Crypto.com Pay for Business Privacy Notice (Australia)
Effective Date: 23 October 2024
Welcome to Crypto.com Pay for Business Privacy Notice (Australia) (“Privacy Notice”). Please spend a few minutes reading it carefully before providing us with any information about you or any other person. This notice only applies to personal data and does not focus on company information.
Contents
4. What data we collect about you 3
7. Disclosures of your data 12
We respect your privacy and are committed to protecting your personal data. This Business Privacy Notice applies to the processing of personal data by Crypto.com Pay (“Crypto.com Pay”, “we”, “us”, “our”) in connection with the use of any of our products, services or applications (collectively, “the Services”) and the use of our crypto.com websites (“Site”) or mobile application (“App”).
Please note that our Services, Site and App are not intended for minors below the age of 18 years. For their protection, we ask anyone under 18 years of age not to register with us.
In case we require information for a person that happens to be under the age of 18 years (for example if the ultimate beneficial owner (UBO) of your company is a minor), please inform us before providing any details and if needed we will send a dedicated notice for their holder of parental responsibility about how the UBO's personal data will be handled.
This Business Privacy Notice aims to give you information on why and how we collect and process your personal data. It also 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 Business Privacy Notice together with other notices or policies 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 personal data. This Business Privacy Notice supplements other notices and policies and is not intended to supersede or override them.
APP Entities or Agencies
We are obtaining and processing your personal data as an APP entity or agency, with which you engage or whose terms you have accepted. For your convenience, you may find in the table below the respective details of the relevant entity responsible for processing your personal data.
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APP Entities or Agencies |
Contact details |
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Foris DAX AU Pty Ltd |
Level 3, 1049 Victoria Road, West Ryde NSW 2114, Australia |
If you have any questions or complaints related to this Business Privacy Notice or our privacy practices, please reach out to [email protected].
However, if you are a customer of a company that holds a Pay Merchant account, that company
is responsible for how your personal data will be processed and you should directly contact
them for more information.
Complaints
You may file a complaint
to the supervisory authority in Australia (i.e. Office of the Australian
Information Commissioner (“OAIC”)) or you may also contact your local,
state or provincial supervisory authority for the way we process your personal
data.
However, we would be much appreciated if you could let us have a chance to address or resolve your concerns before you file a complaint to a supervisory authority. Please feel free to reach out to [email protected].
Our duties and your duties in case of changes
Please note that we have the sole discretion to make changes or to modify this Business Privacy Notice at any time. All such changes or modifications will be effective immediately upon posting it or made available on our Site, App or Services.
We urge you to check this Business Privacy Notice from time to time to keep up-to-date with our privacy practices.
It is also important that the personal data we hold about you is accurate and up-to-date. Please kindly contact us via [email protected] if any of your personal data has changed and requires update during the course of the Services.
Third-party links
The Site and any applicable web browser, e.g. the App or application programming interface (API) 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 and/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 Site or Applications, we encourage you to read the privacy notice or policy of every Third-Party Site you visit or use.
Personal data
Personal data or personal information means information or opinion about an identified individual or an individual who is reasonably identifiable. This is a broad definition which includes the specific 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). In addition, the data protection laws do not apply to information about legal entities (for example, limited liability companies).
When we provide Pay Business services, we process personal data of the individuals authorized to set the account up, use it and give us instructions about the account. We also may process personal data about other people (such as the company’s shareholders, beneficial owners, representatives, employees, customers or business partners) where we are legally required to ask for such information (for example, as part of KYB checks or under anti-money laundering and counter terrorism laws to verify the company’s sources of funds). If you, or your company, give us personal data about other people, you are responsible for ensuring that they understand how we will process their personal data.
For Australian Merchants, you can find more information here.
Depending on whether and how you use our Services, Site or App, 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
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Identity Data |
● first name, ● maiden name, ● last name, ● username or similar identifier, ● title, ● employment status, ● date of birth and gender, ● visual image of your face, ● national identity card, passport, driving license or other form of an identification document.
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● group/company data, ● information on referrals related to you, ● political background, ● close connections, ● behavioral data, ● risk assessment, ● compliance assessment.
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Contact Data |
● residence details, ● billing address, ● delivery address, ● home address, ● work address, ● email address and telephone numbers,
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Financial Data |
● bank account, ● payment card details, ● virtual currency accounts, ● stored value accounts, ● amounts associated with accounts, ● external account details, ● source of funds and related documentation. ● tax information, including tax residency and identification number. |
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● details about payments to and from you, ● other details of any transactions you enter into using the Services, Site or App.
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Technical Data |
● 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 visit the Site, or use the Services or the App.
