This Privacy
Statement describes how RynoxCoin collects, uses, and shares the
Personal Data that it receives from you. It answers the following
questions:
How do we collect Personal Data about you?
What Personal Data do we collect?
Cookies and Similar Tracking Technologies
How do we use your Personal Data, and on what legal basis do we collect your Personal Data?
How do we keep your Personal Data safe?
How do we share your Personal Data?
Do we transfer your Personal Data outside of the European Union?
What are your legal data privacy rights?
How long do we retain your Personal Data?
Notice to California Residents
How do we protect children’s privacy?
How do we use your Personal Data to inform you and market to you?
How do we make changes to this Privacy Statement?
Where does this Privacy Statement apply?
Who can you contact if you have further questions or requests about your privacy?
RynoxCoin
or the “Service” is offered by Rynox Funds HQ Inc. to individuals
residing in the U.S., by Rynox Funds Europe Limited to individuals
residing in the U.K., by Rynox Funds Lithuania UAB to individuals
residing in the EEA, and by Rynox Funds Worldwide Ltd. to individuals
residing elsewhere. Throughout this Privacy Policy, the term
“RynoxCoin”, “Rynox Funds”, “we”, “us” or “our”
refers to the relevant entity that provides the Service to you.
It
is important that you read this Privacy Statement together with any
other privacy statement or fair processing notice we may provide on
specific occasions when we are collecting or processing Personal Data
about you so that you are fully aware of how and why we are using
your data. This Privacy Statement supplements the other notices and
is not intended to override them.
We
collect Personal Data about you both directly and indirectly when you
register, open and use a RynoxCoin account. We also collect the
information that is sent to us by your device to improve your
experience. If you are using RynoxCoin on a location-enabled device
we may also collect geographical location data or use various means
to determine your location (such as sensor data from your device that
may, for instance, provide data on nearby cell towers and Wi-Fi
access spots). We may also automatically collect technical data about
your equipment, browsing actions and patterns by using cookies,
server logs, and other similar technologies. Please see the section
on Cookies
and Similar Tracking Technologies for
additional information.
We also receive data about you
indirectly from third parties, for instance technical data from
analytics and advertising partners like Google; from identity
verification providers and other screening services; and affiliated
and non-affiliated third parties, such as credit bureaus and other
financial institutions.
We only collect
the Personal Data necessary to offer and support our RynoxCoin
services and meet our legal and regulatory obligations. It may be
collected directly from you or indirectly from other sources and an
overview is provided below.
Identity
verification data: To
verify your identity, we collect your name, address, phone, email and
facial image (selfie). We may also require you to provide additional
Personal Data for verification purposes, including your date of
birth, taxpayer or government identification number, or a copy of
your government-issued identification. We may obtain information from
affiliated and non-affiliated third parties, such as credit bureaus,
identity verification services, and other screening services to
verify that you are eligible to use RynoxCoin.
Financial
data: We may collect
various information regarding your finances from third parties and
this may include accounts and credit and debit cards you hold,
balances, transactions, and a risk score.
Account
activity data: We collect
information about your transactions using RynoxCoin, as well as other
details of products and services you have purchased from
us.
Application
use data: We may collect
data on your interaction and use of RynoxCoin. This includes visits
to our website or app, sign-up activity, your debit or credit card,
other payment details to enable you to use RynoxCoin, along with any
additional information you may disclose to our user support team in
order to resolve problems you report.
Your
device data: We collect and
process your internet protocol (IP) addresses, your login data,
browser type and version, time zone setting and location, browser
plug-in types and versions, operating system and platform and other
technology on the devices you use to access RynoxCoin.
Marketing
data: We collect and
process your preferences in receiving marketing from us, and your
email address.
We and third
parties on our behalf may employ various tracking technologies, such
as cookies. and other similar technologies (collectively, “Tracking
Technologies”) to collect additional Personal data automatically as
you interact with our Services, that help us to personalize your
experience with our Service, and help us better manage content on our
Service by informing us what content is effective.
