Foris GFS BH B.S.C. Privacy Notice
Date of publication: 4 December 2024
Welcome to Foris GFS BH B.S.C. Privacy Notice (“Privacy Notice”). Please spend a few minutes reading it carefully before providing us with any information about you or any other person.
4. What data we collect about you
We respect your privacy, and we are committed to protecting your personal data. This Privacy Notice applies to the processing of personal data by Foris GFS BH B.S.C. (“Crypto.com”, we, us, our), details of which are available at Section 3 below in connection with use of any of our products, services or applications (together the “Services”).
Please note that our Services are not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.
This Privacy Notice aims to give you information on why and how we collect and process your personal data.
This Privacy Notice informs you about your privacy rights and how the data protection principles set out in the applicable privacy legislation protect you.
It is important that you read this Privacy Notice together with any other notice or policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of why and how we are using your data. This Privacy Notice supplements other notices and policies.
The controller of your personal data is the legal entity that determines the “means” and the “purposes” of any processing activities that it carries out. For your convenience, you may find in the table below the respective details of the relevant data controller of your personal data.
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Data controller |
Contact details |
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Foris GFS BH B.S.C. |
Room 2207, 22nd Floor, Almoayyed Tower, Building 2504, Road 2832, Block 428, Al Seef District, Manama, Kingdom of Bahrain |
Our Data Protection Guardian (“DPG”) is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions or complaints related to this Privacy Notice or our privacy practices, or if you want to exercise your legal rights, please reach out to [email protected].
You have the right to make a complaint to the Personal Data Protection Authority of the Kingdom of Bahrain (“the Authority”) about the way we process your personal data. The Authority is the Kingdom of Bahrain supervisory authority for data protection issues. Further details about making a complaint to the Authority are available on its official website.
We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please feel free to contact us in the first instance.
We keep our Privacy Notice under regular review. This version was last updated on the date above written. Please check from time to time for new versions of the Privacy Notice. Where required by law, we will additionally inform you regarding appropriate changes of this Privacy Notice.
It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
The applicable web browser, or application programming interface required to access the Services (“Applications”), may include links to third-party websites, plug- ins and applications (“Third-Party Sites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements and policies. When you leave our Applications, we encourage you to read the privacy notice or policy of every Third-Party Site you visit or use.
Personal data, or personal information means any information that relates to an identified or identifiable living individual. This is a broad definition which includes the specific pieces of personal data which we have described below.
A “data subject” is an individual who can be identified, directly or indirectly, by personal data.
This is usually by reference to an identifier such as a name, identification number, location
data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Different pieces of information, which collected together can lead to the identification of a particular individual, also constitute personal data. It does not include data where the identity has been removed (anonymous data).
Depending on whether and how you use our Services we will collect, use, store and transfer different kinds of personal data about you which we have grouped in categories as follows:
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Category of personal data |
Examples of specific pieces of personal data |
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● first name, ● maiden name, ● last name, ● username or similar identifier, ● title, ● employment status, ● date of birth and gender, ● biometric information, including a visual image of your face, ● video and voice recording, ● national identity card, passport, driving licence or other form of an identification document. |
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● group/company data, ● information on referrals related to you, ● political background, ● close connections, ● behavioural data, ● risk assessment, ● compliance assessment. |
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● residence details, ● billing address, ● delivery address, ● home address, ● work address, ● email address and telephone numbers, ● proof of address documentation. |
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● bank account, ● payment card details, ● virtual currency accounts, ● stored value accounts, ● amounts associated with accounts, ● external account details, ● annual income range, |
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● source of funds and related documentation. |
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● details about payments to and from you, ● other details of any transactions you enter into using the Services. |
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● information about your: - investment objectives (e.g. expected annual transaction volume range), - investment experience, - prior investments. |
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● internet connectivity data, ● internet protocol (IP) address, ● operator and carrier data, ● login data, ● browser type and version, ● device type, category and model, ● time zone setting and location data, ● language data, ● application version and SDK version, ● browser plug-in types and versions, ● operating system and platform, ● diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and ● other information stored on or available regarding the devices you allow us access to when you use the Services. |
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● username and password, ● identification number as our user, ● information on whether you have Crypto.com App account and the email associated with your accounts, ● requests by you for products or services, ● your interests, preferences and feedback, ● other information generated by you when you communicate with us, for example when you address a request to our customer support. |
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● information about how you use the Services, mobile applications and other offerings made available by us, including: - device download time, - install time, - interaction type and time, - event time, name and source. |
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● your preferences in receiving marketing from us or third parties, ● your communication preferences, ● your survey responses. |
As explained above under Identity Data, we will also collect:
● video and voice recordings where the video captures the individual's face for identity verification purposes and the individual’s voice is recorded to enhance the authenticity of the verification process. In this specific scenario, the processed personal data fall outside the scope of special categories of data.
