Effective Date: January 9, 2019
Your privacy is important to us.
We are Nino Finance, Inc. ("Data Controller", "we", "us", "our", "Nino Finance", "the Company", "Owner", "Operator").
We want you to obtain personalized experiences anytime, anywhere, on any device. This requires us to collect personal information from you. However, we want to put you in control of that personal information. We want you to be aware at all times where and how your personal information is being used. This is of paramount importance to us.
So let’s describe what this policy tells you. It explains:
- What information we may collect about you
- What we may do with the information we collect about you
- Whether we share your information with anyone else
- The types of cookies we use and how you can reject these cookies
- Where we store your information
- How we keep your information secure
- Your rights in relation to your information
At Nino Finance we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.
How We Collect Information and What Information We May Collect About YouInformation you voluntarily provide
If you contact us (by phone, email or through our website, or app), we may keep a record of that correspondence indefinitely in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
If you report a problem with CoinTracker, we may keep that information indefinitely in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
The information you give may include your name, address, telephone number and email address.Information we collect about you and your device
Through your use of CoinTracker, you will be subject to different types of personal data collected and different manners of collection. We will collect and process your personal data in a lawful, fair, and transparent manner and, where appropriate, with your knowledge or prior explicit consent. Personal data will be relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
Types of Personal Data
The following types of personal data will be collected by the Company through CoinTracker:
- REGISTRATION: You, as a user of CoinTracker, may be asked to register an account to use CoinTracker or access any of the services thereon. During the process of your registration, you will be asked to provide your email address, a password, your Google credentials (if you opt for registration through Google), your Coinbase credentials (if you opt for registration through Coinbase), and any cryptocurrency wallets that you would like to disclose. We use these personal data to provide the services to you and ensure the security of CoinTracker.
- BILLING: If you elect to use any of our paid services, you will be asked to provide billing information, such as, but not limited to, your credit card number and billing address. This personal data will be used specifically for providing you with the services you have purchased. The payment and billing information may be stored for the time period as required by applicable law for lawful purposes (e.g., accountancy records).
- CRYPTO AND FINANCIAL INFORMATION: Depending on how you choose to interact with the CoinTracker services, you may be asked to provide your cryptocurrency wallet and general portfolio information and other information that will assist us in providing the services to you. You may also be asked for API access for certain accounts which may be aggregated for you on CoinTracker.
- USE: Through your use of CoinTracker, you may be asked questions about how to improve CoinTracker or you may, at some point, communicate with representatives of CoinTracker. We will receive your email address, as well as the contents of your communications, answers to questions and any other form of contact between you and CoinTracker. We will use personal data contained in such communications only for the purposes of providing you with the requested information and for improving the services.
- AUTOMATIC COLLECTION: We may collect information from you through automatic tracking systems on your device or through the CoinTracker application programming interface, or API, or other web and mobile analysis software. We may also receive certain usage data, such as your IP address and referral source. We use this information for our legitimate business interests, including analyzing usage of CoinTracker.
- COMBINED OR AGGREGATED INFORMATION: We may combine or aggregate some of your personal data in order to better serve you and to better enhance and update CoinTracker for your and other consumers’ use, or to create public posts about insights or trends in the domain.
We may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from CoinTracker, including referral links we may post on CoinTracker in order to analyze what kind of users visit CoinTracker, how they find it, how long they stay, from which other websites they come to CoinTracker, what pages they look at, and to which other websites they go from CoinTracker. In case your non-personal data are aggregated with certain elements of your personal data in the way that we may become able to identify you, such non-personal data will be treated as personal data.
How Information Is Used
We respect data protection principles and process personal data only for specified, explicit and legitimate purposes for which such personal data were provided. We primarily use your personal data to enable your use of CoinTracker and supply the services requested by you. We may also use your personal data for the following purposes:
- Asking you about your experience with us;
- Communicating with you about your user account with us;
- Analyzing our aggregate user data;
- Enforcing our Terms of Service;
- Providing customer services to you;
- Ensure that content from CoinTracker is presented in the most effective manner for you and for your device to achieve the most user-friendly navigation experience;
- Provide you with marketing information about us and our services (you may opt out from receiving such information at any time);
- Defend our servers against malicious attacks;
- Advising you about updates to CoinTracker or related items; or
- Providing you with information about services that are similar to the services used by you
Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
Our Use of Aggregated and Anonymized Information
We may share anonymized usage data which does not identify you specifically with third parties. We may combine your data with those of other users of CoinTracker and share this information in aggregated and anonymised form with third parties to help us improve the design and delivery of our software tools, increasing the effectiveness of all users.
Newsletters and Marketing Communications
From time to time, we may send you informational communications related to CoinTracker, such as announcements about updates to CoinTracker. you may also receive information from us that is specifically about your use of CoinTracker or about your account with us, including information about security breaches or other privacy-related matters. Please note that such communication does not fall within the scope of direct marketing communication.
After we obtain your explicit prior consent, we may use your personal data for direct marketing purposes, such as:
- Sending you a newsletter;
- Offering you new products, services, mobile applications, and/or recommendations;
- Profiling; and
- Delivering you targeted information regarding promotions related to CoinTracker.
If you decide at any time that you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in the communications, turn off communications in your settings page, or contact us at [email protected].
Please note that we do not collect any sensitive data about you (e.g., your health information, opinions about your religious and political beliefs, racial origins and memberships of a professional or trade associations, social security number). Should we intend to process any sensitive data collected from you, we will seek your explicit consent in advance.
