Bitsy Services Privacy Policy

Effective Date: September 13, 2018

Bitsy, Inc. (“Bitsy” or “we”) adopted this Privacy Policy to reflect our commitment to protecting your privacy. We want you to have the information you need to make informed decisions by describing what we do with the information you entrust to us.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE YOU PROVIDE BITSY WITH YOUR INFORMATION. YOU ALSO MUST READ AND AGREE TO THE BITSY SERVICE USER AGREEMENT (“USER AGREEMENT”).

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to information collected through the following services that Bitsy offers (collectively, the “Bitsy Services”):

  • Three-private-key solution that provides security for certain cryptocurrencies and other digital financial assets purchased and supported through the Bitsy Service (collectively, “Digital Financial Assets”). For a list of the Digital Financial Assets that Bitsy supports, please see the User Agreement;
  • Hosted wallet for Digital Financial Assets (“Bitsy Wallet”) that you load to your computer, tablet, or mobile device (“Device”) and that allows you to store, track, transfer, and manage your Digital Financial Assets;
  • Purchase and sale services through which Digital Financial Assets sold to and bought from Bitsy;
  • Bitsy “Lost Key Process” for a computer, tablet or mobile device that is lost, stolen or damaged; and
  • Transaction records.

If a particular Bitsy Service refers or links to a different privacy policy, then that privacy policy—not this Privacy Policy—applies.

In this Privacy Policy, we use the term “User” to include any individual who accesses and uses any of the Bitsy Services.

INFORMATION WE COLLECT

To operate the Bitsy Services, we collect information from Users. The types of information that Bitsy collects depends on the purpose for which each User chooses to use the Bitsy Services.

  • When a User completes the Bitsy Enrollment, Bitsy collects name, email address, postal address, date of birth, a copy of government-issued ID, a ‘selfie’ photo and other information we may request used to verify the User’s identity. For more information about our identity verification, please see the Verification Procedures that are part of the Bitsy Service User Agreement.
  • When a User initiates purchases or sales, Bitsy collects bank card or bank information to facilitate those transactions and takes great pains to secure such information. Once purchases or sales have been finalized, Bitsy deletes the original bank-related information.
  • When a User wishes to increase the transaction limits associated with the Bitsy Enrollment, Bitsy may collect additional information through the Enhanced Verification Process described in our User Agreement.
  • When a User submits a request for support, Bitsy may collect the following types of information: name, telephone number, email address and other information that the User chooses to give us to respond to the support request.

We receive information about you from third parties that help us operate and improve the Bitsy Services, including:

  • Bitsy’s financial services partner, Beckstrand & Associates Employee Credit Union (“Credit Union”) which transfers Digital Financial Assets into and out of a Bitsy Wallet
  • Service providers for data hosting and maintenance, analytics, marketing and security operations. All of our service providers must adhere to data protection obligations that are consistent with this Privacy Policy and the agreements we enter into with them. When you use the Bitsy Services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access the Bitsy Services. Depending on the settings of a User’s computer or mobile device (“Device”), Bitsy also automatically collects: Internet Protocol (IP) address; Media Access Control (MAC) address; Device make, model, ID, and operating system version; mobile network information; internet service provider; browser type and language; country and time zone in which the Device is located; the Bitsy Application version running on the device; and metadata stored on the Device. This information is collected through cookies and other tracking tools. Bitsy may supplement the information you provide to us with information from other sources. When this information directly or indirectly identifies an individual User, we refer to the information as “personal data.”

HOW WE USE INFORMATION

We use information to operate the Bitsy Services, including:

To administer your Bitsy Wallet and provide the Bitsy Services to you

  • Create and manage your Bitsy Wallet
  • Provide you with customer support and respond to your requests
  • Communicate with you about the Bitsy Services

To improve the Bitsy Services and develop new ones

  • Conduct research and analysis of Users’ behavior to improve the Bitsy Services
  • Develop new features and services to supplement the Bitsy Services, such as new Digital Financial Assets

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged fraud or misuse of the Bitsy Services
  • Analyze data to better understand and design countermeasures against fraud
  • Identify and stop intellectual property infringement

To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement
  • Exercise our legal rights, such as enforcing our User Agreement

HOW WE SHARE INFORMATION

With our service providers

  • We use third-party service providers to help us operate and improve the Bitsy Services. These third parties assist us with data hosting and maintenance, analytics, marketing, security operations and fighting spam. All of our service providers must adhere to data protection obligations that are consistent with this Privacy Policy.

