What type of information we collect
How we use the information
Coinmama collects and uses the information to provide you with an online platform, aimed at allowing you to purchase and/or sell virtual currency in an easy, fast and safe way, as well as making your experience of using the platform smoother and better. Coinmama may further use your Personal Information to send you marketing materials regarding the Services.
With whom we share the information
Coinmama does not rent out or sell your Personal Information. Coinmama shares Personal Information with third parties only in connection with the Services provided to you, and only with selected trusted third-party service providers. Coinmama shares with such service providers the minimum information necessary. Coinmama may also share Personal Information with law enforcement agencies or arbitrators for legal or compliance reasons or in the event of a dispute.
How we protect the information
Coinmama employs industry standard practices to ensure the safety of your information and prevent unauthorized use of any such information.
Individuals under the age of 18 are not allowed to use the Services. If you are under the age of 18, you should not provide any Personal Information to us or use or try to use the Services.
You have the right to decide whether to accept cookies. You can see which cookies we use and exercise your acceptance preferences of cookies served on our Site by clicking the Cookie Settings link found at the bottom of the page.
Cmama Ltd. and/or parent company New Bit Ventures Ltd. (both companies, jointly and severally, shall be referred to as "us", "we" or "Company") respect the privacy of our users (each, "you" or "User") and are committed to protecting the privacy of Users who access, visit, use or engage with our website or any other online services we provide (collectively: the "Services").
We may collect two types of data and information from our Users.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:
For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations.
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
(i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers);
(ii) processing such information to assist us with our business operations;
(iii) performing research, technical diagnostics, personalization and analytics;
(iv) identity verification and fraud prevention services (these recipients include Forter – to learn more about Forter's data protection practices, please visit https://www.forter.com/service-privacy-policy); and
(v) transmitting promotional and informational materials, in accordance with our marketing policy (see below under "Marketing").
Please note that some of the recipients are considered as Data Controllers, in respect of the Data Subject’s Personal Data (these recipients include, among others, Worldpay: for more information about Worldpay's data protection practices, visit https://online.worldpay.com/terms/privacy, or ProcessOut: for more information about ProcessOut's data protection practices, visit https://www.processout.com/privacy-policy/).
We may also disclose Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, 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 affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
You acknowledge that third-party service providers may use your Personal Information or any information you submitted via the Services for analytics purposes, while ensuring that their processing of such information only results in anonymized and aggregated data.
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to Personal Information, including through adequate contractual measures.
We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we cease any further use of your Personal Information (for example, you may ask that we stop using or sharing your Personal Information with third-parties) or that we remove your Personal Information (subject to any other legal obligation that may require us to keep the information).
However, please note that the exercise of these rights is not absolute and may be subject to other regulatory requirements or our legitimate interests.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at email@example.com.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information in discordance with the laws, you can file a complaint with the applicable data protection authority.
We retain the information we collect for as long as needed to provide the Services (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements (unless we are instructed otherwise). 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. Under applicable regulations, we will keep records containing account opening documents, communications, and anything else as required by applicable laws and regulations.
To the extent that we process biometric data (including any biometric information or biometric identifier), we will retain such data only in accordance with the provisions of the applicable laws, and following the satisfaction of the initial purpose of collecting or obtaining such data or following passing 3 years of your last interaction with us (whichever occurs first), we will instruct Au10tix to permanently destroy biometric identifiers associated with you and your biometric information as detailed in Au10tix's biometric data policy (here: https://www.au10tix.com/legal/biometric-data-policy/).
We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.
We take great care of implementing and maintaining the security of the Services and your information. We aspire to continuously employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied, or otherwise, that we will manage to prevent such access.
If you feel that your privacy was treated in discordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at firstname.lastname@example.org.
Your Personal Information, such as your full name, email address, etc., may be used by us, or by our third-party subcontractors to provide you with promotional materials, concerning our Services.
Out of respect to your right to privacy, within such marketing materials, we provide you with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word "remove" to email@example.com.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not use the Services or provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that an individual under the age of 18 has shared any of their information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at firstname.lastname@example.org.
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at email@example.com.
Our details are as follows:
New Bit Ventures Ltd., company #514907880 – 5 Shoham, Ramat Gan 5251001, Israel;
Our EU representative (for EU residents):
Cmama Ltd., company #672704 – 42 Pearse St., Dublin D02 YX88, Ireland.
Last revision: 19 March 2023