Privacy Policy
Table of Contents
- Introduction
- Information Collection
- Information Processing
- Minors' Data
- Cookies
- Information Use and Disclosure
- Cross Border Transfer of Personal Information
- Information Security
- Your Rights
- Data Retention
- Contact Information
- Notices and Revisions
Version: 1.0 - September 2023
1. Introduction
We at Blockchain Bureau (Pty) Ltd, ("BCB", "we", "us", or "our") are committed to transparency in respect of our handling of Personal Information of the users of our website, platform, products and services.
- This Privacy Policy describes how BCB collects and processes your personal information through the BCB websites and applications that are referenced in this Privacy Policy. BCB consists of an ecosystem comprising BCB websites (whose domain names include but are not limited to www.blockchainbureau.com), mobile applications, clients, applets and other applications that are developed to offer BCB Services, and includes independently-operated platforms, websites and clients within the ecosystem.
- This Privacy Policy applies to all Personal Information processing activities carried out by us, across platforms, websites, and departments of BCB. To the extent that you are a customer or user of our services, this Privacy Policy applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you. To the extent that you are not a relevant stakeholder, customer, or user of our services, but are using our website, this Privacy Policy also applies to you together with our Cookie Policy. This Notice should therefore be read together with our Cookie Policy, which provides further details on our use of cookies on the website.
- This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Information, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Information.
We reserve the right to revise this Privacy Policy from time to time. While you should regularly check this Privacy Policy and determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated, we may also notify you of updates to this Privacy Policy in any form as we may deem appropriate or, where required by applicable law, by posting a notice or reaching you via other forms of communication.
2. Information Collection
Personal Information is information that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.
Information you provide to BCB
To subscribe to, and access our services, we'll ask you to provide us with information about yourself. This information is either required by law, necessary to provide the requested service(s), or is relevant for certain specified purposes, described in greater detail below.
Failure to provide the information required could result in BCB not being able to provide you with access to some or all of our services.
| Category of Personal Information | Types of Personal Information |
|---|---|
| Personal Identification Information | Full name, e-mail address, gender, address, phone number, date of birth, nationality, signature, utility bills, photographs, and a video recording of you |
| Sensitive and Biometric Personal Information | BCB may also collect sensitive personal information when permitted by local law or with your consent, such as biometric information, for example to verify your identity by comparing the facial scan information extracted from your selfie or video with the photo in your government issued identity document |
| Government Identifiers | Government issued identity documents such as passport, national identification number, national identity card details, driver's license numbers |
| Company Information | Company registration documentation, personal identification information for all material beneficial owners, personal information about the board of directors, senior management individuals responsible for the operations of the company |
| Financial Information | Bank account information, card payment information, source of funds, source of wealth |
| Transaction Information | Information about the transaction you perform on our platform / through our API(s), such as the name of the recipient, your name and e-mail |
| Information from Cookies | See our Cookie Policy for more information. |
| Employment Information | Job title, salary / wage rate, and Employer |
| Communications | Survey responses, information contained in the Survey. Communications with us including call recordings with our customer services team. |
| Contact Information | E-mail address, country, region |
Information BCB collects from you automatically.
To the extent permitted under the applicable law, we may collect certain types of information automatically, for example whenever you interact with us or use the services. This information helps us address customer support issues, improve the performance of our sites and services, maintain and or improve your user experience, and protect your account from fraud by detecting unauthorized access.
| Category of Personal Information | Types of Personal Information |
|---|---|
| Browsing Information |
|
| Usage Information |
|
| Blockchain Information |
|
| Marketing and Research Information |
|
3. Information Processing
The reasons for the processing of your Personal Information, and the legal basis for such collection and processing thereof, are outlined below.
