ENCRYBIT PRIVACY POLICY

Last updated: September 24, 2018

We humbly request you to read this Privacy Policy ("Policy") carefully, which is administered by Incrybit Limited (Hong Kong company number 2676660) ("Company", "We"). It is subject to jurisdiction in Hong-Kong. We gather and utilize the information when the website https://encrybit.io ("Website") is accessed or the online services provided by the Website ("Services") are used.

The Policy is covered under the Terms of Use of the Website.

  • 1. CONNOTATION
    • 1.1. In order to avoid any confusion, please consider the following terms with its respective meaning as described herewith:
    • "Company", “We” means Company and its associated stakeholders (founders, employees, directors, financial advisors, security advisors, ICO advisors, consultants, accountants, equity holders, service providers, parent companies, subsidiaries, affiliates, representatives, and others working for Encrybit on a permanent or contractual basis.
    • "Data" is the information collected from your usage of the Website and its Services
    • "Terms of Use of the Website" indicates the document reciting the terms and conditions for using the Website (the document is subject to change).
  • 2. POLICY APPLICATION AND ACCEPTANCE
    • 2.1. This Policy will be applied right from the moment you gain an access to the Website. Any use of the services provided by the Website adheres to the acceptance of this Policy. The Policy stands for an entire (no omittance of any single word or sentence) acceptance when you access, browse or utilize any of the services. Any part of the Policy non-exemptible.

