Introduction

1.1 At FIXATI, we are dedicated to protecting the privacy of our website visitors and service users.
1.2 This policy applies when we act as a data controller for the personal data of our website visitors and service users. It pertains to situations where we determine the purposes and means of processing such personal data.
1.3 Cookies are used on our website. For cookies that are not strictly necessary for the provision of our website and services, we will ask for your consent when you first visit our website.
1.4 In this policy, "we," "us," and "our" refer to FIXATI.

How we use your personal data

2.1 This Section 2 outlines:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases for the processing.
2.2 We may process data about your use of our website and services ("usage data"). This may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of this usage data is our analytics tracking system. We may process this usage data to analyze the use of our website and services. The legal basis for this processing is your consent and our legitimate interests, which include monitoring and improving our website and services.
2.3 We may process your account data ("account data"), which may include your nickname and email address. The source of this account data is you. We may process this account data to operate our website, provide our services, ensure the security of our website and services, maintain backups of our databases, and communicate with you. The legal basis for this processing is our legitimate interests, which include the performance of an agreement between you and us, and/or taking steps, at your request, to enter into such an agreement.
2.4 We may process your information included in your personal profile on our website ("profile data"), which may include your nickname and email address. We may process this profile data to enable and monitor your use of our website and services. The legal basis for this processing is our legitimate interests, which include the performance of an agreement between you and us, and/or taking steps, at your request, to enter into such an agreement.
2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). We may process this enquiry data to offer, market, and sell relevant goods and/or services to you. The legal basis for this processing is your consent.
2.6 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). This customer relationship data may include your nickname, contact details, and information contained in communications between us and you. The source of this customer relationship data is you. We may process this customer relationship data to manage our relationships with customers, communicate with customers, keep records of those communications, and promote our products and services to customers. The legal basis for this processing is our legitimate interests, which include the proper management of our customer relationships.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). This transaction data may include your contact details and transaction details. We may process this transaction data to supply the purchased goods and services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, which include the proper administration of our website and business.
2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). This correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. We may process this correspondence data to communicate with you and keep records. The legal basis for this processing is our legitimate interests, which include the proper administration of our website and business, as well as communications with users.
2.9 We may process information about your cryptocurrency exchange transactions ("trading data"). This data may include details of your deals on cryptocurrency exchange markets, such as openings, closures, and other transaction details. The source of this data is your accounts on cryptocurrency exchange platforms, which you deliberately shared with us. We may process this trading data to provide relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
2.10 We may process any of your personal data identified in this policy when necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, which include the protection and assertion of our legal rights, as well as your legal rights and the legal rights of others.
2.11 We may process any of your personal data identified in this policy when necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, which include the proper protection of our business against risks.
2.12 In addition to the specific purposes outlined in this Section 2, we may also process any of your personal data when such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.13 Please refrain from supplying any personal data of other individuals to us, unless we explicitly request you to do so.

Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (including subsidiaries, our ultimate holding company, and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your trading data to our users as reasonably necessary to fulfill our obligations under an agreement with our users. The legal basis for this disclosure is the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
3.4 Financial transactions related to our website and services are handled by our payment services providers. We will share transaction data with these payment services providers only to the extent necessary for processing your payments, issuing refunds, and addressing complaints and queries related to such payments and refunds.
3.5 In addition to the specific disclosures of personal data outlined in this Section 3, we may disclose your personal data when such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data when such disclosure is necessary for establishing, exercising, or defending legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Retaining and deleting personal data

4.1 This Section 4 outlines our data retention policies and procedures designed to ensure compliance with our legal obligations regarding the retention and deletion of personal data.
4.2 Personal data processed for any purpose shall not be kept for longer than necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your personal data when retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

5.1 We may update this policy periodically by publishing a new version on our website.
5.2 It is advisable to check this page occasionally to ensure that you are satisfied with any changes made to this policy.

