Privacy & Cookies Notice
Who we are
Information we collect and for what purpose
We gather various types of Personal Information from our users and Site visitors, and we use this Personal Information internally for a variety of purposes, including but not limited to business reasons, marketing, Site maintenance and statistics, and research and product development.
- Information you provide – when you interact with our Site you may voluntarily provide us with Personal Information, such as your name (including business entity name), date of birth, postal address, email address, phone number, physical location and trading activity. You may provide this Personal Information to us when you contact us, create an account with us, inquire about careers with us, or request information about our Site. You may provide this Personal Information to us directly or through third-party identity verification services or social media. We may also request and collect additional documentation to support and verify the Personal Information you provide, including: identification documents such as passports, drivers’ licenses or national identification cards; official letters and statements proving place of residence; and self-portrait photographs.
- Do Not Track – our Site does not respond to Do Not Track signals communicated by your browser.
How we collect information
To the extent permissible under applicable Data Protection Laws, we collect information about you and any other party whose details you provide to us when you:
- Access or use our Site;
- Create an account with our Site;
- Complete online forms (including call back requests), take part in surveys, post on any forums, download information such as white papers or other publications or participate in any other interactive areas that appear within our Site;
- Interact with us using social media;
- Provide your contact details to us when registering to use or access any services we make available or when you update those details; and
- Contact us or otherwise connect with us, online or offline.
We will also collect your information where you only partially complete and/or abandon any information inputted into our Site and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We may also collect information from your devices (including mobile devices) and applications you or your users use to access and use our Site (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your Internet Protocol (IP) address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described in the following Section below).
How we use your information
To the extent permissible under Data Protection Laws, we use your information to:
- Provide any information or services that you have requested or ordered;
- Compare information for accuracy and to verify it with third parties;
- Provide, maintain, protect and improve our Site;
- Manage, monitor, and administer your use of the Site and provide an enhanced, personal, user experience;
- Manage our relationship with you (for example, customer services and technical support activities);
- Undertake internal testing of our Site or systems to test and improve their security and performance (in these circumstances, we would de-identify any information used for such testing purposes);
- Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
- Comply with applicable Know Your Customer and Anti-Money Laundering regulations;
- Detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- Contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
- Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual);
- Deliver advertising, marketing (including in-product messaging) or information which may be useful to you; and
- Deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers).
In addition to the commercial uses listed above, we may be required to provide any and all of your Personal Information to governmental authorities as necessary to comply with the law. To the extent required by Data Protection Laws, or where we have a legitimate and lawful purpose for doing so, we retain information about you after your withdrawal of funds from the Site, the closure of your account, if your application for an account is declined or if you decide not to proceed with the application.
Our Site may contain technology that enables us to:
- Check specific information from your device or systems directly relevant to your use of the websites, applications or Site against our records to make sure the Site services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- Obtain information relating to any technical errors or other issues with our Site;
- Collect information about how you use the features of our Site; and
- Gather statistical information about the operating system and environment from which you access our Site.
In addition to the purposes described in this Section “How we use your information”, we may also use information we gather to deliver targeted and interest-based advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Site or any other information we have about you (depending on the Site, you may able to configure these features to suit your preferences). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, and/or the DAA’s resources. You may adjust your ad preferences through your social media settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting Your Ad Choices and downloading the mobile AppChoices app.
We use the following different types of cookies:
- Strictly necessary cookies – these cookies are needed for our Site to function properly, for example, these cookies allow you to access secure areas of our Site. Performance cookies and analytics technologies – these non-identifying cookies collect statistics about how visitors interact with our Site, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or Site.
- Functionality cookies – these cookies allow our Site to remember choices you make (such as your username, language or region) and allow us to provide enhanced personalized features.
- Targeting or advertising cookies – these cookies are used to deliver adverts tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. They are usually placed by advertising networks with our permission.
- IP Address and traffic data – we keep a record of traffic data which is logged automatically by our servers, such as your IP address, device information, the website that you visited before ours and the website you visit after leaving our Site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
How we use mobile data
How we use blockchain addresses & blockchain data
We use public Ethereum and Tron Network addresses to identify a user’s journey through our product. We group and analyse these user journeys collectively in order to improve our product user experience. We do not use this data for any purpose at an individual user level.
