Last Updated: October 16, 2020
Your privacy is important to us.
We are Nino Finance, Inc. ("Data Controller", "we", "us", "our", "Nino Finance", "the Company", "Owner", "Operator").
By visiting, using, or registering to use CoinTracker, you consent to us processing your personal information in accordance with this Policy. This is the legal basis upon which we process your personal information as well as because it is necessary for the performance of our obligations under the Terms of Service. By continuing to use CoinTracker, you acknowledge that you have had the chance to review and consider this Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your personal data and the methods of disclosure as described in this Policy. If you do not understand the Policy or do not agree to one or more provisions of this Policy, please immediately cease your use of CoinTracker. You may withdraw your consent at any time by contacting us. At that time, you may also want to remove any cookies which have been placed on any device used to access CoinTracker. Your withdrawal of consent will not affect the lawfulness of any processing carried out by us prior to such withdrawal.
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 collected, shared, and 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
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 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: As a CoinTracker user, you may need to register an account by providing an 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 relevant information for 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. Through such use, 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 purposes provided in this Policy, and the purposes listed below:
- 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
- Ensuring 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
- Providing you with marketing information about us and our services (you may opt out from receiving such information at any time)
- Defending our servers against malicious attacks
- Advising you about updates to CoinTracker or related items, and/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 not listed above or not described in this Policy, 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 provided in this Policy.
User CommunicationsNewsletters and Informational 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.
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.Direct Email Marketing and Advertising
We may use your email address to send you marketing and advertising communications. These communications may include relevant offers, the promotion of new services, targeted information regarding promotions related to CoinTracker, and news about our products and services.Unsubscribe
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 or turn off communications in your settings page.
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 services and software tools, thereby increasing the effectiveness of all users.
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.
Information Storage And SecurityProtection 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 promptly, unless we are obliged by law to retain such personal data for a specific period of time.
- 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
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 Service
- 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 that may violate our Terms of Service, 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 serve you. Such third party service providers may include:
- Data storage companies (such as 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
The third party service providers indicated above may have access to your personal data as part of their contractual relationship with us only if they agree to assure an adequate level of protection of personal data that is consistent with this Policy.
We do not sell, trade, or transfer your personal data to third parties not indicated in this Policy, unless we obtain your prior explicit consent.
Third Party Links
Through your use of CoinTracker, you may find links out to other websites or mobile applications. This Policy does not apply to any of those linked websites or applications. We are not responsible in any manner for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from CoinTracker.
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 reach out to us. 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 requesting us to destroy or de-identify the personal data.
EU-US Privacy Shield and Swiss-US Privacy Shield
When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, CoinTracker relies upon a variety of legal mechanisms, including contracts with our users. CoinTracker complies with the EU-US and Swiss–US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States. You can find CoinTracker’s Privacy Shield certification on the Privacy Shield website.
Nino Finance, Inc. is subject to oversight by the US 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. Should you have any complaints, please let us know directly at [email protected] If you aren't satisfied with our response, please contact JAMS. In the event your concern still is not 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 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
Unless we specifically obtain your consent, any changes to the Policy will apply to the personal data collected on or after the date of the last update that is indicated at the top of the Policy.
It is your responsibility to periodically check this Policy for any such modification, revision or amendment. Any changes made are assumed to have been accepted by you following your continued use of CoinTracker.
For significant changes in the Policy, or where required by the applicable law, we may seek your explicit consent to the changes stated in the Policy.
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.
Complaints about transfers of personal data within the Privacy Shield Framework should be submitted by following the instructions described elsewhere in this Policy.
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.
If you have questions or comments about this Policy, please contact us.