Cookies
Cookies
are small data files stored on your hard drive by a website. Cookies
help us make our website and Service and your use of them better by
allowing us to recognize your browser and capture and remember
certain information. We may use cookies and similar technologies for
various purposes, including to:
Analyze our web traffic using an analytics package
Identify whether you already visited our Sites
Test content on our Sites
Store information about your preferences
To recognize when you return to our Sites
Track advertising attribution statistics
Our Sites may use
a ‘load balancer’ to store an identifier on your browser to help
keep you connected to the same web server throughout your visit, for
a smoother browsing experience.Similarly, session cookies enable our
individual web servers to keep track of your progress throughout your
visit. When you submit data through a form such as a contact page or
comment box, cookies may be set to remember your user details for
future correspondence.
We may use the following
third-party cookies:
Cloudflare - to keep the connection stable and to identify spammers.
Google Analytics (include Ad tags) - website traffic tracking and user ad targeting. It helps us to analyze how you use our sites along with the performance of various advertisements we place.
Hotjar - we use Hotjar in order to better understand our users’ needs and to optimize the RynoxCoin service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site."
LinkedIn Ads - user ad targeting and advertisment performance.
Twitter Ads - user ad targeting and advertisment performance.
If
you do not want RynoxCoin to deploy cookies and other similar
technologies in your browser, you can decline these via our cookie
consent banner, opt-out by setting your browser to refuse some or all
cookies, or notify you when a website tries to set a cookie in your
browser software. If you choose to disable cookies in your browser,
you can still use the Website, although your ability to use some of
the features may be affected. If you want to learn the correct way to
modify your browser settings, please use the Help menu in your
browser or review the instructions provided by the following
browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari
Desktop, Safari Mobile; and Android browser.
If you want
to exercise your rights regarding personal data collected via cookies
and similar tracking technologies, please the What
are your legal data privacy rights section
below.
Analytics
Our
Site and our third-party technology providers use third-party
analytics services (such as Google Analytics) to evaluate your use of
the Sites, compile reports on activity, collect demographic data,
analyze performance metrics, and collect and evaluate other
information relating to the Sites and Internet usage. These third
parties use cookies and other technologies to help analyze and
provide us the data. For more information on how to opt-out Google
Analytics tracking, click here.
You
can opt-out of targeted advertising by using the links
below:
Google
Twitter
LinkedIn
Listed below are
the ways in which we may use and process your Personal Data.
To provide you with a service: It may sound obvious, but we need to make RynoxCoin workin the first place. Without your name, credit/debit card information, and other details; and information about your interaction and use of RynoxCoin and the technology you use to access RynoxCoin, we simply could not offer you our products and services.
To verify your identity: As a financial institution, it is essential that we are able to confirm the true identity of our users. There are rules and regulations across the globe that require we identify our customers, including laws concerning anti-corruption, anti-bribery, anti-terrorism, and anti-money laundering. We use Veriff to verify your identity by determining whether a selfie you take matches the photo in your government-issued identification. Veriff’s facial recognition technology collects information from your photos that may include biometric data, and when you provide your selfie, you will be asked to agree that Veriff may process biometric data and other data (including special categoriesof data) from the photos you submit and share it with us. Automated processes may be used to make a verification decision. Veriff’s privacy policy describes its collection, processing, storage and use of your personal data in more detail.
To verify your address: We use Ekata to validate your physical address. Automated processes may be used to make a verification decision. Ekata’s privacy policy describes its collection, processing, storage and use of your personal data in more detail. In lieu of Ekata, we may use Trulioo to validate your physical address. Automated processes maybe used to make a verification decision. Trulioo’s privacy policy describes its collection, processing, storage and use of your personal data in more detail. We additionally may require further address verification and validation through our partner, SumSub by requesting that you provide us with documentation verifying your physical address suchas bank statements, utility bills, Internet/cable TV/house phone line bills, tax returns, council tax bill, and or government-issued certifications of residence. SumSub’s privacy notice describes its collection, processing, storage and use of your personal data in more detail.
To perform your transactions: To verify that you are eligible to use RynoxCoin and perform the transactions you request, and also to ensure compliance with regulatory requirements (e.g., anti-money laundering laws) and our own internal policies, we must receive and share various information regarding your finances with third parties including accounts you hold, balances, transactions, and a risk score. Please review our sub-processor list for more information on these third-parties.
