Version dated 01.12.2024
READ THIS PRIVACY POLICY CAREFULLY. BY USING OR ACCESSING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY ALL OF THE TERMS OF THIS PRIVACY POLICY AND OUR USER AGREEMENT. DO NOT USE THIS PLATFORM IF YOU DO NOT ACCEPT THIS PRIVACY POLICY (AND/OR ANY CHANGES, MODIFICATIONS, ADDITIONS, AND/OR AMENDMENTS TO IT). IN THE EVENT OF A CONFLICT BETWEEN THIS VERSION AND ITS TRANSLATIONS (IF APPLICABLE), THE ENGLISH VERSION SHALL PREVAIL.
This Privacy Policy (the “POLICY”) is part of the YOURHODL User Agreement (the “User Agreement”). Unless otherwise specified, terms used in this POLICY have the same meanings as in the User Agreement.
1. INTRODUCTION
1.1 This Policy applies to the YOURHODL PLATFORM, including but not limited to the website https://yourhodl.market/, its subdomains, and related mobile applications (in particular iOS, Android, and Microsoft applications) (“PLATFORM”).
1.2 By accessing or using the PLATFORM, you agree that you have read, understood, and agree to comply with the POLICY, User Agreement, Return Policy, and Cookie Policy posted on the PLATFORM.
1.3 If you do not agree with any part of the Policy, please do not use the platform. If you do not understand the terms of the Policy or have any questions about its contents, please get in touch with us at support@yourhodl.market.
1.4 We may revise the POLICY without prior notice by posting the revised version on PLATFORM (such revisions are not retroactive). By continuing to use PLATFORM, you confirm that you accept such changes.
1.5 This Policy defines how YOURHODL will process information collected from PLATFORM users (from now on referred to as ‘USER’ or ‘you’).
1.6. Personal data in this POLICY means information relating to an identified or identifiable natural person; an identifiable natural person is a person who can be identified directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.7 Processing of Personal Data means an operation or set of operations performed on Personal Data or sets of Personal Data, with or without the use of automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.8 This POLICY is an integral part of the User Agreement (as may be revised from time to time) about the operation of the PLATFORM published on the PLATFORM.
2. GENERAL PROVISIONS
2.1 By using this PLATFORM, the USER acknowledges acceptance of this POLICY. The USER has the right to withdraw their consent at any time; however, in some cases, this may prevent them from interacting with the PLATFORM. Such withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
2.2 USERS may visit the PLATFORM anonymously.
2.3 The personal data we collect allows us to contact you regarding the latest YOUHODL services, product announcements, software updates, and other relevant information.
2.4 By accepting this POLICY, you consent to receive marketing communications from us or our partners or third parties related to this PLATFORM via email, SMS, or push notifications (or other forms of written communication), which you may opt out of at any time by contacting us.
2.5 Before allowing you to use PLATFORM and where required by applicable law, we may require you to provide additional information to verify your identity and address. We may also obtain information about you from third parties, such as identity verification services.
2.6 We are not obligated to accept you as a counterparty, including as a user, and it may only be possible to cooperate with you once all Know Your Customer and Anti-Money Laundering documentation required by applicable law is adequately executed and received. We reserve the right to reject your payments of any nature until all the necessary documentation, adequately executed and duly signed, is received.
2.7 We may share your data with our partners or contractors to provide services to you. Accepting this POLICY allows us to share your data with our partners. For example, external payment service providers may process your transactions. We may disclose your data to one or more of these payment service providers through APIs and/or other integration methods so that they can connect your account to their services. Each payment service provider will act as a data controller concerning the data we share with it and may provide you with a copy of its privacy policy that will govern that third party’s use of your data.
2.8. you irrevocably declare:
- That you have read, understood, found acceptable, and fully accept this POLICY;
- That you confirm you freely, clearly, expressly, and unambiguously give your consent to the processing of personal data;
- You are familiar with other legal documents published on PLATFORM and risk warnings and disclosures provided in any form and accept them as an integral part of this POLICY.
3. PRIVACY NOTICE
3.1 Generally, we may only collect necessary information and will not share your data with third parties unless otherwise stated in this POLICY.
