*Last updated: August 3, 2019
natural person, that we may hold about you) is collected, used, stored, disclosed, and removed (each and all referred to as "processing") when you access content we own or operate on the webpages located at www.cethereum.com or any other websites, pages, features, apps, or content we own or operate (collectively, the "Site(s)") and/or when you use the Cethereum wallet, or other Cethereum products or services (collectively, the “Services”).
covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit.
periodic updates about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify CT’s privacy practices or may provide you with additional choices about how CT processes your data.
SHOULD IMMEDIATELY DISCONTINUE ACCESS OR USE OF OUR SERVICES.
2. THE PERSONAL INFORMATION WE COLLECT
other information to provide and improve our products, services, and content (see the section below).
2.3 When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes, in order for you to use our Services. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all or any of our Services when you choose not to share certain information with us.
For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, or request support.
We may use this information in combination with other information we collect about you as set forth in this Policy. Your personal information may also be processed for the purposes of protecting our users from illegal activity, maintaining legal and regulatory compliance and helping us to prevent, detect and investigate fraud, money laundering, terrorism financing and/or other criminal activity or misuse of our Services.
We collect the following types of information:
Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or e-mail address.
Formal Identification Information: Incorporation and corporate subsistence records, non-expired government-issued photo ID cards and information thereon (i.e. passports, driver’s licenses, national identity card, permanent resident cards, citizenship cards, VISAs, etc.).
Financial Information: Bank account information, transaction history, trading data, and/or tax identification.
Transaction Information: Information about the transactions you make on our Services, such as your name, payment method, the fiat and crypto value, and/or timestamp.
Employment Information: Company name, office location, company contact information, job title, and/or description of role.
Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
Usage Data: Information provided to our support team, authentication data, security questions, user ID, and other similar data.
Corporate Information: If you sign up as a corporate entity, we collect information and documentation related to the name, industry, ownership (including beneficial ownership), registration, country of incorporation, business address and financial information of the company. Company information may also contain personal identification information and formal identification information related to the company account holder, shareholders, beneficial owners and/or members of the board of directors of the company.
3. HOW YOUR PERSONAL INFORMATION IS USED
3.1 Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content, and for loss prevention and anti-fraud purposes.
3.2 Some of our Services are subject to laws and regulations requiring us to collect and use the information listed herein in certain ways. For example, Cethereum must identify and verify customers using our Services in order to comply with Know Your Client, Anti-Money Laundering and Counter-
Terrorism Financing laws.
3.3 Should your use of our Services change, we may require you to provide additional information which we may use to verify your identity or address, and/or to manage risk as required under applicable law.
The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements.
3.4 We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or Services
may not be available to you.
4. INFORMATION AND THIRD PARTIES
4.1 We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We will only share your information in the following circumstances:
We may share your information with service providers under contract who help with parts of our business operations such as bill collection, legal services and technology services.
We share your information with payment processors with which we partner to process payments you have authorised.
We may share your information with companies or other entities that purchase CT assets pursuant to a court-approved sale under Canadian bankruptcy or insolvency law.
We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.
5. HOW WE PROTECT AND STORE PERSONAL INFORMATION
5.1 We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in Canada and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining safeguards in compliance with the applicable laws and regulations. For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our computers, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by our payment processor partners in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to CT or Cethereum staff.
5.2 We cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to
not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.
5.3 We cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including e-mail, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe
6. HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
6.1 You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account. If you close your Cethereum Account, we will mark your account in our database as "Closed" but will keep your account information in our database for 30 days. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will
RETENTION OF PERSONAL INFORMATION
We store your personal information securely throughout the life of your CT Account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve
disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.
Contact Information such as your name, e-mail address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
CHILDREN'S PERSONAL INFORMATION
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, CT will require the user to close his or her account and will not allow the user to continue buying or selling digital currencies. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
HOW TO CONTACT US
You can also complain about our processing of your personal information to the relevant data protection authority. In Canada that is the Office of the Information & Privacy Commissioner of Canada, which can be reached at: 1-800-282-1376.