We process your personal data for the following general purposes:
- providing the services, including registration on the Website and Platform, providing demos, establishing contractual relationships, and concluding contracts;
- processing payments from our customers;
- enhancing our services;
- ensuring information security of the services and preventing frauds;
- lead generation, sending newsletters and other direct marketing communications;
- providing customer support, providing information on service updates;
- organizing webinars, events; and
- analysis of business performance and managerial decision making.
| Legitimate interest in processing your personal information | Legal Basis for our use of your personal information |
|---|
4. Minors' Data
BCB does not allow minors to use BCB Services and does not knowingly collect personal information from minors, unless such collection or processing is in respect of an emancipated minor or otherwise authorized by an appropriate responsible party providing consent on behalf of the minor.
6. Information Use and Disclosure
We may share your Personal Information with third parties (including other BCB entities) if we believe that sharing your Personal Information is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. When sharing your Personal Information with other BCB entities, we will use our best endeavors to ensure that such entities are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy. For example, depending on where you reside and the entity responsible for running KYC checks. For more information please refer to Section 1.
We may also share Personal Information with the following persons or in the following circumstances:
- Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include cloud providers, customer relationship management (CRM) providers, e-signature providers, integration tool providers, meeting organizer tool providers, banks, payment processors, invoicing tool providers, instant messaging providers, video conferencing tool providers, UI/UX tool providers, public database providers, social media providers, data cleansing providers, online form providers, reporting tool providers, online advertising platforms and agencies, analytics tools providers, webinar partners, marketing lead contact search engines, business listing pages, project management tool providers, legal consultants, financial consultants, and public authorities.
- Legal Authorities: We may be required by law or by court order to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.
- Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the user consents otherwise). Also, in the unlikely event that BCB or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.
- Protection of BCB and others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of BCB, our users or others. This includes exchanging information with other companies and organizations for fraud protection and business risk mitigation.
7. Cross Border Transfer of Personal Information
To facilitate our global operations, BCB may transfer your personal information outside of the jurisdiction of the country or territory in which you reside or access our services from.
We may transfer your personal information to our third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal information cross-border BCB puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable information protection rules.
8. Information Security
We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We work to protect the security of your Personal Information during transmission and while stored by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your Personal Information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know.
Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account.
9. Your Rights
Subject to applicable law, you have a number of rights in relation to your privacy and the protection of your Personal Information.
- Right to access: you have the right to obtain confirmation that your Personal Information is processed and to obtain a copy of it as well as certain information related to its processing;
- Right to rectify: you can request the rectification of your Personal Information which is inaccurate.
- Right to erasure: you can, in some cases, have your Personal Information deleted;
- Right to object: you can object to the processing of your Personal Information.
- Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your Personal Information by us, provided there are valid grounds for doing so. We may continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law;
- Right to portability: in some cases, you can ask to receive your Personal Information which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your Personal Information on your behalf directly to another information controller;
- Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;
- Right to lodge a complaint with the relevant information protection authority: We hope that we can satisfy any queries you may have about the way in which we process your Personal Information. However, if you have unresolved concerns, you also have the right to complain to the information protection authority in the location in which you live, work or believe an information protection breach has occurred.
These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your Personal Information.
10. Data Retention
We keep your Personal Information to enable your continued use of BCB Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering legislation, or to resolve disputes and/or legal claims or as otherwise communicated to you. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your Personal Information is described below.
- Personal Identifiable Information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as is required under such laws.
- Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis and until you (a) unsubscribe, or we (b) terminate your account. Thereafter we will add your details to an unsubscribed list to ensure we do not inadvertently market to you.
- Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes.
- Recording of voice calls with you may be kept for a period of up to six years, for audit/ compliance purposes and to resolve disputes and/or legal claims.
- Information collected via cookies, web page counters and other analytics tools is kept for a period of up to one year from the date of the collection of the cookie of the relevant cookie.
11. Contact Information
Our information officer can be contacted via email at [email protected] and will work to address any questions or issues that you have with respect to the collection and processing of your Personal Information.
12. Notices and Revisions
If you have any concerns about privacy at BCB, please contact us, and we will try to resolve it. You also have the right to contact your local Information Protection Authority.
Our business changes regularly, and our Privacy Policy may change also. You should check our websites frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account with us.