● a visual image of your face which we will use, in conjunction with our sub-contractors (See Section Disclosures of Your Data below), to check your identity for onboarding and fraud prevention purposes. This data falls within the scope of special categories of data.
Certain types of personal data are subject to additional protection under the legislation applicable to you. They are called “sensitive personal data”. The special types are:
● Personal data revealing racial or ethnic origin; race, ethnical origin, political or philosophical opinions, religious beliefs, affiliation to union, personal criminal record, or any information in relation to his health or sexual status
● Political or philosophical opinions;
● Religious beliefs
● Affiliate to union;
● Personal criminal record;
● Data concerning health;
● Data concerning a natural person’s sexual status.
We will only use sensitive personal data for a specific purpose and if we are able to satisfy both the lawful basis requirements set out below, as well as at least one of the following additional conditions:
● You have given explicit consent;
● Processing relates to personal data which are manifestly made public by you;
● Processing is necessary for the establishment, exercise of defence of legal claims;
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you – for example, to provide you Services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect information from and about you, including through:
Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data, Investment Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:
● apply for our Services;
● make use of any of our Services;
● request marketing to be sent to you, for example by subscribing to our newsletters;
● enter a competition, promotion or survey, including through social media channels;
● give us feedback or contact us.
Automated technologies or interactions. As you interact with us via utilising our Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other online identifiers. We will also
collect Transactional Data, Investment Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies. You may find more information about how we use cookies through the Cookie Preferences.
Third parties or publicly available sources. We also obtain information about you, including Social Identity Data, from third parties or publicly available sources. These sources may include:
● fraud and crime prevention agencies,
● a customer referring you,
● public blockchain,
● publicly available information on the Internet (websites, articles etc.)
We will only use your personal data when the applicable legislation allows us to. In other words, we have to ensure that we have a lawful basis for such use.
Most commonly, we will use your personal data in the following circumstances:
● performance of a contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; we use this basis for provision of our Services;
● legitimate interests: means our interests (or those of a third party), where we make sure we use this basis as far as your interests and individual rights do not override those interests;
● compliance with a legal obligation: means processing your personal data where we need to comply with a legal obligation we are subject to;
● consent: means freely given, written, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you; under specific circumstances this consent should be explicit – if this is the case, we will ask for it properly.
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
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Purpose and/or activity |
Categories of personal data |
Lawful basis for processing |
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To register you as a new customer |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data |
● Performance of a contract |
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To carry out and comply with anti-money laundering requirements |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data ● Investment Data ● Profile Data |
● Compliance with a legal obligation |
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To process and deliver our Services and any App features to you, including to execute, manage and process any instructions or orders you make |
● Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data |
● Performance of a contract |
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To prevent abuse of our Services and promotions |
● Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data ● Marketing and Communications Data |
● Legitimate interests: safeguarding the security and integrity of our Services by detecting and preventing fraud and unauthorized activities, thereby protecting both our business and our customers |
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To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development |
● Identity Data ● Contact Data ● Profile Data ● Transactional Data ● Marketing and Communications Data |
● Performance of a contract ● Consent, if required |
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process this personal data. |
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To enable you to partake in a prize draw, competition or complete a survey |
● Identity Data ● Contact Data ● Profile Data ● Usage Data ● Marketing and Communications Data |
● Performance of a contract ● Consent, if required |
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To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business |
● Identity Data ● Contact Data ● Profile Data ● Usage Data ● Marketing and Communications Data |
● Legitimate interests: understanding our customers and improving our products and services |
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To administer and protect our business, our Site, App(s) and social media channels including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data |
● Identity Data ● Contact Data ● Financial Data ● Technical Data ● Transactional Data ● Investment Data ● Usage Data |
● Legitimate interests: to run our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise |
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To use data analytics to improve our products/services, marketing, customer/user relationships and experiences |
● Technical Data ● Usage Data |
● Legitimate interests: to define types of customers/users for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy ● Consent, if required |
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
● Identity Data ● Contact Data ● Technical Data ● Usage Data ● Profile Data ● Investment Data ● Marketing and Communications Data |
● Legitimate interests: to develop our products/services and grow our business ● Consent, if required |
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To use the services of social media platforms or advertising platforms some of which will use the personal data they receive for their own purposes, including marketing purposes |
● Technical Data ● Usage Data |
● Consent |
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To use the services of financial institutions, crime and fraud prevention companies, risk measuring companies, which will use the personal data they receive for their own purposes in their capacity of independent controllers |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Investment Data ● Technical Data ● Usage Data |
● Legitimate interests: to conduct our business activities on the market of financial services, to participate actively in the prevention of crime and fraud |
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To record voice calls for compliance, quality assurance and training purposes |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data |
● Legitimate interests: to comply with the industry standards and requirements in payments services, to ensure quality of our service, including by proper training of our personnel |
What is an automated decision?