To prevent fraud: We use the personal information we collect in connection with providing you our services to detect and prevent fraudulent activity. We share thisinformation with Unit 21 and Sift, both third party service providers, to assist us with this effort. Unit 21 and Sift use various technologies to capture various device identifiers, such as canvas fingerprinting and may use automated decision making in order to detect and prevent fraudulent activity. For more information on the privacy practices of Unit 21 please review their Privacy Policy. For more information on the privacy practices of Sift, please review their Service Privacy Notice.
To keep your account secure: We use your phone number to verify the number you provide at signup. This includes sending SMS or text messages (including by an automatic telephone dialing system) to any of the phone numbers provided by you or on your behalf in connection with your RynoxCoin account. We additionally use your email address to conduct a verification round trip at each session.
To keep you informed: It is important for security and financial transparency that we keep you aware of your transactions and related activity at RynoxCoin. We will send you emails with confirmations, invoices, technical notices, updates, security alerts, legal and support and administrative messages.
For investigations: Occasionally, we need to look at your account activity in order to check and protect against fraudulent, unauthorized or illegal behavior.
For customer care: We strive to make sure you can easily use RynoxCoin with no headaches, but sometimes you need help. Our customer care team will occasionally need access to your account data in order to fix any issues or answer your questions.
To manage and improve our service: We like to understand how you use and engage with RynoxCoin in order to make sure it is the best it can be. This process includes combining different accounts, transactional, marketing and other data to analyze the effectiveness and performance of our offering.
Marketing: We want you to be aware of product updates, news, events, and promotions and much more. If you consent, we will (i) send you information, including regular personalized emails, to keep you up to date with all things RynoxCoin; (ii) keep you informed of industry updates and much more; (iii) from time to time we may also invite you to take part in our polls, surveys, focus groups and other types of market research; and (iv) if you have consented / opted in by accepting our cookies we collect hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, and where you may have seen RynoxCoin advertisements.
Business operations: We may need to use your Personal Data for our business operations, including internal training and administration, legal compliance, to enforce our legal rights, to protect third party rights, and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
Third parties: If you (i) use RynoxCoin by (a) using an application (whether directly or by authorizing an application to use RynoxCoin, (b) using a link provided by a third-party, or (c) any third party integrations or (ii) if you partner with us in a program or other business arrangement where a third-party intermediary is involved, all such third parties may receive detailed information about your account, your use of RynoxCoin, transaction history or even the ability to take actions on your behalf. When you authorize an application or third party integration via RynoxCoin, you will be notified of what Personal Data will be shared with these third parties. Information collected by these applications or third-party integrations are subject to their terms and policies and are required by contract by Rynox Funds to maintain the confidentiality and security of your Personal Data.
The primary legal
grounds upon which we collect and process your Personal Data are:
through obtaining your consent at the time of collection,
due to the necessity of doing so to perform the services as requested,
in order to comply with our legal obligations, and
to pursue our legitimate interests (e.g., to improve our services).
Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using that data.
We have
implemented security measures to prevent your Personal Data from
being accidentally lost, used or accessed in an unauthorized way,
altered or disclosed.
We protect your Personal Data by
maintaining physical, electronic, and procedural safeguards,
incorporating tested security technologies, in compliance with
applicable laws. We may use network safeguards such as firewalls and
data encryption, enforce physical access controls, and authorize
access to Personal Data only for those people who require access to
fulfill their job responsibilities.
In addition, we limit
access to your Personal Data to those employees, agents, contractors
and other third parties who have a business need to know. They will
only process your Personal Data on our instructions and they are
subject to a duty of confidentiality. Those with access to your
Personal Data are carefully screened, periodically reevaluated, and
are required to keep all your Personal Data confidential.
We sometimes share
your information internally between employees and contractors of our
parent company the Rynox Funds Group (including those based outside
the European Economic Area(“EEA”)), in particular in connection
with activities undertaken jointly or in common with such group
members and/or provide IT and system administration services and
undertake management reporting.
We do not sell, trade or
otherwise transfer your Personal Data to third parties other than
third parties who assist us in operating RynoxCoin, third parties who
assist us in facilitating certain programs and other business
arrangements for which you have expressly agreed to participate,
management and reporting, maintaining compliance with relevant laws
(including compliance with relevant anti-corruption, anti-bribery,
anti-terrorism, and anti-money laundering laws), conducting our
business or supporting our users, or providing you with applications
or services integrated via our API. We require that those third
parties agree to keep this information confidential and secure on the
same conditions and protection levels we provide to you as a user, in
accordance with relevant privacy laws, including the GDPR. A complete
list of our sub-processors can be viewed here.
