Crypto.com Onchain Privacy Notice
Last Material Update: 20 November 2024
We ask that you please read this Privacy Notice before providing us with any information about you or any other person. If you do not agree to this Privacy Notice and any revisions that may be made to it, you should discontinue your use of this Site and our Services.
Introduction
Welcome to Crypto.com Onchain Privacy Notice (“Privacy Notice”).
We respect your privacy, and we are committed to protecting your personal data. This Privacy Notice tells you about your privacy rights and how the data protection principles set out in the Data Protection Act of the Cayman Islands (“DPA”) protect you.
If you are a resident of the European Union, including Iceland, Liechtenstein and Norway (EU) or resident of the United States (US), please refer to the relevant content below.
Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.
Contents
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how we will collect, use, store and transfer your personal data when you visit our Site, or through your use of the Services (see the Glossary) and any data you may provide when you register for or use the Services, sign up for alerts or newsletters, contact us with a question or request for help and/or participate in any renewals, promotions or surveys.
The Site and the Services are not intended for minors below the age of 18 and we do not knowingly collect data relating to minors.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice, we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other policies and privacy notices and is not intended to override them.
As a best practice approach, we usually explain through understandable and common means the terms and conditions of our Services, renewals, promotions or surveys, please read them carefully before submitting your personal data.
Controller
Growth Labs, a company incorporated under the laws of the Cayman Islands (“we”, “us” or “Crypto.com”), is the data controller and responsible for the processing of your personal data.
Contact details and Complaints
If you have any questions or complaints about this Privacy Notice or our privacy practices, or if you want to exercise your legal rights, please contact us at [email protected].
You have the right to make a complaint to the Cayman Islands Ombudsman (“Ombudsman”) about the way we process your personal data. The Ombudsman is the Cayman Islands supervisory authority for data protection issues. Further details about making a complaint to the Ombudsman are available here: https://ombudsman.ky/make-a-complaint.
We would, however, appreciate the chance to deal with your concerns before you approach the Ombudsman or other relevant authority, so please feel free to contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
We keep our Privacy Notice under regular review. This version was last updated on the date above written. The Privacy laws around the globe change regularly, please check from time to time for new versions of the Privacy Notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Site and any applicable web browser, smartphone app 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. When you leave our Site or Applications, we encourage you to read the privacy notice of every Third Party Site you visit or use.
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). More information could be found here:
https://ombudsman.ky/data-protection-organisation/what-information-does-the-dpl-apply-to
We may collect, use, store and transfer different kinds of personal data about you which we have grouped in categories in the table below.
Please note that for the registration and use of the Crypto.com Onchain App a certain amount of personal data is required. Identity Data, Contact Data and Financial Data will be collected if you connect the Crypto.com Onchain App with the Crypto.com App. Identity Data, Contact Data and Financial Data will not be transferred from the Crypto.com App to the Crypto.com Onchain App technically, but all the personal data that we have on file on our systems will be linked.
If you are an EU resident and you have chosen to connect the Crypto.com Onchain App with the Crypto.com App, click here.
If you are a US resident and you have chosen to connect the Crypto.com Onchain App with the Crypto.com App, click here.
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Category of Personal Data
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Specific Pieces of Personal Data |
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● first name, ● maiden name, ● last name, ● username or similar identifier, ● title, ● date of birth and gender, ● biometric information, including a visual image of your face, ● national identity cards, ● passports, driving licenses or other forms of identification documents.
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● residents details, ● billing address, ● delivery address, ● home address, ● work address, ● email address and telephone numbers, ● proof of address documentation.
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● payment card details, ● virtual currency accounts, ● amounts associated with accounts, ● external account details. |
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● details about payments to and from you, ● other details of your transactions that will be available from your address scanning on public explorer.
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● internet connectivity data, ● internet protocol (IP) address, ● operator and carrier data, ● installation and login data, ● device type, category and model, ● your Crypto. com Onchain App address, ● browser type and version, ● 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 the devices you allow us access to when you visit the Site, or use the Services, or the Crypto.com Onchain App.
