Privacy Policy

Last Updated: 1 August , 2018

Bwise Limited. (“Bwise”, “we”, “us” and “our”) is committed to protecting the privacy of those who visit our website at http://www.bwise.io/ (the “Site”) and those who register for the services we offer on the Site as described by the Terms of Use at http://www.bwise.io/terms-conditions (the “Services” and the “Terms of Use”). This Policy describes the information we collect, how we use and disclose such information and the measures we implement in order to maintain and protect the information. For the purposes of applicable EU data protection laws and unless otherwise stated, we are the data controller and we are responsible for the collection and use of your Personal Information (as defined below).

THE INFORMATION WE COLLECT
If you chose to register to our Services, you will be required to create an account and provide us with some Personal Identifiable Information, such as your name, email address and phone number. Furthermore, when you decide to withdraw your Bitcoins from your account, you will be required to provide us with the target address to which you wish to transfer the Bitcoins.

While using our Site and Services, we may also automatically collect information that your browser sends whenever you visit our Site. Such information may include your IP address, the type of device and operating system you are using, the domain from which you are visiting, language information and additional information with respect to your usage.
We may also request you to provide additional personal identifiable information and KYC information such as: taxpayer or government identification number, a copy of your government-issued identification, copies of utility bills, date of birth and any other proof of your identity as we may request, all as may be required by any applicable law and regulations.
(Some of the information collected which is Personal Identifiable Information is hereinafter referred to as “Personal Information”).
In general, users are not obligated by law to provide us with any information. However, without providing it you will not be able to receive the Services, which require registration and provision of Personal Information, as further detailed above. We will only process Personal Information upon your consent, or where it is necessary to comply with legal obligations which we are subject to (such as compliance with anti-laundering laws), or where we have a legitimate interest to process data, providing such processing does not override your fundamental rights and freedoms.

We also collect non-descriptive, non-identifiable statistical information about how many visitors use our Services, how our users use the Services and what Services our users are accessing (the “Aggregated Information”).

We also record the transactions made via the Services, such as the amount of Bitcoins you deposit and withdraw, the amount of interest gained, the withdrawal destination address, etc., and any additional information you may disclose to our customer support team through our email address at [email protected] (“Transactions“).

USE OF COOKIES, WEB BEACONS AND OTHER TRACKING TOOLS
We and our third party service providers collect information about you, your device, and your use of the Service through cookies, clear gifs (a.k.a. web beacons/web bugs) (“Web Beacons”), and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature, and access times for a web page or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the Service. Some of our Services may also include social media features, such as the Facebook “like” button, and widgets, such as the “share this” button. These social media features that collect certain information are either hosted by a third party or hosted directly on our Site and your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
Cookies are small text files that are saved by your browser when you access our Site. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service.

Web Beacons: Web Beacons help us better manage content on our Site by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send.
You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
Delete existing Tracking Tools.
Disable future Tracking Tools.
Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set.

HOW WE PROTECT AND STORE PERSONAL INFORMATION
Bwise uses reasonable organizational and technical security measures designed to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, including without limitation firewall, data encryption technologies, authentication tools and information access controls. Note however that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by unauthorized third parties. Therefore, although we use reasonable efforts to protect your information, we cannot guarantee the security of any information you provide us. If you know or have reason to believe that your Bwise Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Bwise Account, please contact us following the instructions in the Contact Us section below.

HOW WE USE THE INFORMATION
We use the information listed above to:
Provide you with the requested Services and transactions.
Operation and improvement of the Site and our business and Services and to customize your user experience.
Provide you customer service, including responding to your questions, feedback and complaints.
Correspond with you on Service related issues.
Protection from fraud or security threats.
Compliance with applicable laws and regulations, including reports to Anti Money Laundering Authorities.

We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, Service information (including marketing, promotions, contests, surveys), etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Furthermore, we use Aggregated Information for statistical analysis of how users make use of the Services so we can also better improve the quality of our Services and customize your user experience.

We will not use your Personal Information for purposes other than those set out in this Policy, without your prior explicit consent. From time to time we may request your consent to share your Personal Information with third parties and to that extent we will provide you with the necessary information.
For the avoidance of doubt, we will not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent.

MINORS
Bwise does not knowingly collect information from or about any individual who is under 13 years of age or knowingly allows children under the age of 13 to register for our Services. If you are under 13, do not register or attempt to register for any of our Services or send information about yourself to us. If we learn that we have collected or have been sent Personal Information from a child under the age of 13, we reserve the right to delete such Personal Information as soon as reasonably practical. If you believe that we might have collected or been sent information from a child under the age of 13, please contact us at [email protected]

SHARING YOUR PERSONAL INFORMATION
We may disclose your Personal Information to third parties in the following ways:
At your direction.
To hosting providers or cloud platforms.
To service providers that support the operation and maintenance of our Services.
To comply with law or a legal proceeding (including court or government order to subpoena), to detect, prevent, or otherwise address fraud, security or technical issues and to enforce this Policy and/or our Terms of Use.
In the event we are involved in or subject to, a merger, acquisition, change of control, financing or sale of business or assets, information collected from you may be transferred to one or more third parties involved in such transaction, and, upon such transfer, the relevant third-party privacy policy or policies may govern further use of the information.

We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

TRANSFERRING YOUR PERSONAL INFORMATION OVERSEAS
Any Personal Information which we may collect may be transferred to, processes and stored at destinations outside your territory and/or outside of the European Economic Area (“EEA”), where your Personal Information may not be protected by the same standards. By using the Site and the Services, you explicitly consent to such transfer and use of Personal Information outside your territory, for the following reasons:
Where our hosting provider or cloud platform is outside your territory or outside the EEA.
If necessary for providing you with the Services you request.

HOW YOU CAN ACCESS, CHANGE OR DELETE YOUR PERSONAL INFORMATION
You may have a legal right under certain applicable laws (for instance if the User is an E.U. citizen) to receive, rectify, erase, and restrict the Personal Information that we collect, to object to processing and, if processing occurs based on consent, to withdraw your consent.
Should you wish to modify, delete or retrieve your Personal Information collected through the Site, you may do so by contacting us at the address detailed below. We shall verify your request and then make efforts to respond within 90 days, however, deletion of data may take longer.
For any request or question regarding deletion or amendment of Personal Information, you can contact our Data Protection Officer at the contact details listed below and we shall make efforts to respond and support your request.
We will retain your information only for as long as required to provide you the Services and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Subject to the above, once your account is deleted, we will delete all your Personal Information other than the Personal Information required to maintain the log that records the Transactions.

Under some jurisdictions (such as under certain E.U. regulations), a user has a right to withdraw its consent at any time. In such a case, the withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

HOW YOU CAN CONTACT US ABOUT PRIVACY QUESTIONS
If you have questions or concerns regarding this Policy, you are welcome to send us an email or otherwise contact us at the following address:
VIA E-MAIL
[email protected]

IN WRITING
Bwise Limited.
Address: Harju maakond, Tallinn, Mustamäe linnaosa, Laki tn 30, 12915
Or contact Bwise’s Data Protection Officer:
Benjamin Engel
E-mail: [email protected]

E.U. citizens have the right to lodge a complaint with a supervisory authority (Data Protection Authority in your jurisdiction) in case of a breach of any E.U. data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.

CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Policy at any time, and when required by law, we will notify you of such changes. If we make any material changes to this Policy, we will notify you by email (the e-mail address specified in your account).

LAW
The law governing the provision of this Policy is the laws of Estonia and any disputes arising in respect hereof shall be governed exclusively by the courts of Estonia