We
may also release your information to certified and authorized law
enforcement officials when we believe release is appropriate to
comply with the law, enforce our terms or policies, or protect the
rights, property, or safety of RynoxCoin, our users, or others. We
have a set of guidelines for how we engage with law enforcement
officials that are available to the public here.
Finally,
in the event of the sale or transfer of ownership, your data would be
shared with the new owners.
RynoxCoin’s
parent company Rynox Funds is headquartered in the United States.
Many of our affiliates and third party service providers are based
outside the EEA, so processing of your Personal Data may involve a
transfer of your Personal Data outside the EEA and may be maintained
or accessed in servers or files located in countries outside the EEA,
including the United States.
By voluntarily providing your
Personal Data on or via this website or app, you consent to its
transfer, processing and storage in the United States or other
countries outside the EEA, some which have not been deemed by the EEA
to have “adequate” privacy safeguards.
Whenever we
transfer any Personal Data outside the EEA, we will put in place an
adequate level of protection to ensure that any such transfers
comply, and are consistent with applicable EU data protection laws,
including with respect to transfers among Rynox Funds affiliates, the
standard data protection clauses adopted by the EU
Commission.
Please contact us
at data.privacy@Rynoxcoin.com if
you are located in the EU and want further information on the
specific mechanism used by us when transferring Personal Data outside
of the EEA.
You have the right
to:
Access the Personal Data we store and process about you or to request a copy of it to transfer to another service provider.
Request that we correct inaccurate data about you.
Ask us to delete, restrict, or object to us processing your data, although for legal reasons (e.g. anti-money laundering rules and regulations) we cannot always do this.
Request the transfer of your personal data to you or to a third party, in a structured, commonly used, machine-readable format.
Withdraw your consent at any time where we are relying on consent to process your personal data, including for marketing
To lodge a complaint with a supervisory authority.
Your marketing
preferences can be updated within RynoxCoin under your user settings
or through any Newsletter via the “Unsubscribe” link. For all
other Data Privacy inquiries, please submit your request through our
standard customer support process, by contacting our Support
Team.
Also, under
the relevant privacy laws of the EEA (including the European
Union’s General
Data Protection Regulation)
in respect of your EEA Personal Data you may have a number of
important rights. For further information on each of those rights,
including the circumstances in which they apply, see the Guidance
from the European Commissioner’s Office (ECO) on individual’s
rights under the European Union’s General Data Protection
Regulation here.
RynoxCoin’s
parent company Rynox Funds maintains reasonable procedures to help
ensure that your Personal Data is reliable for its intended use,
accurate, complete, and current.
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, as well as other factors required by General Data Protection Regulation or other laws to which we are subject, including those relating to anti-money laundering and counter terrorist financing. Our legal and regulatory compliance obligations require that we retain customer data for a period of 5 years after the end of the customer relationship.
When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable law and regulations.
In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Should you make a Data Subject request through our standard customer support channel, we will retain the minimum required amount of data in order to keep a record of your request and the action we took to resolve it.
Rights
Under the CCPA
Access
to Specific Information and Data Portability Rights – Subject to
certain exceptions, if you are a California resident you have the
right to request a copy of the personal information that we collected
about you during the 12 months before your request. Once we receive
your request and verify your identity, we will disclose to you:
The categories of personal information we have collected about you;
The categories of sources for the personal information we have collected about you;
Our business or commercial purpose for the information collection;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you.
Sale of
Personal Information
You
have the right to request that we disclose to you: the categories of
your personal information that we sold, and the categories of third
parties to whom your personal information was sold. RynoxCoin does
not sell your personal information in its ordinary course of business
and will never sell your personal information to third parties
without your explicit consent.
Deletion
Request Rights
You
have the right to request that we delete any of your personal
information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable
consumer request we will delete (and direct our service providers to
delete) your personal information from our records, unless an
exception applies. To exercise the access, data portability, and
deletion rights described above, please submit a verifiable consumer
request through our standard customer support process, by contacting
our Support
Team.
