Privacy Policy

ONLINE PRIVACY STATEMENT

Last Revised:  This Privacy Policy shall be effective from August 2024.

This is the privacy statement for BVNK Holdings Limited and all of its subsidiaries and affiliates (BVNK, we, us, our).

BVNK respects and protects the privacy of visitors to our websites and our customers who use our services. To ensure transparency, this Privacy Policy describes our data handling practices when you (i) register, access or use content we own or operate on the website located at www.bvnk.com, www.layer1.com, http://digitalwallet.eg/ or any other associated websites we own or operate (site(s)); (ii) represent one of our clients; (iii) work with us as a service provider or introducer; or (iv) visit a BVNK office or register to attend a BVNK event.

Please take a moment to read through this Privacy Policy. If you have any specific questions about it, you’re welcome to contact us at dpo@bvnk.com and we will be happy to give you further clarity.

A printable version of this Privacy Policy is available here.

 

Information about this Privacy Policy

This Privacy Policy outlines what data we collect from you, how we use this information, and how we take care in disclosing this information, in compliance with data protection laws, including the General Data Protection Regulation (EU 2016/679) (“GDPR”), the Spanish Data Protection Act (Organic Law 3/2018), and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) (collectively, “Data Protection Laws”).

By accessing and reading our Privacy Policy, you acknowledge you have been informed about the processing of your personal data that we may process from you.

Terms not otherwise defined in this Privacy Policy shall have the same meaning as is found in the applicable Data Protection Laws.

 

PRIVACY STATEMENT

What is the lawful reason BVNK uses to process personal data?

The four lawful reasons BVNK uses to process personal data are set out in Article 6 of the GDPR.

Processing will only be lawful if and to the extent that at least one of the following applies:

  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Consent).
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Contract Performance).
  • processing is necessary for compliance with a legal obligation which we are subject to (Legal Obligations).
  • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Legitimate Interest).

1. Consent

Where we process personal data as a result of Consent, we ensure that consent is freely given, specific and informed, and established by a clear affirmative act. Where Consent is withdrawn, we have set out (below) how this may be undertaken by the data subject.

 

2. Contract Performance

Where we enter into a contract with third parties, processing of personal data may, as a matter of course, be necessary in order to execute such a contract or take pre-contract preparation steps.

 

3. Legal Obligations

Where there are legal obligations which apply to BVNK, processing of personal data may be required by law.

 

4. Legitimate Interest

Where we process personal data as it is necessary for the purpose of our legitimate interests, we do so on the basis of a balanced evaluation of our interests and the rights and freedoms of the data subject which require protection. We have concluded that the way we manage the processing of personal data results in a cumulation of data subject protections which show that the balance is in favour of BVNK being able to rely on Article 6.1(f) of the GDPR as a lawful reason to process personal data.

 

Why does BVNK need to collect and store personal data?

We collect and store personal data to provide our clients, customers, suppliers or third parties with the service they require or provide as a party to a contract with us, or a third-party with an interest in BVNK. We do not process personal data for any reason other than this purpose.

We only keep personal data for as long as is necessary to undertake this purpose. We are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of the data subject’s right to privacy.

 

What categories and types of personal data does BVNK collect?

If you wish to use any of our services, we will collect and retain certain relevant data of yours, including some of your personal data.

We collect the following categories and types of personal data:

 

Category of Personal Data Collected Type of Personal Data Collected
Identifiers Names, Address, Date of Birth, Signature, Unique Identifiers/Personal Descriptors, IP Address, Cookies/Online Tracking Technologies, Communications from You.
Sensitive Personal Data Government Issued Identification Numbers, Nationality.
Financial Information Transaction Information, Credit Information, Account Authentication Details, Contractual Details.
Professional or Employment-Related Information Socio-Demographic Details, Work Details, Employer, Profession and Education Background.
Internet or Other Technical Information Details about your devices and technology that you use to access our services, Log Data (the type of browser you use, access times, pages viewed, and the page you visited before navigating to our Services), Device Information (data about the device you use to access our services, including information about the device’s software and hardware, Media Access Control ("MAC") address and other unique device identifiers, device token, mobile network information and time zone).
Geolocation Data Location
Commercial Information Products/Services Provided to You, Consumption Data (data about your consumption habits relating to your use of our services, including which purchases you make with both virtual and real currencies.

 

How does BVNK collect my personal data?

We collect your personal data directly from you, from third parties operating on our behalf, from cookies and other online tracking technologies; and from publicly available resources (public records and information about you that is openly available on the internet.

 

How does BVNK handle my personal data?

The following principles are observed in the handling of your data:

  1. We will only collect personal data for a purpose consistent with the purpose for which it is required. The specific purposes for which information is collected will be apparent from the context in which it is requested, as they are set out as follows.
  2. Personal data will only be processed for a purpose compatible with that for which it was collected, unless you have consented to an alternative purpose.
  3. We do not retain your data indefinitely. We will destroy or delete any personal data that is no longer needed by us for the purpose it was initially collected, or subsequently deleted. BVNK is however required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements, contractual obligations and agreed practices. Personal data may be held in addition to these periods depending on individual business needs. 

 

How will BVNK use the personal data it collects about me?