Your rights

6.1 In this Section 6, we summarize the rights you have under data protection law. While some of these rights are complex, we have provided a general overview here. For a comprehensive understanding of these rights, we recommend referring to the relevant laws and guidance from regulatory authorities.
6.2 Your primary rights under data protection law include:
(a) The right to access.
(b) The right to rectification.
(c) The right to erasure.
(d) The right to restrict processing.
(e) The right to object to processing.
(f) The right to data portability.
(g) The right to lodge a complaint with a supervisory authority.
(h) The right to withdraw consent.
6.3 You have the right to confirm whether we process your personal data and, if so, to access the personal data and receive additional information. This additional information includes details about the purposes of the processing, the categories of personal data involved, and the recipients of the personal data. As long as the rights and freedoms of others are not affected, we will provide you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data when logged into our website.
6.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data completed.
6.5 In certain circumstances, you have the right to the erasure of your personal data without undue delay. These circumstances include when the personal data are no longer necessary for the purposes they were collected for, you withdraw your consent, you object to the processing under specific data protection rules, the processing is for direct marketing purposes, or the personal data have been unlawfully processed. However, there are exclusions to the right of erasure, such as when processing is necessary for the exercise of freedom of expression and information, compliance with a legal obligation, or the establishment, exercise, or defense of legal claims.
6.6 In certain circumstances, you have the right to restrict the processing of your personal data. These circumstances include when you contest the accuracy of the personal data, the processing is unlawful but you oppose erasure, we no longer need the personal data but you require it for legal claims, or you have objected to processing pending verification of the objection. When processing has been restricted, we may still store your personal data, but will only process it with your consent, for legal claims, to protect the rights of another person, or for important public interest reasons.
6.7 You have the right to object to the processing of your personal data when it is based on our legitimate interests or the performance of a task carried out in the public interest. If you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defense of legal claims.
6.8 You have the right to object to the processing of your personal data for direct marketing purposes, including profiling. If you object, we will cease processing your personal data for such purposes.
6.9 You have the right to object to the processing of your personal data for scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out in the public interest.
6.10 When the legal basis for our processing of your personal data is your consent or the performance of a contract to which you are a party, and such processing is automated, you have the right to receive your personal data in a structured, commonly used, and machine-readable format from us. However, this right does not apply if it adversely affects the rights and freedoms of others.
6.11 If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you reside, work, or where the alleged infringement took place.
6.12 If our processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing prior to the withdrawal.
6.13 You may exercise any of your rights regarding your personal data by providing written notice to us, in addition to the other methods specified in this Section 6.

About cookies

7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.2 Cookies can be "persistent" or "session" cookies. Persistent cookies are stored by a web browser and remain valid until their set expiry date, unless deleted by the user before the expiry date. Session cookies expire at the end of the user session when the web browser is closed.
7.3 Cookies do not typically contain information that personally identifies a user. However, personal information we store about you may be linked to and obtained from cookies.

Cookies that we use

8.1 We use cookies for the following purposes:
(a) Authentication: We use cookies to identify you when you visit our website and navigate through it.
(b) Status: We use cookies to determine if you are logged into our website.
(c) Security: We use cookies as part of our security measures to protect user accounts, prevent fraudulent use of login credentials, and safeguard our website and services.
(d) Analysis: We use cookies to analyze the use and performance of our website and services.
(e) Cookie Consent: We use cookies to store your preferences regarding the use of cookies.

Managing cookies

9.1 Most browsers allow you to refuse or delete cookies. The methods for doing so may vary depending on the browser and its version. You can find up-to-date information on blocking and deleting cookies through the following links:
(a) Chrome: https://support.google.com/chrome/answer/95647?hl=en
(b) Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(c) Opera: http://www.opera.com/help/tutorials/security/cookies/
(d) Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(e) Safari: https://support.apple.com/kb/PH21411
(f) Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
9.2 Blocking all cookies may impact the usability of many websites.
9.3 If you block cookies, you may not be able to access all features of our website.

Our details

10.1 This website is owned and operated by FIXATI.
10.2 You can contact us:
(a) By post, using the postal address provided above.
(b) Using our website contact form.
(c) By email, using the email address published on our website.