Use
of an Authorized Agent to Submit a Request
Only
you or a person you formally authorize to act on your behalf, may
make a verifiable consumer request related to your personal
information as a California consumer. If you use an authorized agent
to submit such a request, we will require written proof that the
authorized agent has been authorized to act on your behalf or a copy
of the power-of-attorney document granting that right.
We do not knowingly solicit or collect information from individuals under 18. If we become aware that a child under the age of 18 has provided us with Personal Data, we will close the account and restrict their information. If you believe that we might have collected Personal Data from a child under 18, please contact us using the information below.
In compliance with
applicable laws, we may send you personalized marketing information,
including by email, and such information may include product and
service updates, industry news, our events, activities and offers,
information about our business and personnel and tips. We may combine
your Personal Data such as age, transaction history, account usage to
improve the value and specificity of these communications.
You
can ask us to stop sending you marketing messages or information at
any time by following the “unsubscribe” link on any marketing
message sent to you or by updating your contact preferences directly
on the Rynox Funds Platform. Please note, it may take up to 10 days
for this to take effect. Where you opt out of receiving these
marketing messages or publications, this will not apply to Personal
Data collected by or provided to us in connection with a specific
purpose, request, order, event or activity or any dealings with you,
and you may still receive emails from us relating to the operation of
RynoxCoin, like transaction confirmations.
This version was
last updated on the date indicated above and historic versions are
archived and can be obtained by contacting us. We may update this
Privacy Statement from time to time as we deem necessary or
appropriate in our sole discretion. If there are any material changes
to this Privacy Statement, we will notify you by email, by means of a
notice on RynoxCoin, or as otherwise required by applicable law. We
encourage you to review this Privacy Statement periodically to be
informed regarding how we are using and protecting your information
and to be aware of any policy changes. Any changes to this Privacy
Statement take effect immediately after being posted or otherwise
provided by us.
It is important that the Personal Data
we hold about you is accurate and current. Please keep us informed if
your Personal Data changes during your relationship with us.
This Privacy
Statement applies to all of the RynoxCoin services. This Privacy
Statement does not apply to services that have separate privacy
notices that do not incorporate this Privacy Statement.
This
Privacy Statement doesn’t apply to the information practices of
other companies and organizations that advertise our services or to
services offered by other companies or individuals, including
products or sites that may include RynoxCoin or be linked from
RynoxCoin.
This website and app may include links to
third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to
collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy statement
of every website you visit.
You
can direct any questions or complaints about the use or disclosure of
your Personal Data to us by contacting us as set out below. We will
investigate and attempt to resolve any complaints or disputes
regarding the use or disclosure of your Personal Data as soon as
possible.
If you have any questions about this Privacy
Statement or need to contact us, please email us
at data.privacy@Rynoxcoin.com,
or contact us by mail at 80 East Sir Francis Drake Blvd., Ste. 3D,
Larkspur, CA 94939. All Data Subject Requests should be submitted to
our Customer
Support Team. Rynox Funds
does not process requests received by a privacy automated service
(bot). All requests must come directly from the individual to the
email address noted above.
As Rynox Funds is based in the
United States it has appointed Rynox Funds, Lda. a company
incorporated in Portugal (Co. Number: PT513095136) to be its
representative within the EEA. They may be contacted
at data.privacy@Rynoxcoin.com.
If
you are resident in the European Union and are dissatisfied with the
resolution of your complaint in respect of your EEA Personal Data,
you may contact the EU data protection authority in your jurisdiction
using the contact details provided here for
further information and assistance.
Subprocessor |
Purpose |
Country |
|---|---|---|
Amazon |
Cloud Hosting |
United States |
Checkout.com |
Credit/Debit Card Processing |
United States |
Customer.io |
Customer communications |
United States |
DLocal |
Payment Processor |
Brazil |
Ekata |
Address Verfication Services |
United States |
Trulioo |
Address verification Services |
Canada |
Veriff |
Identity Verification |
Estonia |
SumSub |
Address verification Services |
Germany |
Sift |
Fraud Prevention |
United States |
Twilio |
Automated SMS Services |
United States |
Unit 21 |
Fraud Prevention |
United States |
Zendesk |
Customer Support Ticket Management |
United States |