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● password, ● requests by you for products or services, ● information on whether you have Crypto.com App account and the email associated with your accounts, ● 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 Site, the Services, mobile applications and other offerings made available by us, including: o device download time, o install time, o interaction type and time, o event time, name and source. |
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● your preferences in receiving marketing from us or third parties, o your communication preferences, o your survey responses.
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We will only ask for your Identity Data, Contact Data and Financial Data if it is necessary to provide you with the Services.
We may also ask you to prove ownership or control of a particular blockchain address. We are required to ask for this information to comply with anti-money laundering and counter-financing of terrorism requirements, and to ensure we safeguard against and report any suspicious activity.
In addition, the DPA also treats certain other categories of personal data as sensitive and accordingly such sensitive data warrants extra protection.
Sensitive data (a.k.a. Special Categories data) includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation, as well as details of criminal records or any proceedings for any offence committed or alleged to have been committed, including the disposal of any such proceedings or any sentence of a court in the Cayman Islands or elsewhere.
We will only collect, use, store and transfer your sensitive data, if we are able to satisfy both the lawful basis requirements (see Section 4 and the Glossary), as well as at least one of the following additional conditions:
● is necessary for the purpose of, or in connection with, any legal proceedings;
● is necessary for the purpose of obtaining legal advice; or
● is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
● the exercise of any functions conferred on any person by or under an enactment.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
If you refuse to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (where the personal data is necessary for the performance of that contract), 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 data from and about you including through:
Direct interactions. You may give us your Identity Data, Contact Data and Financial Data 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:
● visit our Site or Crypto.com Onchain App;
● apply for our products or services;
● create an account;
● subscribe to our service or publications;
● make use of any of our Services;
● request marketing to be sent to you;
● enter a competition, promotion or survey;
● give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Site or Crypto.com Onchain App, 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 similar technologies. We will also collect Transactional Data. We may also receive Technical Data about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies through the Cookie Settings.
Third parties or publicly available sources. We also obtain information about you from third parties or publicly available sources (credit reference agencies, fraud and crime prevention agencies, public blockchain).
We will only use your personal data when the DPA, the EU General Data Protection Regulation (“GDPR”) (if applicable) or the California Consumer Privacy Act (”CCPA”) (if applicable) allows us to. Most commonly, we will use your personal data in the following circumstances:
1. For the provision of the Services.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and individual rights do not override those interests.
Please refer to the Glossary, lawful basis sections to find out more about the types of lawful bases that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. See below for further details on marketing.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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 on 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/Activity |
Categories of personal information |
Lawful basis for processing including basis of legitimate interest |
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To register you as a new user |
● Identity Data ● Contact Data ● Financial Data ● Profile Data
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● Performance of a contract with you
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To carry out and comply with anti-money laundering requirements
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● Identity Data ● Contact 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
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● Identity Data ● Contact Data ● Transactional Data ● Technical Data ● Marketing and Communications Data |
● Performance of a contract with you
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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
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● Legitimate interests |
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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
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● Identity Data ● Contact Data ● Profile Data ● Transactional Data ● Marketing and Communications Data |
● Performance of a contract with you ● Consent, if required= |
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To keep our records updated and to study how users use our products/services |
● Identity Data ● Contact Data ● Profile Data ● Transactional Data ● Marketing and Communications Data
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● Legitimate interests ● Consent, if required
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a. To manage risk and crime prevention including performing anti-money laundering, counterterrorism, sanction screening, fraud and other background checks,detect, investigate, report and prevent financial crime in broad sense,obey laws and regulations which apply to us and respond to complaints and resolving them |
● Identity Data ● Contact Data ● Technical Data ● Transactional Data Sensitive Data (a.k.a. Special Categories Data) data that you give us directly or that we receive from third parties and/or publicly available sources:- data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);- data that is incidentally revealed by photographic ID although we do not intentionally process this personal data |
● Compliance with a legal obligation ● We may also process such data in connection with these purposes if it is necessary for the performance of a contract with you ● In addition to our legal obligations, we may process this personal data based on our legitimate interest in ensuring that we are not involved in dealing with the proceeds of criminal activities and do not assist in any other unlawful or fraudulent activities, as well as to develop and improve our internal systems for dealing with financial crime and to ensure effective dealing with complaintsFor Sensitive Data (a.k.a. Special Categories Data) it is necessary for reasons of substantial public interest under the EU Anti-Money Laundering Legislation as the Cayman Islands are subject to the Council Decision 2013/755/EU on the association of the overseas countries and territories with the European Union (‘Overseas Association Decision’).