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Profile Data |
● username and password, ● information on whether you have Crypto.com App account and the email associated with your accounts, ● 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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|
Usage Data |
● information about how you use the Site, 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. |
|
Marketing and Communications Data |
● your preferences in receiving marketing from us or third parties, ● your communication preferences, ● your survey responses. |
Special categories of personal data
Certain types of sensitive personal data are subject to additional protection
under the legislation applicable to you. They are called “special categories”
of personal data. The special categories are:
● Racial or ethnic origin;
● Political opinions or associations;
● Religious or philosophical beliefs;
● Trade union membership or associations;
● Sexual orientation or practices;
● Criminal record;
● Health or genetic information;
● Genetic data (that is not otherwise health information);
● Biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
● Biometric templates.
For Australian Merchants, you can find more information here.
We use special categories of personal data for specific purposes only. We will only collect and process them when you have given express consent for us to do so. For Australian Merchants, we will only be collecting special categories of personal data if it is also reasonably necessary for one or more of our functions or activities.
We are subject to Australia Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) and KYC/KYB laws and regulations, which may require us to process information for identification purposes. See “Section 6” below which describes the purposes for which we will use your personal data.
We may be able to collect and use sensitive personal data without consent where it does so as regard to suspected unlawful activity or misconduct of a serious nature, for the establishment, exercise, or defense of a legal claim, or for the purposes of a confidential alternative dispute resolution process.
If you refuse to provide personal data
If we require certain information for our contract with you or because it is legally required and you do not provide this to us, we may not be able to offer you products or services, or perform our contract with you.
Where we need to collect personal data by law, or under the terms of a contract we have with our Pay Business client, 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 the Pay Business applicant – for example, to provide Pay Business Services. In this case, we may have to cancel a product or service our Pay Business client has with us, but we will notify you if this is the case at the time.
We use different methods to collect information from you:
Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial 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:
● visit our Site or App;
● apply for our Services;
● create an account;
● make use of any of our Services;
● request marketing information to be sent to you, for example by subscribing to our newsletters;
● enter a competition, promotion or survey, including through social media channels; and/or
● give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect these personal data through cookies, server logs and other online identifiers. We will also collect Transactional 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.
Social media widgets and similar links. Our Site may contain links, social media plug-ins, "widgets", "tweet", “share" and "like" buttons which are linked to social media platforms such as Facebook, X (Twitter), Instagram, Threads, Discord, LinkedIn, Reddit and Telegram.
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:
● individuals involved in setting up, using, or providing instructions with regards to the Pay Merchant account,
● third-parties database, tools or agencies,
● fraud and crime prevention agencies,
● public blockchain,
● publicly available information on the Internet (websites, articles etc.)
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal data for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal data and the reasonable expectations you might have in the circumstances.
We will only use your personal data when the applicable legislation allows us to and for lawful purposes only. We will use your personal data in the following circumstances:
● performance of 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 (e.g. the requirement or authorization by or under Australian or New Zealand law or a court/tribunal order, for example, Australian Taxation Office (ATO) etc.); and/or
● upon consent: means freely given, 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.
Purposes for which we use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data. We have also identified what our legitimate interests are, where appropriate.
We process your personal data for purpose and/or activity stated below:
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Purpose and/or activity |
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To register you as a new customer |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data
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To carry out and comply with anti-money laundering, counter-terrorist financing, KYC/KYB and Ongoing Customer/Business Due Diligence requirements |
● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data
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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 ● Financial Data ● Transactional Data ● Technical Data
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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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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 ● Transactional Data ● Marketing and Communications Data |
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To keep our records updated and to study how customers use our products/services |
● Identity Data ● Contact Data ● Transactional Data ● Marketing and Communications Data |
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To manage, process, collect and transfer payments, fees and charges |
● Identity Data ● Contact Data ● Financial Data ● Transactional Data
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To collect and recover payments owed to us
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● Identity Data ● Contact Data ● Financial Data ● Transactional Data
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To obey applicable legislation and handle complaints, including:
● manage risk and crime prevention involving performance of anti-money laundering, counter terrorism, sanction screening, on-going customer due diligence, fraud and other background checks
●
detect, investigate, report and prevent financial crime in a
broad sense ● ensure your account's security, in order to honor requests regarding information and/or changes to your account
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● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data ● Usage 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/KYB 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.
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To enable you to partake in a prize draw, competition or complete a survey |
● Identity Data ● Contact Data ● Usage Data ● Marketing and Communications Data
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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 ● Usage Data ● Marketing and Communications Data
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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 ● Usage Data |
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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
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● Identity Data ● Contact Data ● Usage Data ● Technical Data ● Marketing and Communications Data
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To use data analytics to improve our website, products/services, marketing, customer/user relationships and experiences
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● Technical Data ● Usage Data |
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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 ● Investment Data ● Marketing and Communications Data
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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
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● Technical Data ● Usage Data
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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
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● Identity Data ● Social Identity Data ● Contact Data ● Financial Data ● Transactional Data ● Technical Data ● Usage Data |
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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 |
Automated Decision Making
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 via [email protected].
