Privacy Policy

Version: 0.1

Last Updated: 20.04.2024

 

Welcome to EUREVO Evolution s.r.o Privacy Policy and Notice (“Privacy Policy”). Please take a moment to read it carefully before sharing any information with us about you or any other person.

 

1.                Introduction

EUREVO Evolution s.r.o (“EUREVO”, “Company”, “we” or “our”) registered in Cimburkova 916/8, Žižkov, 130 00 Prague 3, Czech Republic, offers digital asset sale and buy services (“Service”) to users (“Users”) through its trading desk on crypto asset service platforms (“P2P Platform”) that offer Peer-to-Peer transactions. Only for your convenience, the P2P Platform could be, exemplary, Binance, OKX, Bybit and others. In respect of our business model, we process some of your personal data as a data controller.

This Privacy Notice aims to explain the personal data we process about you, our purposes and methods for such processing, the legal basis we rely on, transfer of your personal data, and your rights, in accordance with our obligation to inform you under the Czech Data Protection Act 2000 (the “Law”).

Please note that our Services are not intended for minors under the age of 18 years, and we do not knowingly or intentionally collect data relating to minors.

 

2.                Personal data we process about you

Depending on whether and how you use our Services, we will process different kinds of personal data.

 

Category of personal data

Examples of personal data

İdentity Data

•                 Legal name,

•                 Date of birth,

•                 Czech or foreign ID number,

•                 Nationality,

•                 Biometric information, including a selfie (visual image of your face),

•                 Information on your identity card including national identity card, driving license, passport or residence permit.

Contact Data

•                 Email address,

•                 Phone number,

•                 Address details.

Social Identity Data

•                 Political background,

•                 Close connections,

•                 Risk assessment,

•                 Compliance assessment.

Transactional Data

•                 Details about payments,

•                 Details of transactions you make while you use our Services.

Financial Data

•                 Bank account information,

•                 Source of funds/wealth.

Technical Data

•                 Internet protocol (IP) address,

•                 Device type, category, and model,

•                 Operating system and name of the browser,

•                 Location data.

Usage Data

•                 Your requests for our Services,

•                 Your identification number as our user,

•                 Your interests, feedback and complaints,

•                 Information you provided to us during your communication with us.

3.                Our Purposes for Which We Use Your Personal Data

Your personal data will only be processed for specific, explicit, and legitimate purposes and in accordance with the applicable laws and good faith. In addition, we will ensure to process your personal data in connection to the specific purposes of processing, in a limited and appropriate manner.

Below, we specified our legal basis for processing your personal data, and in some cases we may rely on more than one legal basis. Please contact us if you would like to learn more about those specific legal grounds.

Personal data

Purpose of processing

Legal basis

To process and execute your instructions and orders while we provide our Services

•                 Identity Data

•                 Financial Data

•                 Transactional Data

•                 Performance of a contract

To carry out and comply with anti-money laundering requirements

•                 Identity Data

•                 Contact Data

•                 Social Identity Data

•                 Contact Data

•                 Financial Data

•                 Expressly stated by laws

•                 Compliance with our legal obligations

To process, collect and transfer payments, fees and to collect and recover payments owed to us

•                 Identity Data

•                 Contact Data

•                 Financial Data

•                 Transactional Data

•                 Performance of a contract

To conduct risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, PEP checks, fraud and other background checks, detect, investigate, report and prevent financial crimes, respond to complaints

•                 Identity Data

•                 Contact Data

•                 Social Identity Data

•                 Financial Data

•                 Transactional Data

•                 Technical Data

•                 Expressly stated by laws

•                 Compliance with our legal obligations,

•                 Performance of contract

•                 Legitimate interests

To use the services of financial institutions, crime and fraud prevention companies

•                 İdentity Data

•                 Social Identity Data

•                 Contact Data

•                 Technical data

•                 Transactional Data

•                 Financial Data

•                 Performance of a contract

•                 Legitimate interests

To respond to the demand of authorities

•                 Identity Data

•                 Contact Data

•                 Social Identity Data

•                 Financial Data

•                 Transactional Data

•                 Technical Data

•                 Expressly stated by laws

•                 Compliance with our legal obligations

To be able to follow legal processes, to use as evidence in disputes that may arise, and to protect the company in legal claims

•                 Identity Data

•                 Contact Data

•                 Social Identity Data

•                 Financial Data

•                 Transactional Data

•                 Technical Data

•                 Usage Data

•                 Legitimate interests

Cookies

We do not use cookies, or other tracking applications on the p2p platforms.

However, we encourage you to review the Cookie Policy of the P2P Platform that you are using in order to access our services and our trading desk. We do not control P2P Platforms and are not responsible for their privacy practices. We do not act as a data controller or data processor in terms of data processing activities carried out by P2P Platforms through cookies and other tracking technologies.

Sale or transfer of business

In order to meet our legal obligations, or based on our legitimate interests we may need to process your personal data in connection with, or during the negotiations of any acquisition, merger, sale, bankruptcy, or other change of control.

