This Privacy Notice sets forth BYBLET's privacy practices with respect to information collected from Site visitors and users of the Services or the Site (each a “User” or “you”, with the term “your” to be construed accordingly), including personally identifiable data ("Personal Data"). This Privacy Notice explains how BYBLET collects and protects your Personal Data. By becoming a User through the Site or by otherwise submitting Personal Data to us, you give your consent to the collection and use of your Personal Data by BYBLET as explained in this notice. Capitalised terms used but not defined herein shall have the meanings ascribed to them under the Terms and Conditions of Use.
The information we collect varies depending on the type of activity you are performing on our Site or how you use the Services. At times we will collect personal information from you and in other instances our Site will collect other information in order to deliver our Services or as part of operating the Site. For example, when you become: (i) a user of the Platform by completing the account opening process or otherwise submit Personal Data in order to receive Services, e.g., when you make a wire transfer or tell us where to send money; or (ii) an issuer that issued or is issuing utility coins and wants to list the utility coin through the Site by completing the necessary process and providing the appropriate disclosure of information, we may collect information about you, as further described below:
We collect Personal Data from you when you apply for, access and use products and Services offered by BYBLET. This information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions between or among you and our affiliated companies or others. The Personal Data that we collect may include your name, address, citizenship, telephone number, email address, Social Security Number, date of birth and financial related information (including assets, net worth, income, account balances, account transactions, investments and investment experience).
When you interact with BYBLET through the Site or Services, we receive and store certain information about you. Such information, which may be collected passively, may specifically identify you.
When you use our Site, we gather certain other information automatically ("Other Information") and store it in log files. This information may include Internet Protocol ("IP") addresses, browser type, Internet Service Provider ("ISP"), referring/exit pages, operating system, date/time stamp and clickstream data.
We may collect information about you from third parties in order to meet certain legal or regulatory requirements and/or to protect against fraud. In some circumstances, we may obtain information from global terrorist watchlists and/or information about criminal offenses or convictions.
In operating the Site, we may also use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features.
The use of cookies by any of our affiliates or service providers is not covered by our privacy policy. We do not have access to or control over these cookies. Our partners use session ID cookies to make it easier for you to navigate our Site and use our Services.
BYBLET uses the Personal Data you provide and Other Information in a manner that is consistent with this Privacy Notice. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to respond to your communication. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such Services and to monitor your use of such Services. In addition, we use your information to provide, analyze, administer, enhance and personalize our Site and Services to you, examples of how we use your information include to:
1. Deliver our Services as requested;
2. Communicate with you about our Site or Services;
3. Provide you with information about goods or services that may interest you;
4. Present you with marketing relating to our Services and more relevant display;
5. Produce advertisements and to share promotional events;
6. Conduct research and analysis to improve our Site and Services;
7. Manage our Services offerings, and assess the effectiveness of our marketing efforts;
8. Analyze and improve the content and functionality of our Site and Services;
9. Improve our products, services, and business;
10. Prevent, detect, or investigate security concerns, including fraud;
11. Comply with applicable laws, regulations, or industry requirements; and
12. Fulfill any other purpose for which you provide it or to which you consent.
If at any time you wish not to receive any future marketing communications, or you wish to have your name deleted from our mailing lists, please contact us immediately as indicated below. Note, however, we will send you administrative communications that are reasonably necessary to the Service, such as billing or service notifications.
We may share Personal Data and Other Information with any of our affiliates and third parties in accordance with applicable laws, regulations, or industry requirements and in the ways that are described below.
We employ third party service providers to perform certain functions on our behalf, such as hosting, email and postal delivery, product and service delivery, analytics services, data maintenance and storage, ID verification, processing applications and payments and completing transactions. When we employ another company to perform a function on our behalf, we only provide them with the information that they need to perform that specific function. These companies are authorized to use your Personal Data only as necessary to provide these services to us.
If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or any other business transaction, we may share information, including Personal Data, subject to confidentiality arrangements.
We may also share Personal Data and Other Information:
1. To prevent, detect, or investigate security concerns, including fraud;
2. To protect and defend our operations, rights, privacy, safety or property, or that of its subsidiaries, affiliates, officers, employees, contractors, agents and/or partners;
3. To comply with applicable laws, regulations, or industry requirements; or
4. With law enforcement if required by law or in order to prevent fraud or other potential wrongdoing.
We do not share your personal information with third parties for their direct marketing purposes.
Personal Information may be stored and processed in our affiliates, third party partners, or any country where we have operations or where we engage service providers. BYBLET, its affiliates, third party partners, or service providers may transfer, store, and process your Personal Information throughout the world, including but not limited to, Ireland, the United Kingdom (UK), Malta, Singapore, Australia, and the United States.
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we ensure that the transfer of your Personal Information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.
• We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate international transfers of Personal Information to third countries.
• Additionally, we may rely on adequacy decisions from the European Commission, where available. In certain instances, we may rely on certain exemptions for sharing personal information (such as with law enforcement outside of the EEA) in emergency situations, pursuant to Article 49(1)(f) of the General Data Protection Regulation, as amended from time to time.
• For UK personal data, adequacy decisions are issued by the UK Secretary of State under the Data Protection Act 2018, as amended from time to time. Where no adequacy decision applies, we implement safeguards recognised under UK law, such as the International Data Transfer Agreement (IDTA) or the Addendum to the Standard Contractual Clauses of the European Union.
Please contact us if you have any questions regarding international data transfers.
The security of your Personal Data is important to us. To protect your Personal Data from unauthorized access and use, we use administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These measures include computer safeguards and secured files and buildings. When you enter sensitive information (such as financial or personal information) on our website, we encrypt the transmission of that information using secure socket layer technology (SSL). We also use third party ID verification to ensure our Users' true identities are validated.
We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
This Privacy Notice applies only to the Site. The Site may contain links to other web sites or third-party services not operated or controlled by BYBLET, including social media features, (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Site do not imply that BYBLET endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. The date the Privacy Notice was last revised is identified at the top of the page. Your continued use of the Site after we email you or indicate that we made changes to the Privacy Notice is deemed to be acceptance of those changes.
Please feel free to contact us if you have any questions about our Privacy Notice or information practices.
