Privacy policy

Definitions

• “Personal data / information” — any information relating to an identified client (“data subject”). An identified client is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, mental, genetic or social identity of that natural person.
• “Processing of personal data” — any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Restriction of processing” — marking stored personal data with the aim of limiting its processing in the future.
• “Profiling” — any form of automated processing of personal data consisting of the use of personal data to evaluate certain aspects relating to natural or legal persons.
• “Filing system” — any structured set of personal data accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographic basis.
• “Controller” — a natural or legal person, public authority or other body which alone or jointly with others determines the purpose and means of the processing of personal data.
• “Processor” — a natural or legal person which processes personal data on behalf of the controller.
• “Recipient” — a natural or legal person to which personal data is disclosed.
• “Third party” — a natural or legal person other than the data subject, controller or processor, who under the direct authority of the controller or processor is authorised to process personal data.
• “Consent” of the data subject — any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
• “Personal data breach” — a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
• “Biometric data” — personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allows or confirms their unique identification, such as facial images or dactyloscopic data.
• “Website” — www.daxchain.eu.

Purpose of this policy

The purpose of this Privacy Policy is to define the following:

• the person responsible for the protection of personal information;
• the types of personal information collected;
• the sources from which the information is gathered;
• the use of information regarding IP addresses and the use of cookies;
• the disclosure of personal information to third parties;
• the client’s ability to correct, update and delete their own personal information; and
• the security measures used to prevent the loss, misuse or alteration of the personal information under Daxchain’s control.

Responsible person

Protection of personal information is the responsibility of the Data Protection Officer, whom the client may contact with any question relating to personal information. To get in touch with the DPO, write to office@daxchain.eu with “DPO” in the subject line.

Types of personal information collected

Daxchain may collect your personal information if you use the website or the Daxchain system, open an account, or perform any transaction. The types of personal information include, but are not limited to:

• name and surname;
• date of birth;
• photographic identification;
• personal document information (passport, ID, address information);
• address;
• phone number;
• e-mail address;
• username;
• IP addresses;
• geographic location;
• device and browser information;
• banking details, including account numbers;
• crypto wallet and transaction details, including the wallet’s blockchain address; and
• the history of the client’s transactions.

Why we collect and process it

Daxchain may use your personal information for the following purposes, including but not limited to:

• to enable the client to open and operate an account;
• to enable the client to perform transactions;
• to enable the client to contact Daxchain;
• to analyse statistics on the use of the website and the Daxchain system;
• for regulatory purposes;
• to provide the client with information about products and promotions that may be of interest; and
• for our own market research and statistical analysis.

Daxchain processes your personal information only for the purpose or purposes for which it was provided to us.

Principles we apply

Personal data shall be:

• processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency);
• collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes (purpose limitation);
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (data minimisation);
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data is erased or rectified without delay (accuracy);
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which it is processed (storage limitation);
• processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality); and
• demonstrably compliant with all of the above (accountability).

Where the information comes from

Daxchain collects information from the following sources, including but not limited to:

• the client’s Daxchain profile;
• the client’s social network profiles (Facebook, Google, LinkedIn); and
• public cryptocurrency blockchain sources.

IP addresses and cookies

Daxchain collects information about the client’s device, including where available the IP address, operating system and browser type, for system administration and aggregated reporting. This is statistical data about users’ browsing actions and patterns and may be used in relation to the security of the platform.

Daxchain uses cookies — a browser feature that assigns a unique identifier to the client’s computer. Information collected from cookies is used to evaluate the effectiveness of the website, analyse trends and administer the system. We also use web beacons or clear GIFs, typically stored in e-mails, to confirm receipt of and response to our messages and to provide a more personalised experience.

Daxchain uses third-party service providers to better understand the use of the website. The information they collect may be combined with information collected about the client while using the website. Those providers are contractually restricted from using the information for anything other than assisting Daxchain. Our full cookie notice is the Cookie Policy.

Disclosure to third parties

Personal information may be used for the purposes set out in this policy and as otherwise permitted by law or regulation. Daxchain may make personal information available to its affiliates, agents, representatives, trusted service providers and contractors for purposes consistent with this policy, and may share it with financial institutions, insurance companies or other companies subject to data protection regulation. Daxchain may also share personal information with law enforcement or regulatory agencies as required by law. Daxchain will ensure that any third party is aware of the obligations under this policy and is bound by terms no less protective than those Daxchain undertakes to the client.

Where required and permitted by law we may share information about the client with the following parties, among others:

• third-party verification providers (identity and address verification);
• acquiring and card-issuing banks;
• payment processing partners;
• our other service providers;
• banks and other financial institutions; and
• government and regulatory officials.

Daxchain co-operates with partners in different jurisdictions, so a client’s information may be processed, stored and analysed in a jurisdiction other than their own, but only as permitted by the law and regulation of that jurisdiction. Daxchain is committed to the safety of clients’ personal information through secured data transfer channels, contractual obligations and other means.

Correcting, updating and deleting your information

The client has the right to access their own personal information and to request the correction or updating of incorrect data by writing to office@daxchain.eu.

The client may also request the deletion of their account and personal information by writing to office@daxchain.eu. Daxchain will review the request and will decline it only where it is inconsistent with internal rules or with legal and regulatory obligations.

On the client’s written request, Daxchain will inform the client of the personal information held and of the general disclosure of that information, and will provide a copy of the personal information retained. A charge may be applied for access to one’s own personal information.

Security measures

Daxchain has implemented security measures to ensure the confidentiality and safety of clients’ personal information and to protect against misuse, alteration or destruction. Only authorised Daxchain individuals have access to clients’ personal information.

Security and privacy measures are reviewed from time to time in line with legal and technical developments, and this policy is updated accordingly.

Retention

Daxchain holds clients’ personal information only for as long as necessary, having regard to the purposes described in this policy and to legal and regulatory requirements. In accordance with record-keeping obligations, Daxchain retains accounts and personal information for at least five years after they are closed by the client.

Links to other sites

There may be links from the website to other websites and resources provided by third parties. This policy applies only to this website. Accessing a third-party website requires the client to leave this website. Daxchain does not control third-party websites or any content on them, and the client agrees that Daxchain is not liable for those websites, including their content, policies, failures, promotions, products, services or actions, or for any damages, losses or failures caused by, related to or arising from them. Daxchain asks clients to review the policies, rules, terms and regulations of every website they visit.

Marketing

The client has the right to ask Daxchain not to process their personal information for marketing purposes. The client may exercise this right of refusal at any time by contacting Daxchain at office@daxchain.eu.

Updates

Website policies, terms and conditions, content, information, promotions, disclosures, disclaimers, rules and features may be revised, modified, updated or supplemented at any time and without prior notice at the sole discretion of Daxchain. Amended privacy and security policy terms are posted on the website.

Contact

If the client has any question, comment or concern regarding this Privacy and Security Policy, please contact Daxchain at office@daxchain.eu with “DPO Officer” in the subject line.

DAXCHAIN OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Raua tn 36, 10126, Estonia. Registration number: 14660094.