Automated decision is usually a decision that may impact you and is made automatically based on software algorithms, without human intervention. As an illustrative example, we use automated decisions to complete the onboarding process of a new customer or to perform anti-fraud monitoring.
Why is an automated decision important to you?
Depending on the particular case, using your personal data may lead to automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.
How do we protect your interests regarding automated decisions?
The rights and interests of individuals whose personal data undergoes automated decision- making is safeguarded through appropriate measures. When an automated decision is made about you, you have the right to oppose the decision, to express your opinion, and to require human intervention regarding the decision. If you need more detailed information or wish to exercise this right, please contact us.
We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Investment Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.
We will get your opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Further, you can let us know directly that you prefer not to receive any marketing messages by emailing [email protected].
Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).
For more information about the cookies we use, please review the Cookie Preferences.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may also need to process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets. This will be based on our legitimate interests in carrying out such transactions, or to meet our legal obligations.
We share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Services to you on our behalf.
Depending on your use of services provided by companies under the Crypto.com brand and for the purposes of enhancing your user experience in this regard, the respective companies exchange certain data about you. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We pass your personal data to the following entities:
● companies and organizations that assist us in processing, verifying or refunding transactions/orders you make and in providing any of the Services that you have requested;
● identity verification agencies to undertake required verification checks;
● fraud or crime prevention agencies to help fight against crimes including fraud, money- laundering and terrorist financing;
● anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services;
● any third party because of any restructure, sale or acquisition of our group or any affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
● regulatory and law enforcement authorities, where the law allows or requires us to do so.
The blockchain technology used in the provision of certain Services operates on a decentralized network, where transactions are recorded in an immutable and transparent manner. This characteristic ensures the integrity and security of the data stored on the blockchain. However, it also means that once data is added to the blockchain, it becomes virtually impossible to remove or delete it.
We share your personal data within our group. This will involve transferring your personal data outside the Kingdom of Bahrain.
Many of our external third parties are based outside the Kingdom of Bahrain so their processing of your personal data will involve a transfer of data outside the Kingdom of Bahrain.
Whenever we transfer your personal data out of the Kingdom of Bahrain, we ensure a similar degree of protection is afforded to it by ensuring the following safeguards are implemented:
● the country to which we transfer your personal data has been deemed to provide an adequate level of protection (attention third-party website link) for personal data by the Personal Data Protection Authority of the Kingdom of Bahrain;
● obtaining prior authorization from the Personal Data Protection Authority to transfer data outside the Kingdom of Bahrain in accordance with the applicable regulatory requirements.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the Kingdom of Bahrain.
While there is an inherent risk in any data being shared over the internet, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:
● organisational measures (including but not limited to staff training and policy development);
● technical measures (including but not limited to physical protection of data, pseudonymization and encryption); and
● securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
If you want to know more about our security practice, please visit this link.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:
● in the event of a complaint;
● if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims;
● to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data
● in accordance with relevant industry standards or guidelines;
● in accordance with our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal data for the time of the promotion and for a certain period after its end to prevent the appearance of abusive behavior.
Please note that under certain condition(s), you can ask us to delete your data: see your legal rights below for further information. We will honor your deletion request ONLY if the condition(s) is met.
You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal data. If you need more detailed information or wish to exercise any of the rights set out below, please contact us.
You may:
● request notification from us if your personal data is being processed, which enables you to obtain confirmation of whether we are processing your personal data, to receive information on what personal data we hold about you, the purpose of processing and information regarding how your personal data is being used by us (including where it has been obtained, and to which parties it has been disclosed);
● request us to rectify, block or erase the personal data relating to you when the processing of such data is in breach of the provisions of the applicable privacy legislation, in particular if the data is inaccurate, incomplete, outdated or if its processing is illegal. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you. In addition, please also check sub-section “Specifics regarding the use of the blockchain” above;
● object to the processing of your personal data, where the processing of your data for a specific purpose or in specific manner is causing, or there are reasonable grounds is likely to cause unwarranted substantial damage, being material or moral, to you or others;
● request that decisions be reconsidered if they are made solely by automated means, without human intervention (detailed explanation in Section 6 above);
● withdraw consent at any time where we are relying on consent to process your personal data; however, this will not affect the lawfulness of any processing carried out before you withdraw your consent; if you withdraw your consent, we may not be able to provide certain products or services to you, but we will advise you if this is the case at the time you withdraw your consent;
● complain to the Personal Data Protection Authority of the Kingdom of Bahrain or any relevant authority about any perceived violation and to seek compensation for damages in the courts.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
The statutory period under the Persona
Data Protection Law of the Kingdom of Bahrain for us to reply to a legitimate
request is 10 working days (15 working days for request
for notification of personal data processing).
Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.