      The complete acceptance and application of the Policy are applicable to any “individual” or “business” using the Website.
    • 2.2. If any point of the Policy is obnoxious for you or you do not entertain the collection of your Data, then you shall immediately freeze the usage of Website.
    • 2.3. The Data Protection Legislation
      • 2.3.1. The data protection legislation in Encrybit has been the Data Protection Act 2004 (the “DPA”) and Implements Directive 95/46/EC.
      • 2.3.2. On May 25, 2018, Regulation 2016/678 of the European Union on the protection of personal data (“GDPR”) comes into force and will, to the extent that there are GDPR and the DPA (and/or the DPA has not been amended) replace the DPA.
      • 2.3.3. 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.
    • 2.4. Standards for Data Protection
      • 2.4.1. Please be ensured about your personal information shared with us in the following manner:
        • i. It will be used in accordance with law and everything will be transparent to you.
        • ii. The data will be used for the purpose as specified while collection and not any purpose other than that.
        • iii. The data will be collected and used in a competent manner and pertinently defined boundaries during the time of collection.
        • iv. It will be held systematically and updated with time as required.
        • v. It will be taken care that your identity isn’t exposed unnecessarily for a prolonged period.
        • vi. It will be safe.
        • vii. It will be transferred internationally if required and only with mandatory shielding.
  • 3. DATA ASSEMBLY
    • 3.1. Data Provided by you
      • 3.1.1. As the Website deals with sensitive services related to cryptocurrency, the Company is entitled to ask for “Know your Customer” information, which is subject to applicable government norms. We urge you to provide with the requested information as and when required.
      • 3.1.2. The Data requested must be made available to the Company else, the services will not be activated or seized if in use. The final decision rights are with the Company.
    • 3.2. Data Collected by the Company
      • 3.2.1. The Company may automatically collect Data based on your activity or interaction with the Website. To know the type of Data collected, refer article 3.2.2.
      • 3.2.2. The Company collects the following data based on your interaction, activity and services used without any exemption:
        • i. Internet Protocol (IP) address and geographical location;
        • ii. cookie information;
        • iii. browser identification information;
        • iv. information pertaining to device (mobile or personal computer) hardware, operating system, browser details and device identifiers;
        • v. information extracted from your communication with the Website like metadata;
        • vi. information regarding the exact time, date and duration of accessing the Website and its services;
        • vii. third party information if any shared with the Website;
        • viii. information collected from your activities on the Website like search operation, the history, the results and the part visited by you by clicking the search result;
        • ix. Other information.
      • 3.2.3. If your browser blocks the collection of any of the above-mentioned information, then some of the Website services will not be available for use.
    • 3.3. Data Collected by the Company from other sources
      • 3.3.1. The Company is entitled to receive information related to you from other resources as the credentials used to login in a third-party service. The collection of such Data adheres to the third-party service allowance.
  • 4. DATA UTILIZATION
    • 4.1. We will only use your personal data in accordance with The Data Protection Legislation (refer article 2.3) and Standards for Data Protection (refer article 2.4). The Data collected by the Company as a part of this Policy while your interaction with the Website and its Services is intended to be used for the following purposes:
      • 4.1.1. To develop and administer the Website and its services efficiently;
      • 4.1.2. To improve and enhance the performance Website and its services for providing personalized experience;
      • 4.1.3. To develop new offerings, services and conveniences as expected by you;
      • 4.1.4. To detect and prevent any fraud or illegal activities for the protection of your rights and Company’s reputation;
      • 4.1.5. To carry out our research and analyze the Data for enhancing the Website and its services;
      • 4.1.6. To deliver the best catered information relevant to you regarding our services, events or upcoming attractions; and
      • 4.1.7. To verify its compliance with the Terms of Use of the Website.
    • 4.2. The Company will also use cookies and web beacons for collection and association of your Data with your device and browser.
  • 5. DATA SECURITY
    • 5.1. The Company will take care of security measures concerning the Data obtained from you and collected by us. The Policy includes protection of Data collected, stored and processed so that your personal information is refrained from any unauthorized access, modification or data breach.
    • 5.2. The Company is not liable for the loss or leak of Data while transferred over the Internet. We take charge of the Data only after collection.
    • 5.3. The Company is not liable for any Data copied from the public blockchain network.
  • 6. DATA REVELATION
    • 6.1. The acceptance of this Policy hereby claims that you allow the Company to collect, store, process and utilize your Data.
    • 6.2. The Data collected can be disclosed with the personal information in case of following situations:
      • 6.2.1. With your permission and consent to share;
      • 6.2.2. Shared with the following third party organizations for collaboration purpose:
        • i. Members of the Incrybit Limited (Hong Kong company number 2676660) and trusted third parties (including financial partners and banking institutions) who assist us in our provision of the Services to Users (including to parties that provide administrative, KYC provider, wallet provider, telecommunications, trade execution, payment or clearing, prepare and mail account statements, transaction confirmations and other services in connection with the services) on the basis that those parties agree to keep your information confidential.
        • ii. We may also release your personal data to non-affiliated third parties at your direction or for which you have provided your express consent, or if required by law, regulation or any Regulatory Body (such as the Hong Kong Internal Revenue Department, the Hong Kong Customs and Excise Department and other international data protection authorities).
        • iii. Our official sponsors. They will not be allowed to use your data for their personal purposes.
        • iv. External individuals/entities to whom certain functions are outsourced. They will not be allowed to use your data for their personal purposes.
        • v. Legal advisors to take care of the services provided. They will not be allowed to use your data for their personal purposes.
      • 6.2.3. If the Company or any of the Company assets are merged with another organization or acquired in a small portion or as a whole; and
      • 6.2.4. Within the Company premises
    • 6.3. Thus, your data can be shared with third party organizations, which may or may not be a part of our Company or its assets. Apart from getting acquired, the Company can acquire parts or an organization as a whole as required. In case or any change or merger, your personal data will be used and treated in accordance with this Policy.
    • The third-parties will be instructed to use your personal data as intended. They will not be allowed to use your data for their personal purposes.
  • 7. DATA CONSERVATION
    • 7.1. Holding Period for your Personal Data
      • 7.1.1. The Company will hold/retain your personal data taking into account the requirement for the same. It can be from satisfying for the purpose it is collected for, any legal, accounting or reporting consequences.
      • 7.1.2. To decide or discover the holding period of your personal data, the Company will consider the following points:
        • i. Quantity, type and sensitivity of the data.
        • ii. Any kind of adverse consequences occurring due to illegitimate access to your personal data.
        • iii. In case the purpose for which data has been collected can be fulfilled by other alternatives.
        • iv. Legal necessities to be applicable if any.
      • 7.1.3. To have an idea, the Company has a strategy to hold the records for a minimum time period of 7 years even after the termination of agreement between us.
    • 7.2. Legal rights pertaining to your Personal Data
      • 7.2.1. You can exercise the following rights with respect to your personal data shared with the Company:
        • i. Right to have an unambiguous information about the usage of your personal data by the Company.
        • ii. Right to pull back the permission granted to the Company for collecting, processing or sharing your personal data with third party organization at any point of time.
        • iii. Right to get a replica of your personal data held by the Company and to check that it is being processed in accordance with the law.
        • iv. Right to correct or complete the information in your personal data if you feel that the Company holds incorrect or incomplete information about you.
        • v. Right to ask the Company to erase your personal data if you found that it is no longer fulfills the purpose or it has been processed in an illegal way as per your local law. Nevertheless, the Company may or may not fulfill your request in case of any legal consequences if raised at that time. Although, you’ll be notified about the same.
        • vi. Right to impede the processing of your personal data i.e. temporary suspension of your data processing or usage in case of any legal requirement.
        • vii. Right to oppose against the processing of your personal data under particular instances even if being used by the Company for the specified purpose.
        • viii. Right to acquire your personal data from the Company and reutilize it for personal objectives. This is possible only when you have provided your personal data (excluding all other information) to the Company and it is being processed with your permission by automated means or to fulfill a contract.
        • ix. Right to file a complaint in concern with any malfunction with your personal data to the local legal entity. In this case, the Company entertains the issue to be brought up first to them, which can ensure smooth resolution of the issue.
      • 7.2.2. The Company will not charge any kind of fees to operate your rights or acquire your personal data. But if your request is ambiguous or baseless, the Company may choose to ignore the same.
      • 7.2.3. To exercise any of the above-mentioned rights or to access your personal data, the Company will require specific information from you to authenticate your identity. The personal data will be shared to the person who is entitled to receive it. The Company can interrogate you to seek additional information so that they can resolve your request quickly.
      • 7.2.4. The Company requests 30 days of time from its reception to answer genuine requests.
  • 8. PRIVACY POLICY ADAPTATIONS
    • 8.1. The Company holds the right to adapt this Policy at any moment of time and frequency. We request you to keep a check on this section periodically and take active measures accordingly. It will help you to learn if there is any change in protection of your Data.
    • 8.2. As you continue to use the Website, we assume it as your responsibility to check the Policy page regularly and take action in case of any change.
    • 8.3. If you continue using the Website and its services after adaptions in this Policy, then the Company considers it as your acceptance for any change in the Policy and you abide by it.
  • 9. FEEDBACK
    • 9.1. The Company is open to feedback, suggestions or queries regarding the acceptance, implementation and adaptation of this Policy at info@encrybit.com.