The legal basis for this processing is that it is necessary to fulfil a contract with you, as well as our legitimate interests, such as monitoring and improving the Site and the proper protection of the Site against risks.
Note that we are not responsible for your use of the Ethereum blockchain and/or the Tron Network and your data processed in these decentralized and permissionless networks.
How we share your information
We intend to keep your data and information confidential, in compliance with our legal obligations. We may share your information with, where permitted by applicable law:
- Our corporate family, affiliates and subsidiaries;
- Our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organizations we engage to help us send communications to you);
- Partners, including system implementers, resellers, value-added resellers, independent software vendors and developers; Third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
- Third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third-party application providers);
- Third parties for marketing purposes;
- Third party credit reference and fraud prevention agencies;
- Third parties to enforce our legal rights and satisfy our legal obligations, including without limitation any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others;
- Third parties to comply with the rules, regulations and guidelines of the payment networks in which transactions are processed;
- Our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- Third parties to transfer information and/or assets in the event of a joint venture, collaboration, financing, merger, acquisition, sale, bankruptcy filing, change of legal form or other corporate restructuring;
- Another organization to whom we may transfer our agreement with you; and
Legal basis for processing in the EU
In the EU, we collect your personal data for the following purposes:
Where necessary to perform any contract we enter into, or have entered into, with you to provide services or access to our Site; Where necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; and Where we need to comply with a legal or regulatory obligation in the EU. If you require details about the specific legal basis we are relying on to process your personal data please contact us at support@toobemi .com.
How we store and protect your information
We will endeavor to keep your information secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We will take commercially reasonable steps to protect your Personal Information but we cannot guarantee the security of your information which is transmitted to our Site or to other website, applications and Site via an internet or similar connection.
If you believe your account has been compromised, please contact us at firstname.lastname@example.org.
You may provide us with instructions on what to do with your Personal Information. Users have choices and control over their Personal Information. Where we need to collect Personal Information and you fail to provide that data when requested, we may have to close your account and/or block your access to the Site. Since your choices and instructions may result in loss of access to the Site and services, please review your options carefully.
If you have any questions about your Personal Information, our use of this Personal Information, or your rights when it comes to any of the foregoing, contact us at email@example.com.
Your rights in respect to your Personal Information if you are located in the EU or Switzerland
If you are located in the EU or Switzerland, you have the following rights in respect to the Personal Information that we hold:
- Right of access – the right to obtain access to your personal data;
- Right to rectification – the right to obtain rectification of your Personal Information without undue delay where the data is inaccurate or incomplete;
- Right to erasure – the right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the data is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction – the right to restrict data processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;
- Right to portability – the right to portability allows you to move, copy or transfer Personal Information easily from one organization to another; and,
- Right to object – you have a right to object to data processing based on legitimate interests and direct marketing.
- Right to withdraw consent – you have a right to withdraw your consent to our processing your data. If you exercise this right, we may not be able to provide services to you. If you wish to exercise one of these rights, please contact us at firstname.lastname@example.org and we will respond within 30 days of the request. If you request access to your personal data, we will provide all information to you by email in addition to context regarding data use. If you request erasure of your personal data, we will respond with a confirmation of erasure by email within 30 days of the request. If your request is deemed unfounded and/or excessive, under the GDPR we retain the right to refuse to respond to the request or to charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. If we refuse to respond, or charge a reasonable fee, we will provide our reasons for doing so. If you are not satisfied with the reasons, you may complain to the relevant supervisory authority, the Information Commissioners Office.
If you feel your Personal Information has been inappropriately handled, you can lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at European Commission.
In addition, the browser you use may provide the ability to control cookies or other types of local data storage. We does not control these choices, or default settings, which are offered by makers of your browser.
If you have any queries about how we treat your information, the contents of this notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please email us at email@example.com, subject line: “Data protection officer” in the subject header.