With the Credit Union

  • The Credit Union transfers Digital Financial Assets into and out of a Bitsy Wallet

For corporate transactions

  • We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

  • Applicable law may require us and our service providers to disclose your information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).

To enforce legal rights

  • We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

  • We may ask for your consent to share your personal data with third parties. When we do, we will make clear why we want to share the personal data.
  • We may collect and provide aggregate information about our Users (such as how many persons used the Bitsy Services on a particular date) to our partners and affiliates but this aggregated information generally does not include personal data about any individual User.

COOKIES AND TRACKING TOOLS

The Bitsy Services may use cookies and other tracking tools.

  • A cookie is a small data file that contains a unique identification number that a website places on your hard drive when you visit a site. The cookie stores information about your computer, the type of browser you use, and how many times your computer visits a certain site. Cookies enable us to track how often Users are visiting the Bitsy Services and the specific pages visited, the number of entries in specific events, the estimated audience size for sponsors and advertisers, and other User preferences. You can refuse to use cookies by turning them off in your browser. You do not need to have cookies turned on to use most of the Bitsy Services. However, you may find that some areas on the Bitsy Services will be slower, or may not function at all, and you may not be able to participate in certain activities such as contests or sweepstakes if the cookies are disabled. To learn more about cookies generally, visit http://www.allaboutcookies.org.
  • The Bitsy Services also may use clear GIFs [Graphics Interchange Formats] (also known as pixel tags, web beacons, or web bugs). A clear GIF is computer code that contains a unique identifier that enables us to monitor user activity and traffic of the Bitsy Services. We use GIFs to gather aggregate information on visits to the Bitsy Services and assist with enrollment and other features.

Data collection technology helps us improve your experience of the Bitsy Services by, for example, compiling statistics about use of the Bitsy Services to help us analyze technical and navigational information about the Bitsy Services and to detect and prevent fraud. We also may use other data collection technology to collect information from the Device that you use to access the Bitsy Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your Device is located.

Your Control of Cookies: Some mobile web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your Device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your Device. Although you are not required to accept cookies or Device identifiers, if you block or reject them, you may not have access to all features available through the Bitsy Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Data about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Bitsy, do not respond to DNT signals.

HOW WE PROTECT AND RETAIN INFORMATION

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal data to those employees who need to know that information to service your Bitsy Wallet or perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate security measures to protect your personal data.

You are responsible for maintaining the security of your Bitsy Wallet. We may suspend your use of all or part of the Bitsy Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address provided through Bitsy Enrollment.

If you believe that your Bitsy Wallet or information is no longer secure, please notify us immediately at [email protected].

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

YOUR CHOICES ABOUT YOUR PERSONAL DATA

If you would like to review, correct, update, restrict or delete personal data that you have previously provided to us, or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (if and when these rights are provided to you by law), please contact us at [email protected].

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data deleted or suppressed or other limitations you would like to put on our use of your personal data. For your protection, we will verify your identity before fulfilling your request. We will respond to your request as soon as reasonably practicable and in any event within 30 days.

Please note that we often need to retain certain personal data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which are not removed. In addition, we also may not allow you to review certain data for legal, security or other reasons.

If at any time you believe that the Bitsy Services have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

CHILDREN'S PRIVACY

We do not knowingly collect personal data from anyone under age thirteen (13). If we learn that a child under age thirteen (13) has improperly provided us with information, we will delete the child's personal data from our records.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you can request a notice disclosing the categories of personal data about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. At this time we do not share personal data with third parties for their direct marketing purposes.

LINKS TO OTHER WEBSITES AND SERVICES

The Bitsy Services may include links to third-party websites and services that are not operated by us. When you click these links, you are directed away from the Bitsy Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal data that you provide to these other websites and services.

HOW TO CONTACT US

If you have any question regarding the Bitsy Services or our privacy practices, please send your query to [email protected].

Modified: 12/11/2018