Customer's consent his email address, name, last login date, register date will be passed on to UAB "MailerLite", Paupio g. 28, LT-11341 Vilnius, Lithuania in order to receive per email newsletters and information from logicpay AG regarding logicpay AG's events, new products, services and app features.
6.1 logicpay AG erases the Customer's personal data in principal 1 year after termination of the contractual relationship or before if the data is not required for the purpose for which they were collected anymore. A longer retention may be necessary due to guarantee, warranty, statute of limitations (e.g. the limitation period for damages of 3 years or in specific cases the general limitation period of 30 years according to the Liechtenstien General Civil Code) and statutory retention periods (e.g. under commercial or tax law) applicable to logicpay AG, or for the duration of any legal disputes in which the data are required as evidence or for as long as there are other legitimate interests in retention.
7.1 In accordance with applicable law, the Customer has the right to access, correct, request deletion
of
his personal data, to object to the processing of his personal data, and to dataportability of his
personal
data, to request restriction of the processing of his personal data. To exercise these rights the
Customer
can send an email to or a letter to logicpay AG, Landstrasse 40, 9495 Triesen, Liechtenstein. logicpay
AG
does not use personal data for automated decisions support@coinary.io within the meaning of (i.e.
decisions
producing legal effects concerning data subjects, or otherwise significantly affecting them, based
solely on
automated processing of personal data, including profiling).
7.2 The Customer has the right to file a complaint to the competent data protection authority, when he
believes his data protection rights have been violated.
8.1 By checking the respective box as a part of the registration process, the Customer confirms to have
read
the Privacy Policy and agrees to the data processing as described herein.
8.2 Further, by checking the respective separate box the Customer can consent that his email address
name,
last login date, register date will be sent to UAB "MailerLite" in order to receive marketing
communication
as described in point 5 above.
The Customer has the right to withdraw his consents at any time via mail to logicpay AG, Landstrasse 40,
9495 Triesen, Liechtenstein, or via E-Mail to support@coinary.io. The withdrawal of his consent does not
affect the lawfulness of processing based on consent before its withdrawal.
9.1 logicpay AG may update this Privacy Policy from time to time in response to changing legal, technical or business developments. logicpay AG will take appropriate measures to inform the Customer, about the updates, consistent with the significance of the changes. logicpay AG will obtain Customer's consent to any material changes in this Privacy Policy if this is required by applicable data protection laws. The current version of this Privacy Policy is: May 2019.