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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
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● Performance of a contract with you ● Consent, if required |
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To gather market data for studying users behavior including their preference, interest and how they use our products/services,determining our marketing campaigns and growing our business
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● Identity Data ● Contact Data ● Profile Data ● Usage Data ● Marketing and Communications Data
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● Legitimate interests: understanding our users and improving our products and services |
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To administer and protect our business, our Site and Crypto.com Onchain App and social media channels including bans,troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
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● Identity Data ● Contact Data ● Technical Data ● Transactional Data
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● 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
● Identity Data ● Contact Data ● Profile Data ● Usage Data ● Marketing and Communications Data ● Technical Data |
● Legitimate interests: to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy ● Consent, if required |
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
● Technical Data ● Usage Data |
● Legitimate interests: to define types of 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 ● Marketing and Communications Data
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● Necessary for our Legitimate interests: to develop our products/services and grow our business ● Consent, if required |
Marketing
We may use your Identity
Data, Contact Data, Financial Data,
Technical Data, Transactional
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 or purchased from us and you have not opted out of
receiving that marketing. We will use your Marketing and Communications Data for our respective activities.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for direct marketing purposes.
Opting out
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 of terms and conditions and so forth).
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences.
Change of purpose
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.
Sale or transfer of business
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 transaction, or to meet our legal obligations.
We may share your personal data with our third-party service providers, agents, subcontractors and other associated organisations, our group companies and affiliates (as described below) in order to complete tasks and provide the Services and use of the Crypto.com Onchain App to you on our behalf. 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 may pass your personal data to the following entities:
● companies and organisations 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 as a result 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, whether they are outside or inside of the Cayman Islands, where the law allows or requires us to do so.
We may share your personal data within our group. This will involve transferring your data outside the Cayman Islands or the origin of where your data is collected.
Many of our external third parties are based outside the Cayman Islands so their processing of your personal data will involve an international transfer of your data.
Whenever we transfer your personal data out of the Cayman Islands, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
2. Based on our own adequacy assessment regarding the applicable country or territory pursuant to Schedule 1, Part 2(4) of the DPL.
3. Where the Ombudsman has authorised the international transfer.
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.
The DPA does not dictate how long any personal data is required to be kept. To determine the appropriate retention period for personal data, we will 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 (e.g. email addresses and content, chats, letters will be kept up to 6 years following the end of our relationship, in accordance with the limitation period applicable in the Cayman Islands);
● to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data (e.g. anti-money laundering obligations, information needed for audit purposes, etc.); or
● 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 user’s personal data for the time of the promotion in order to prevent the appearance of abusive behavior.
Please bear in mind that the right to deletion/erasure of your personal data is not absolute which means that in some circumstances, you can ask us to delete your data: see Section Your Legal Rights for further information. However, when interacting with any blockchain, we may not be able to ensure that your personal data is deleted. This is because blockchains are public decentralised networks and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances, we will only be able to ensure that all personal data that is held by us is permanently deleted.
If you are an EU resident, please make sure that you also review Section 10 below.
Under certain circumstances, you have rights under the data protection laws in relation to your personal data:
● Right to be informed - this enables you to be informed at all times about who we are and the purposes for processing your personal data.