How Information Is Stored And Kept SecureProtection of Personal Data
We protect your personal data by using reasonable security safeguards against loss or theft, unauthorized access, disclosure, copying, use, or modification. Your personal data are contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. We implement a variety of security measures, such as encryption and pseudonymisation, when users enter, submit, or access their personal data to maintain the safety of your personal data. Please note, however, that no system involving the transmission of information via the Internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your personal data very seriously and we therefore take all reasonable steps to ensure the ongoing confidentiality, integrity, and availability of your personal data. Nevertheless, we are not liable for any loss, theft, unauthorized access, disclosure, copying, use, or modification of your personal data that occurs outside our reasonable control.Breach notification
Should a personal data breach occur, we will inform the relevant authorities without undue delay and immediately take reasonable measures to mitigate the breach. We will notify you about such a breach via email as soon as possible but no later than within seven business days.Retention period
Your personal data will be kept for as long as it is necessary to provide you with the requested services. When your personal data are no longer necessary to deliver the requested services, we will delete your personal data immediately, unless we are obliged by law to retain such personal data for a specific period of time.
There are two types of cookies, namely, persistent cookies (i.e., cookies that remain valid until their expiration date, unless deleted by the user before that date) and session cookies (i.e., cookies that are stored on a web browser and remain valid until the moment when the browser is closed). We use both persistent cookies and session cookies.
- Understanding and saving user’s preferences for future visits;
- Keeping track of advertisements; and
- Compiling aggregate data about traffic and interactions in order to offer better experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf
Most Internet browsers accept cookies automatically, although you are able to change your browser settings to control cookies, including whether or not you accept them, and how to remove them. You may also be able to set your browser to advise you if you receive a cookie, or to block or delete cookies.
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. Users can also choose to visit CoinTracker anonymously, but you may not be permitted to access any of the services.
How Information May Be Shared Or Disclosed
We may disclose your information if we believe that it is reasonable to do so in certain cases, in Our sole and exclusive discretion. Such a disclosure or transfer is limited to the situations when the personal data are required for the purposes of (1) provision of the services, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. Please note that some third parties may be located outside of the jurisdiction in which you reside.
Such reasonable disclosure cases may include, but are not limited to:
- Satisfying any local, state, or Federal laws or regulations;
- Responding to requests, such as discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
- Bringing legal action against a user who has violated the law or violated our Terms of Services;
- As may be necessary for the operation of CoinTracker;
- Generally cooperating with any lawful investigation about our users; or
- If we suspect any fraudulent activity on CoinTracker or if we have noticed any activity which may violate our Terms or other applicable rules
We may utilize third party service providers, from time to time or all the time, to help us with CoinTracker and to help to serve you. Such third-party service providers may include:
- Data storage companies (e.g., Amazon Web Services and other cloud storage providers);
- User information logistics providers (e.g., Google Analytics or other analytics companies which help us track general user information and usage);
- Web hosting companies;
- Newsletter providers; and
- Other parties who assist us in operating CoinTracker and conducting our business
Please note that some non-personal data may be provided to third parties for marketing, advertising, or other uses. We also allow third-party behavioral tracking which may include non-personal data.
Transmittals From Us
From time to time, we may send you informational communications related to CoinTracker, such as announcements or other information. You may also receive information from us that is specifically about your use of CoinTracker or about your account with us, including information about security breaches or other privacy-related matters.
By providing any personal information to us, or by using CoinTracker in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.
Third Party Links
Before visiting and providing any information to any such third-party websites and applications, you should familiarize yourself with the applicable privacy practices and take reasonable steps necessary to protect your personal data.
Accessing, Correcting, and Erasing Personal Data
We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your personal data as current as possible and update your personal data through CoinTracker if necessary.
You may at any time review or change the personal data in your user account or terminate your user account by logging into it through CoinTracker and updating your personal data. Upon your request to terminate your user account, we will deactivate or delete your account and information from our active databases.
If you would like to access, modify, or delete your personal data that are processed through CoinTracker, please send us an email to [email protected]. We will answer your request within a reasonable timeframe.
We do not market to any individual under the age of 18 years old. Individuals under 18 years of age may not create an account on CoinTracker. However, we cannot distinguish the age of people accessing CoinTracker. If a person under 18 has provided us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact us at [email protected] requesting us to destroy or de-identify the personal data.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
When transferring data from the European Union, the European Economic Area, and Switzerland, CoinTracker relies upon a variety of legal mechanisms, including contracts with our Users. CoinTracker complies with the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to the United States. You can find CoinTracker’s Privacy Shield certification here (see Nino Finance, Inc.). You can also learn more about Privacy Shield on its website.
Nino Finance, Inc. is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance — free of charge to you. We ask that you first submit any such complaints directly to us via [email protected]. If you aren't satisfied with our response, please contact JAMS. In the event your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.
Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, CoinTracker will provide individuals access to personal data about them. Nino Finance, Inc. will also take reasonable steps to enable individuals to correct, amend, or delete personal data that is demonstrated to be inaccurate.
CoinTracker is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CoinTracker complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
Updates, Modifications, or Revisions
Complaints about Handling of Personal Data
After you submit such a complaint, we will send you an email within five business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe.
If you are a resident of the European Union and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
Change of Control
If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate CoinTracker and provide the Services. The new owners will be obliged to comply with this Policy.
Changes to our Policy
Any changes we may make to this Policy will be posted on this page. Where it makes sense because the changes are material, we will notify you by email or in another appropriate manner such as when you next interact with CoinTracker.