Last Updated: December 1, 2021
Your privacy is important to us.
1. PERSONAL INFORMATION COLLECTION
Personal Information You Provide: we collect the following categories of personal information from you:
- Identification Information:
We collect your email address and password.
- Cryptocurrency Information:
We collect the public wallet address for each cryptocurrency holding you connect to the Service and the associated transaction history including the dates and amounts of each transaction. Depending on how you configure your CoinTracker account, we may pull the transaction history directly from the blockchain, collect it from the exchange that processed the transaction for you (if you give us read access to your account at the relevant exchange) or get it from materials or information you upload through the Service.
- Financial Information:
Our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.
- Communication Information:
We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys, or requests for market research seeking your opinion and feedback.
- Social Media Information:
We maintain a social media presence on platforms like Twitter and YouTube. When you interact with us on social media, we may receive personal information that you provide or make available to us based on your settings, such as your profile information.
Internet Activity Information:
When you visit, use, and interact with the Service, the following information may be created and automatically logged in our systems:
- Device Information:
The manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Service. The information we collect may vary based on your device type and settings.
- Usage Information:
information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We use Google Analytics, a web analytics service provided by GoogleLLC (“Google”), to help collect and analyze usage information. Here are more details about how Google uses this information.
- Location Information:
We may derive a rough estimate of your location from your IP address when you visit the Site.
- Email Open/Click Information:
We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
The following technologies may be used to collect Internet Activity Information:
Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Personal Information Collected from Third Parties:
Tax Information: if you share your CoinTracker account with third party tax advisors, and those tax advisors cannot identify you based on the Identification Information we collect when you create your account, we may collect additional information about you from your advisors, such as the last four digits of your social security number, to permit those advisors to identify your account. Please note, however, that we do not collect or store your full social security number.
Third-party login information: when you link, connect, or log in to the Service with a third-party service, such as Google, you direct such third parties to send us information associated with your account on that service, as controlled by that service or as authorized by you via your privacy settings at that service.
Personal Information We Create: we use your cryptocurrency information to create reports relating to your capital gains and losses and tax liability.
2. PERSONAL INFORMATION USE
Your personal information is used for the following purposes:
Service Deliver, including to:
Track your cryptocurrency portfolio’s performance and help calculate related capital gains and losses;
Provide and secure the Service;
Create, maintain, and authenticate your account;
Give your tax advisors access to your account (with your consent); and
Process transactions through our third-party payment processors.
These activities are necessary to perform our contract with you.
Communicating with You: to send you updates about administrative matters such as changes to our terms or policies, provide user support, and respond to your requests, questions, and feedback. These activities are necessary for our legitimate interests of providing user support and keeping you informed of administrative changes.
Service Improvement, including to
improve the Service and create new features;
personalize your experience; and
create and derive insights from de-identified and aggregated information.
These activities are necessary for our legitimate interest in analyzing how the Service is used, enhancing and personalizing users’ experience, improving the Service, and developing new features and services.
Marketing and Advertising: we and our advertising partners may use your personal information for marketing and advertising purposes, including:
Direct Marketing: to send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers, and events via email.
Where necessary we obtain your consent for marketing.
Compliance and Protection, including to:
Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities;
Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
Audit our compliance with legal and contractual requirements and internal policies; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
These activities are necessary to comply with our legal obligations and for our legitimate interest in exercising or protecting rights and maintaining safety and security.
3. PERSONAL INFORMATION SHARING
We do not sell, rent, license, or lease your personal information to third parties. However, in certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:
Service Providers: to assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with service providers, including hosting services, cloud services, and other information technology services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.
Professional Advisors: we may share personal information with our professional advisors such as lawyers and accountants where doing so is necessary to facilitate the services they render to us. If you share your CoinTracker account with one of your tax or other advisors we will share your personal information with those advisors.
Business Transfers: if we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
Legal Requirements: we do not volunteer your personal information to government authorities or regulators, but we may disclose your personal information where required to do so for the Compliance and Protection purposes described above.
4. PERSONAL INFORMATION RETENTION
To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.
5. YOUR RIGHTS AND CHOICES
As a CoinTracker user you have the following rights:
Knowledge. You can request information about the categories of personal information that CoinTracker has collected about you, the business purpose for collecting your personal information, the categories of sources from which the personal information was collected, whether CoinTracker has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information (we provide this information in the Personal Information Collection, Use, and Sharing sections above);
Access and Data Portability. You can request a copy of the personal information that we maintain about you in a structured, commonly used, and machine-readable format.
Deletion and Correction. You can ask us to delete or correct the personal information that we hold about you.
Objection. You may have the right to object to how we use your personal information.
Restrict Processing. You may ask us to suspend our processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.
Opt-Out. You can opt-out of marketing communications by following the opt-out or unsubscribe instructions contained in any marketing communication we send you. You can also control the communications you receive through your settings page.
Please contact us to exercise your rights. Your authorized agent may submit requests in the same way. After receiving your request we may request additional information to verify your identity. You can also submit a complaint to the data protection regulator in your jurisdiction. We will not treat you differently for exercising your rights.
Do Not Track. We honor “Do Not Track” signals and do not track, plant cookies, or use advertising when we receive a “Do Not Track” signal.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
CoinTracker is headquartered in the US. The US may have data protection laws less stringent than or otherwise different from the laws in the EU. Transfers of your personal information to CoinTracker in the US are necessary to perform the agreement we have entered into, or are about to enter into, with you.
Before July 16, 2020, we relied on our EU-U.S. Privacy Shield certification to transfer personal information from the EU to the U.S. On July 16, 2020, the European Court of Justice ruled that the EU-U.S. Privacy Shield is no longer available for these transfers. Before September 8, 2020, we relied on our Swiss-U.S. Privacy Shield certification to transfer personal information from Switzerland to the US but on September 8, 2020 the Swiss Federal Data Protection and Information Commissioner determined that the Swiss-U.S. Privacy Shield is no longer available for these transfers. We continue to comply with the Privacy Shield Principles described in the Privacy Shield section below as required by the US Department of Commerce.
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 EU to the U.S.
CoinTracker 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 contact us. If you are not satisfied with our response, please contact JAMS. In the event your concern still is not addressed by JAMS, you may be entitled to 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 information about them. CoinTracker will also take reasonable steps to enable individuals to correct, amend, or delete personal information that is demonstrated to be inaccurate.
CoinTracker is responsible for the processing of personal information 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 information from the EU, including the onward transfer liability provisions.
Our Service is not directed to children who are under the age of 18. CoinTracker does not knowingly collect personal information from children under the age of 18. If you believe that a child under the age of 18 provided personal information to CoinTracker please contact us and we will delete that information.
8. LINKS TO OTHER WEBSITES
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are 100% failsafe and we cannot guarantee the security of your personal information. You use the Service at your own risk.
11. CONTACT US