3.2 We may collect the following data and information sent to us by your computer, cell phone, or other access device:
3.2.1. information provided by you, including information sent through PLATFORM (including but not limited to personal data such as your name, address, phone number, email address);
3.2.2. information provided by other companies that have obtained your authorization to share information about you with third parties (including personal data);
3.2.3. information about your interaction with advertising and services such as registration, comments;
3.2.4. information we collect (or may collect) through cookies;
3.2.5. your IP address;
3.2.6. emails or other communications sent by USERS within the PLATFORM;
3.2.7. information about the location of the device when accessing and using the PLATFORM;
3.2.8. information about the device, including but not limited to identifier, name and type, operating system, and other technical information about the users of the means of access to PLATFORM;
3.2.9 Other profile information includes personal pages, gender, age, and mobile number.
3.3 We may ask you to provide information that we, in our sole discretion, deem necessary to comply with applicable laws, regulations, and/or policies. You must provide such information if you intend to continue using PLATFORM and/or obtain new services or features within PLATFORM (i.e., in the absence of such information, further use of PLATFORM will not be possible).
3.4 We may collect and use information about USERS (including personal data) for the following purposes:
3.4.1. to provide services through PLATFORM;
3.4.2. to improve YOURHODL’s services;
3.4.3. to develop a commercial version of our PLATFORM and YOURHODL services;
3.4.4. to promote the development of YOURHODL services (if necessary in the future);
3.4.5. to communicate with the USER;
3.4.6. to communicate with external networks and platforms;
3.4.7. for registration and authentication;
3.4.8. for payment processing;
3.4.9. for infrastructure monitoring;
3.4.10. for contact management and messaging;
3.4.11. for analytics;
3.4.12. for the protection of the PLATFORM and USERS;
3.4.13. for interaction with support and feedback platforms;
3.4.14. to manage support requests and contacts;
3.4.15. to manage the USER database;
3.4.16. for the launch, maintenance, and operation of the PLATFORM (including the provision of services);
3.5. suppose we intend to process your data for purposes other than those in subparagraph 3.4. In that case, we will inform you of such processing and your right to consent to processing personal data.
3.6 We will process your data for the purposes set out in subparagraph 3.4.
3.7. The collection and processing will be carried out within the framework of the PLATFORM.
3.8. Personal data may be freely provided by the USER or, in the case of data usage, automatically collected when using the PLATFORM.
3.9. We do not trade, sell, or rent users’ data to other parties.
3.10. We may share aggregated information other than personal data about visitors and USERS with business partners, trusted partners, and advertisers.
3.11. We may disclose USER personal information if we believe that such disclosure is necessary:
3.11.1. To comply with legal requirements or to respond to a subpoena, search warrant, or other legal process obtained by us, whether or not applicable law requires a response;
3.11.2. for legal purposes in a court of law or stages leading to potential legal actions arising out of improper use of PLATFORMA or related services;
3.11.3. for the disclosure of personal data at the request of public authorities;
3.11.4. to protect our rights; or
3.11.5. to protect the safety of members of the public and USERS of the service and/or PLATFORM.
3.12. by giving us consent to process personal data, you grant us the right to share your data (to the extent necessary for disclosure) with:
3.12.1. our banking partners;
3.12.2. Other USERS – only for the purposes and to the extent necessary for the normal use or operation of YOURHODL services (including for ratings, reviews, and similar purposes) related to the commercial use of YOURHODL services;
3.12.3. third parties, including our subsidiaries and affiliates, which we may engage from time to time to preserve, analyze, or otherwise store or process data collected from USERS;
3.12.4. organizations with which we plan to merge or be acquired;
3.12.5. providers of identity verification services for fraud prevention purposes;
3.12.6. law enforcement agencies, government officials, or other third parties when we believe in good faith that disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of legal documents published on PLATFORM;
3.12.7. by other third parties only with your prior consent or direction.
3.13. We reserve the right to transfer personal data to an assignee who has acquired such rights due to our selling assets to that assignee.
4. STORAGE AND TRANSFER OF DATA
4.1 We process personal data transparent, fair, and lawfully.
4.2 At YOURHODL, only a limited group of employees involved in KYC and identity verification can access USER’s data. In some cases, data (including USER personal data) may be available to specific categories of persons responsible for the operation of the PLATFORM (administration, sales, marketing, legal department, system administrators) or to external parties (such as third-party technical service providers, email services, hosting providers, IT companies, communication agencies) with whom we work.
4.3 We will only collect personal data from USERS if they voluntarily provide us with such information. By submitting your data, you consent to its transfer (including cross-border transfer), storage, or processing.
4.4 We and third parties engaged by us to store and process your data store and process your data on servers that host our respective facilities or those of our service providers. YOURHODL or such providers may operate in countries where laws on the processing of personal data are less stringent than in your country. We ensure that your data will only be stored or processed in countries that provide adequate protection for the rights of personal data subjects.
4.5 While we cannot guarantee that data loss, misuse, or alteration will not occur, we make every effort to prevent such occurrences.
4.6 Any other susceptible information (e.g., credit card numbers collected for commercial transactions) is encrypted before being passed to us by the USER.