Marketing
We may use your Identity Data, Contact Data, Technical Data, Transactional Data and Usage 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.
For information as to how to opt-out from marketing communications, please see ‘Opting out’ section below.
Third-party marketing
We will get your opt-in consent before we share your personal data with any third party for marketing purposes. For information as to how to opt-out and/or withdraw given consent from specific marketing communications, please see below ‘Opting out’ section and follow the instructions contained in the specific marketing materials.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links and/or withdraw given consent 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).
Cookies
You can set your browser to refuse all or some browser 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 via [email protected].
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 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 and use of the App 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, 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 types of 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, whether they are outside or inside of Australia, where the law allows or requires us to do so. For example, we may provide your personal data upon AML investigation, law enforcement request & investigation, tax reporting, CTF & fraud prevention, such as Australian Tax Office (ATO)’s request for information under Taxation Administration Act (1953) etc.
Specifics regarding the use of the blockchain
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 Australia.
Many of our external third parties are based outside Australia, so their processing of your personal data will involve transfer of data outside Australia.
We will ensure that the overseas recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is substantially similar to the Australian privacy regime and ensure that there is contractual agreement implemented between the parties to provide arrangements and provisions requiring the overseas recipient to comply with the APPs, and only disclose personal information for the primary purpose for which it was collected unless an exception to that principle applies.
Please contact us via [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of Australia.
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 unauthorized 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 reason. They will only process your personal data based 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:
● organizational 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, and may require you to directly notify your customers when it is 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 unauthorized 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:
o under the relevant respective Australia Anti-Money Laundering laws and regulations, we are obliged to retain your personal data for a minimal period of 7 years after the making of the record. This period may be further extended in certain cases if so provided by and in accordance with the applicable law and regulation;
o if information is needed for audit purposes and so forth;
● 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 ONLY proceed with those deletion requests 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 access to your personal data, which enables you to obtain confirmation of whether we are processing your personal data, to receive a copy of the personal data we hold about you and information regarding how your personal data is being used by us;
● request rectification of your personal data by asking us to rectify information you think is inaccurate and to complete information you think is incomplete, though we may need to verify the accuracy of the new data you provide to us;
● request erasure of your personal data by asking us to delete or remove personal data we hold about you; 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 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 fundamental 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; you also have the right to object where we are processing your personal data for direct marketing purposes;
● require that decisions be reconsidered if they are made solely by automated means, without human intervention (detailed explanation in Section 6 above);
● request restriction of processing your personal data, which enables you to ask us to suspend the processing of your personal data, if you want us to establish the data accuracy; where our use of the data is unlawful, but you do not want us to erase it; 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, or if you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;
● request the transfer of your personal data to you or to a third party, and 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 information which you initially provided consent for us to use or where we used the information to perform a contract with you;
● 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 relevant authority about any perceived violation and to seek compensation for damages in the courts.
If you are a customer of the company that holds the Pay Merchant account, please contact the company directly.
If you are an authorized person or representative of the company that helps to set up, use or hold the Pay Merchant account, or is authorized to provide instruction to us about the Pay Merchant account (e.g. director, senior management, authorized employee or beneficiaries etc.), you may contact us via email at [email protected]. It is important that the personal data we hold about you are accurate, complete and up to date as possible. Please keep us informed if your personal data has been changed during your relationship with us.
Fee
You may make a written request to access details of personal data that we have collected, utilized or disclosed about you in accordance with the provisions of the Australia’s Privacy Act 1988 (Cth).
In most circumstances, we do not charge an administrative fee. However, we may charge an administrative fee for the provision of information if the request has incurred cost.
We will make such personal data available to you in a form that is generally understandable and will explain any abbreviations or codes.
We understand that there are times whereby we may be requested to speed up our response, and in the event, we receive such a request from you, please be informed that we may contact you to find out further details pertaining to your request.
If we are not able to fulfill the request, we will notify you within the prescribed period under the Australian privacy regime, and provide the reason. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the APPs (see above “Section 11. Your legal rights”).
If you would like a copy of the personal data which we hold about you, please contact us via [email protected].
Period for replying to a legitimate request
We will attempt to respond to each of your written requests, including but not limited to complaints, not later than a reasonable time period after receipt of such requests and no later than the time period prescribed under Australia laws. We will advise you in writing if we cannot meet your requests within the time limit.
To protect your personal data and to prevent any unauthorized disclosure or deletion of your personal data, we may require that you provide sufficient identification prior to proceeding with your request. Any such identifying information will be used only for this purpose.
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