Last modified: 01.08.2022
We collect two types of data and information from Users who access the Services.
The first type of information is non-identifiable information pertaining to a User(s), which may be made available or gathered via your access to the Services (“Non-personal Information”). We are not aware of the identity of a User from which the Non-Personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. browser type, language preference, access time, etc.) which may be collected in order to enhance the functionality of the Services. We may also collect such information on your activity on the Services (e.g. clicks, actions, etc.) as required to provide them.
The second type of information is individually identifiable information, namely information that identifies an individual or which may, with reasonable effort, identify an individual (“Personal Information”). Such information includes:
- Contact information and any Magic Square account (including any account as part of Magic Affiliates network) information: When you register to the Services, or access the Services, or contact us for any other purpose, you may be asked to provide us or our trusted third party service providers with your full name, Magic Square account username, Magic Square password, email address, or phone number.
- Information related to sale or delivery of cryptographic tokens: When you contact us for the purpose of participating in a sale of any cryptographic tokens, or for the purpose of purchasing or receiving of such cryptographic tokens, you may also be asked to provide us or our trusted third party service providers with your digital wallet address, full home address (country, state/province, zip code, city, street, house number), gender, date of birth, formal identification information (such as government issued identity documents, e.g. among others national identity card, Passport or passport number, driver’s license, visa, or details of any of the aforementioned documents, or any other information we, in our sole discretion, may find required), images of identification documents, images of proof-of-residence (utility bills, bank/credit card statements, government-issued letters), images of yourself (selfie photos), as well as any other information we, in our sole discretion, deem necessary for our compliance with any legal or regulatory obligations, including among others any anti-money laundering (AML) or combating the financing of terrorism (CTF) laws or regulations or securities laws or regulations, Know Your Customer (KYC) or customer due diligence (CDD) or any reporting or record keeping requirements (e.g., among others, contents of KYC questionnaire and responses thereto, employment status, profession and job title or position, field of activity of employing company or own business, name of employing company or own business, URL to the website of employing company or own business, signature sample, ultimate beneficiary of purchased cryptographic tokens, etc.), or any transaction documents related to any cryptographic token delivery, including verification of qualified or accredited investor status or any other status (including, among others, proving that you do not come from a specific country which may currently, or in the future, be restricted by the Company at Company’s sole discretion) under any applicable laws or regulations or under securities laws or regulations in any jurisdiction, as well as any other information you agreed to share with us or with our third party service providers.
- Device information: We may also collect pseudonymized (which cannot directly identify you) Personal Information from your device. Such information includes IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Services.
- Communication information: We may collect and keep information from your communications with us.
- Voluntary information which is collected from time to time (for example, through surveys) to enable us to improve our services or consider the wider needs of our users or potential users, or voluntary information that might be collected from you upon request and subject to your specific consent, for the purpose of provision of any of the Services to you.
If we associate Non-Personal Information with Personal Information, we will treat such information as Personal Information.
We are working closely with third parties (including, for example, our business partners, sub-contractors, etc.) and may receive information about you from them to the extent permitted by applicable laws. For example, we may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Services), traffic analytics vendors, fraud prevention agencies and others. In particular, digital wallets and their providers may provide us with your digital wallet address and certain other information you choose to share with digital wallets or their providers. We may also receive your data from third party providers, which may conduct KYC, or CDD, or any other screening or AML or CTF-related procedures on our behalf. We may combine this information with the information we have already collected from you via the Service in order to provide you with, and to and improve, our Service.
The legal bases for processing depend on the Services you use and how you use them. This means we collect or process your Personal Information only where:
- It is necessary for the performance of our contractual obligations towards you and providing you with our Services.
- Subject to your consent.
- When we need to process your data to comply with a legal obligation to which we are subject.
- To protect and accomplish our legitimate interests and to comply with our legal obligations.
- Providing the Services.
- Communicating with you – If you have contacted us, for any reason, we will use your information in order to further communicate with you and handle issues raised by you.
- Conducting statistical and analytical purposes, intended to improve the Services. Providing you with the Services.
- Ensuring compliance with our terms, policies and applicable laws and regulations.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies, digital wallets or their providers, and subcontractors.
- Providing you with the Services, including providing a personalized display of our Site;
- Storing and processing such information on our behalf;
- Performing research, technical diagnostics or analytics;
- Conducting KYC, or CDD or any other screening or AML or CTF-related procedures;
- Other identification and verification purposes;
- Marketing purposes.
We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable laws, regulations, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
In any case we will conclude that disclosure of Personal Information is necessary, we will only disclose that portion of the Personal Information that is required in order to satisfy the basis for disclosure. We will share the Personal Information under appropriate safeguards.
This section addresses the specific rights applying to residents of the EU or residents of other jurisdictions that grant the below rights.
Depending on your jurisdiction, you may request to:
- 1.Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
- 2.Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
- 3.Request rectification of your personal information that is in our control.
- 4.Request erasure of your personal information.
- 5.Object to the processing of personal information by us.
- 6.Request to restrict processing of your personal information by us.
- 7.Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements under applicable laws.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
We will retain your personal information for as long as necessary to provide the Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may keep records containing user Personal Information, account opening documents, communications and anything else, if and as, required by applicable laws or regulations.
Transfer of Data Outside the European Economic Area (“EEA”)
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Cookies and Tracking Technologies
When you visit or access our Site we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies (collectively, “Tracking Technologies“). Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Site, improve our Site’s performance, perform analytics and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources and, as a result, such data may become Personal Information.
How to manage your cookie settings – there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively:
For other browsers, please consult the documentation that your browser manufacturer provides.
The Services are intended to the use of individuals over the age of majority in the territory they reside in and in the territory of their citizenship, and in any case is not intended to the use of individuals under the age of 18 (“age of majority“). In the event that we become aware that a user under the age of majority has shared any information, we will discard such information. If you have any reason to believe that an individual under the age of majority has shared any information with us, please contact us at: [email protected].