4.7 We retain data for the time necessary to provide the services requested by the USER or specified for the purposes set out herein, and the USER may always request that we suspend or delete the data
4.8 We confirm that personal data is processed to ensure appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical and organizational measures strictly necessary to process personal data.
4.9 In some cases, we may be obliged to compare the personal data provided by the USER with third-party databases to verify its accuracy and confirm the USER’s identity by applicable regulatory requirements.
4.10. USERS have the right to find out at any time whether their data has been stored and may contact us for information about the content, origin, and other information relating to its processing.
5. POLICY CHANGES
5.1 We may make changes to this POLICY from time to time. If we make changes, we will post them on the PLATFORM to notify USERS.
5.2 After YOURHODL posts the changes to the Policy, the USER must accept and agree to them when using the platform.
5.3 Your continued use of the PLATFORM (including simple access and browsing) means you accept and agree to any changes made to this POLICY.
5.4 You acknowledge and agree to review the POLICY periodically and familiarize yourself with any changes that may occur.
5.5. We will notify you of any changes and additions to this Privacy Policy via pop-ups and/or notices on this PLATFORM.
6. YOUR RIGHTS.
6.1 You have the right to obtain confirmation as to whether YOURHODL is processing your data and, if so, access the personal data and the following information:
6.1.1. the purposes of the processing;
6.1.2. the categories of personal data that YOURHODL processes;
6.1.3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
6.1.4. where possible, YOURHODL will keep the personal data for the estimated period or, if this is not possible, will use criteria to determine this period;
6.1.5. the existence of the right to request us to rectify or erase personal data or to restrict processing of personal data concerning the data subject, or to object to such processing;
6.1.6. of the right to complain with a supervisory authority;
6.1.7. if YOURHODL has not collected the personal data from the data subject, it will provide any available information about its source;
6.1.8. the availability of automated decision-making.
6.2 You have the right to obtain the rectification of your inaccurate personal data without undue delay.
6.3 Given the purposes of the processing, you have the right to supplement incomplete personal data, including by submitting an additional statement.
6.4 You have the right to request that we delete your data without undue delay if one of the following grounds applies:
6.4.1. the personal data is no longer necessary in connection with the purposes for which it was collected or otherwise processed;
6.4.2. you withdraw your consent, which forms the basis for the processing, and there is no other lawful basis for the processing;
6.4.3. you object to the processing by clause 6.7, and there is no overriding lawful basis for the processing, or you object to the processing by clause 6.8;
6.4.4. YOURHODL has processed the personal data unlawfully;
6.4.5. YOURHODL must erase the personal data to comply with a legal obligation under applicable law;
6.5. you have the right to request restriction of processing in one of the following cases:
6.5.1. you dispute the accuracy of the personal data for a period that allows us to verify the accuracy of the personal data;
6.5.2. the processing is unlawful, and you object to the erasure of personal data and instead request restriction of its use;
6.5.3. we no longer need the personal data for processing, but you need it for the establishment, exercise, or defense of legal claims;
6.5.4. you object to the processing by clause 6.7 until YOURHODL verifies whether our legitimate grounds override yours.
6.6. You have the right to receive your data provided to us in a structured, commonly used, and machine-readable format and to transfer this personal data to another data subject.
6.7 You have the right to object at any time to the processing of your data where such processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority and for legitimate interests pursued by us or a third party, unless your interests or fundamental rights and freedoms override such interests, requiring the protection of personal data.
6.8 Where we process personal data for direct advertising purposes, you have the right to object to processing your data for such advertising.
6.9 You can complain to the relevant data protection or supervisory authority.
7. YOUR RESPONSIBILITIES
7.1 You are responsible for the security of login information, such as usernames and passwords, which gives you access to your personal information held by us.
7.2 Ensure you keep your login information secure and not share it with others.
7.3 Please note that keyloggers, viruses, or other surveillance devices may intercept login information on computers from which you access PLATFORM, so you should take precautions against such devices, especially on public computers.
7.4 USERS are responsible for any third-party personal data received, published, or transmitted through PLATFORM and confirm that they have the third party’s consent to provide us with this personal data. You now indemnify us against any loss and/or damage that may arise if you fail to obtain the relevant consent.
8. CHILD PROTECTION
If you are under 18, you may not use the PLATFORM and YOURHODL services. We do not knowingly solicit or collect information from anyone under 18. If we learn someone under 18 has provided us with personal information, we will delete it immediately.
9. CONTACT INFORMATION
If you have any questions, comments, requests, or complaints regarding this Policy or other PLATFORM materials, please get in touch with our support team at support@yourhodl.market.
*Third-party service providers must handle such data with the same level of care as we do and are strictly prohibited from disclosing it to others except as outlined in this Policy.