We may use your personal data to:

  1. Provide, maintain, and improve the features and functionality of our site and services, based on our legitimate interest and/or the performance of the contractual relationship between you and us.
  2. Provide for internal non-marketing or administrative purposes, based on our legitimate interest.
  3. Provide information to you about updates and new services, based - when relevant - (i) on the performance of the contractual relationship between you and us or, (ii) if relevant, your consent; or (iii) if relevant, our legitimate interest.
  4. Process billing and collection of any fees based on the performance of the contractual or pre-contractual relationship between you and us.
  5. Meet our legal and regulatory obligations in terms of the applicable laws.

To comply with legal and regulatory requirements in rendering our services, BVNK may be required to disclose information about you and/or your account to the following trusted third parties, namely:

  • Our agents, affiliates and/or professional advisors.
  • Service providers assisting us in processing or otherwise fulfilling transactions and/or providing required services.
  • Law enforcement, regulatory and governmental agencies if or when requested.

We don’t use your personal data to:

  • Send commercial or marketing messages to you, without your prior consent.
  • Sell your data to third parties.

 

Will BVNK share my personal data with anyone else?

We do not sell your personal data.  However, we may share your information in the manner and for the purposes described below:

  • Internally, where such disclosure is necessary to provide you with our services or to manage our business;
  • With third parties who help manage our business and deliver services, pursuant to a contract between the third party and BVNK. In these circumstances, the third party may be another controller, processor or sub-processor. Where the third party is a processor or a sub-processor, they are obliged amongst other things, to keep your details secure, and to use them only to fulfil their contractual obligations to BVNK under a processing agreement or terms which comply with Data Protection Laws;
  • With agencies and organisations working to prevent fraud in financial services;
  • With our regulators;
  • To comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.

When they no longer need your personal data to fulfil this service, they will dispose of the details in line with BVNK’s data retention policy, or as otherwise set out in the processing agreement.

 

We operate globally

The personal data we collect from you may be transferred to, stored and processed outside of the jurisdiction in which you live. The laws of those countries may vary from the laws applicable in your own country. Data gathered in the European Economic Area (EEA) may be transferred to, stored and processed at a destination(s) outside of the EEA. Said international data transfers will be carried out in strict compliance with the Regulation and after having executed the relevant Standard Contractual Clauses with the recipients of the data.

Your account is stored by BVNK on a secure server maintained and operated by third-party service providers. These third-party providers are bound by and adhere to the relevant data processing agreements, in compliance with Data Protection Laws.

 

Your data protection rights

Depending upon where you reside, certain choices and rights may be available to you under applicable Data Protection Laws. If you have questions about what rights may apply to you, please contact us at dpo@bvnk.com.

 

You may have the right to:

  • have access to your personal data by submitting a request to us;
  • know the personal data we have collected about you, including:
    • the categories of personal data we have collected about you;
    • the categories of sources for the personal data we have collected about you;
    • the specific pieces of personal data we have collected about you;
    • our business or commercial purpose for collecting or selling your personal data; and
    • the categories of third parties to whom we have sold or shared your personal data, if any, and the categories of personal data that we have shared with each third-party recipient;
  • have your personal data deleted;
  • have your personal data corrected if it if wrong;
  • have the processing of your personal data restricted;
  • object to further processing of your personal data, including to object to marketing from us or sharing for the purposes of cross-contextual behavioral advertising or profiling;
  • make a data portability request;
  • withdraw any consent you have provided to us;
  • restrict any automatic processing of your personal data;
  • limit our use of any sensitive personal data to those uses which are necessary to perform services or for other business purposes; and
  • complain to the appropriate Supervisory Authority.

Residents of the State of California may also request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

For your protection, we will take steps to verify your identity before fulfilling any request.

You also have a right to complain to a Supervisory Authority, in particular:

  • a list of European Union data protection authorities can be found here;
  • the United Kingdom’s data protection authority’s contact details can be found here;
  • the South African data protection authority’s contact details can be found here;
  • the Singapore data protection authority’s contact details can be found here; and
  • the California Privacy Protection Agency contact details can be found here.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights.

 

Do Not Track Requests

Our sites are not designed to respond to "do not track" requests from browsers.

 

Security measures for your personal data

We take all appropriate and reasonable technical and organisational measures to prevent the loss of, damage to or unauthorised destruction of personal data and the unlawful access to or processing of such data. We have systems in place to control your data in a way that minimises its exposure.

We will take reasonable steps to identify all reasonably foreseeable internal and external risks posed to your personal data under our possession or control and establish and maintain appropriate safeguards against any risks identified.

 

Under what circumstances will BVNK contact me?

The personal data we process is subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure. We will get in touch with you where this is required under Data Protection Laws.

 

Third-Party Links

We may provide links to other websites or resources provided by third parties. These links are provided for your convenience only.  We have no control over the contents of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party links on the sites, you do so entirely at your own risk and subject to the terms and conditions of those websites.

 

Children

We do not knowingly collect personal data from children under the age of 13 through our sites. If you are under 13, please do not give us any personal data. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Privacy Notice by instructing their children never to provide us personal data. If you have reason to believe that a child under the age of 13 has provided personal data to us, please contact us, and we will endeavour to delete that personal data from our databases.

 

Revisions to this Privacy Policy

This Privacy Policy may be revised from time to time so we can keep it up to date with global best practices, but we will always let you know when we do via email.

 

CONTACT DETAILS

Email: dpo@bvnk.com

Address: Level 3, 89 Charterhouse St, Barbican, London EC1M 6PE

Address: 101 West Broadway, Suite 1975, San Diego, CA 92101

For US individuals, you may also call us at 888-315-0331.

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