● Request access to your personal data (commonly known as a "data subject access request) - this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● Request correction of your personal data - this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data - this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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, if applicable, at the time of your request. If a valid erasure request is received, we will take steps to ensure erasure from back-up systems as well as live systems. You will be informed after your personal data has been erased.
● Object to the processing of your personal data (in whole or in relation to certain purposes or in certain manners) where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your individual rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Right to stop direct marketing - where we are processing your personal data for direct marketing purposes, you have the right to notify us in writing requesting that we cease or do not begin processing your personal data for direct marketing purposes.
● Rights in relation to automated decision making - if the decision is made solely by automated means (without human involvement), you will be notified when decisions are made solely on an automated basis.
● Request restriction/stop of processing your personal data - this enables you to ask us to suspend the processing of your personal data in the following scenarios:
1. If you want us to establish the data's accuracy.
2. Where our use of the data is unlawful, but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
● Request transfer of your personal data - we will provide to you, or a third party you have chosen (where technically feasible), your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Right to withdraw consent by contacting us through [email protected]- 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. We will advise you if this is the case at the time you withdraw your consent.
● Right to complain/seek compensation - you have the right to complain to the Ombudsman or any relevant authority about any perceived violation and to seek compensation for damages in the courts.
Please refer to the Glossary at paragraph 10 below for further detail on each of these rights. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within 30 days. Occasionally, it could take us longer than 30 days if your request is particularly complex or you have made a number of requests, also if more time is required to consult with a third party or other data controller (if needed) before we can reply to your request; In this case, we will notify you and keep you updated.
As per the Guidance of the Ombudsman, for some requests the period for us to reply is 21 days:
- request based on the right to stop or restrict processing,
- request based on the rights in relation to automated decision making.
The said period could be expanded on the same conditions as described in the first paragraph.
As an EU Resident the EU General Data Protection Regulation (“GDPR”) applies to you. In some sections throughout this Privacy Notice we encourage you to check this content as it provides you with certain specificities, please read it carefully.
What is personal data
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). More information could be found here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-personal-data_en
Additional condition for processing of special categories of personal data
Processing of your personal data is necessary for reasons of substantial public interest, on the basis of the EU Anti-Money Laundering Legislation as the Cayman Islands are subject to the Council Decision 2013/755/EU on the association of the overseas countries and territories with the European Union (‘Overseas Association Decision’). Hence, we are required to process for instance information from your ID documents including a photographic picture of you.
See also the respective row in the table which describes the purposes for which we will use your personal data.
Period for replying to a legitimate request
The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
Lodging a complaint with a data protection authority
If you are an EU resident, you can also lodge a complaint with your local data protection authority. A detailed list is available here:
https://edpb.europa.eu/about-edpb/board/members_en
We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please feel free to contact us in the first instance.
Retention period
Under the EU Anti-Money Laundering legislation (Anti-Money Laundering Directives 4 and 5) we are obliged to retain your personal data for a period of 5 years after the end of the relationship between us as a company and you as a customer. This period may be further extended in certain cases if so provided by and in accordance with the applicable legislation.
Another example relates to our legitimate business need to prevent abuse of the promotions that we launch. We will retain a user’s personal data for the time of the promotion in order to prevent the appearance of abusive behavior.
International Transfers
We share your personal data within our group. This will involve transferring your personal data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
● the country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission;
● a specific contract approved by the European Commission which gives safeguards to the processing of personal data, the so called Standard Contractual Clauses.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
Comply with a legal obligation means processing your personal data
where it is necessary for compliance with a legal obligation that we are
subject to.
Site means the website at www.crypto.com.
Services shall have the same meaning as given in Section 3.1 of the Terms and Conditions.
Crypto.com means Growth Labs and its affiliates.
Crypto.com App means the Crypto.com wallet mobile application.
Crypto.com Onchain App means the Crypto.com Onchain mobile application.