4.                How We Collect Your Personal Data

We use different methods to collect information from and about you by automatic or non-automatic means, including through:

•                 Your direct interaction with us where you give your personal data (including forms, emails, live chat communications);

•                 Publicly available information on the Internet (websites, news, articles, etc.)

•                 Fraud and crime prevention agencies and tools managed by third parties.

•                 Blockchain networks through the p2p trading platform.

 

5.                Our Legal Basis

Your collected personal data may be processed based on the following legal grounds which are specified in the Law:

•                 Explicit consent: for instance, asking you to leave a review and take a survey.

•                 Such processing is expressly stated by laws: for instance, processing of your personal data in order to comply with our obligations under the Law on Prevention of Laundering Proceeds of Crime.

•                 Necessity for the establishment of performance of the contract: for instance, processing of your personal data to allow you to visit and use our Services, and execute your transactions and orders.

•                 Compliance with our legal obligations: for instance, sharing your personal data with authorised public institutions and organizations, including the Financial Crimes Investigation authorities, in order to comply with our obligation to submit documents when requested within the scope of the prevention of laundering proceeds of crime and financing of terrorism.

•                 Establishment, protection and defence of a right: for instance, processing of personal data in order to monitor and follow notices, lawsuits and other legal processes sent to us, and defend ourselves in case of a dispute.

•                 Our legitimate interests: for instance, processing of your personal data in order to ensure the security of your transactions, to carry out communication activities.

 

6.                Transfer of Your Personal Data

Your personal data may be shared with our suppliers, business partners, information technology service providers, our group companies, authorised public institutions and organisations and legally authorised persons for the purposes described in the Section 3 of this Privacy Notice, in accordance with the conditions regarding the transfer of personal data under the Law and within the scope of the data processing conditions set out in the Law.

For instance, your personal data may be transferred to the following third parties:

•                 Our suppliers and group companies in order to provide our services securely, to perform and report transactions and orders, and to carry out analysis and audits;

•                 Identity verification companies to conduct required identity verification checks;

•                 Fraud or crime prevention agencies to comply with our obligations to help preventing financial crimes in a broad sense;

•                 Information technology service providers to ensure the security of your transactions and securely store of your personal information;

•                 Business partners to improve, customise and personalise our services;

•                 Third parties to whom we lawfully transfer or may transfer our rights and duties specified under our terms of use;

•                 Authorised public institutions and organizations and legally authorized persons in order to comply with our legal obligations and to carry out the processes related to any dispute that may arise;

•                 Regulatory and law enforcement authorities, in order to comply with our obligations to provide information, documents and submission within the scope of the prevention of laundering proceeds of crime and financing of terrorism.

We will also make sure that we meet the conditions set out in the Law in cases where we transfer your personal data to third parties abroad.

 

7.                Data Security

We have put in place appropriate measures to safeguard your personal data. We have access matrixes for our employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are under the duty of confidentiality. Our security measures could be addressed briefly as follows:

•                 organisational measures (including but not limited to staff training and policy development);

•                 technical measures (including but not limited to physical protection of data, pseudonymisation and encryption); and

•                 securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).

Any suspected personal data breach will be notified to you and relevant authorities within a reasonable time specified by data protection legislation.

 

8.                Your Legal Rights

Please make sure you are aware of your rights specified under the Law. If you need more detailed information or wish to exercise any of your rights, please contact us.

You may:

•                 request information whether your personal data is processed or not;

•                 request information as to if your personal data have been processed;

•                 request information about the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose;

•                 request information about the third parties to whom your personal data are transferred domestically or abroad;

•                 request the rectification of the incomplete or inaccurate data, if any;

•                 request the erasure or destruction of your personal data if there are no applicable legal basis for processing;

•                 request reporting of operations as the rectification of the incomplete or inaccurate data or the erasure or destruction; to the third parties to whom your personal data have been transferred;

•                 object to the occurrence of a result against you; by analysing the data processed solely through automated systems;

•                 claim compensation for the damage arising from the unlawful processing of your personal data.

You can send your requests regarding these rights to us via e-mail address through [email protected] , attaching the documents enabling your identification. Please note that we may request that you provide some details necessary to verify your identity.

Your data subject requests will be answered free of charge. However, if the requested transaction requires an additional cost, fees may be required.

Your requests will be answered electronically as soon as possible and within (30) thirty business days at the latest, depending on the nature of the request. If your request is rejected, your application will be answered with justification.

 

9.                Our duties and your duties in case of changes

We keep our Privacy Notice under regular review and update it from time to time. Please check for new versions of the Privacy Notice. If there are material changes, we will let you know about them. It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if there would be a change in your personal information.

 

10.             Data Controller Information

Legal Name

EUREVO Evolution s.r.o

Address

Cimburkova 916/8, Žižkov, 130 00 Prague 3, Czech Republic

Email Address

[email protected]

 

 

EUREVO Evolution s.r.o., is a limited liability company registered in Czech Republic (registration number 21462151).
The Company is regulated and supervised by the Financial Analytical Office (FAU) to provide services related to virtual assets.

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