We at DEFI BULL HQ LTD. (DEFI BULL) (defined below) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the website.
Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request via our Support widget or via email.
We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.
By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.
If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.
| Where You Reside | Services Provided |
|---|---|
| United States | Digital Currency services |
| EU and the United Kingdom | Digital Currency services |
| Germany | Digital Currency services |
| European Economic Area | Digital Currency services |
| Singapore | Digital Currency services |
| Japan | Digital Currency services |
| Anywhere else | Digital Currency services |
| United Kingdom (and select non-EEA countries in Europe) | Digital Currency services |
| United States (Others) | Digital Currency services |
The DEFI BULL operating entity determines the means and purposes of processing your personal information in relation to the Services provided to you (typically referred to as a "data controller").
You may be asked to provide personal information anytime you are in contact with the DEFI BULL company. They may also combine it with other information to provide and improve our products, services, and content. For example, even if you do not reside in the United States (the "US"), your information may be shared with DEFI BULL which provides global support for all Services including technical infrastructure, product development, security, compliance, fraud prevention, and customer support.
If you have any questions about your DEFI BULL Account, your personal information, or this Privacy Policy, please submit your request via our Support widget.
Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.
Information you provide to us. To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services, or is relevant for certain specified purposes. As we add new features and Services, you may be asked to provide additional information.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.
We may collect the following types of information from you:
Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
For example, we may automatically receive and record the following information on our server logs:
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.
Information we collect from our affiliates and third parties. From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law.
Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).
DEFI BULL may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.
Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
1) To maintain legal and regulatory compliance
Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, DEFI BULL must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. This includes collection and storage of your identificators. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. If you do not provide personal information required by law, we will have to close your account.
2) To enforce our terms in our user agreement and other agreements
DEFI BULL handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.
3) To detect and prevent fraud and/or funds loss
We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.
4) To provide DEFI BULL's Services
We process your personal information to provide the Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.
5) To provide Service communications
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails sent for legal or security purposes.
6) To provide customer service
We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
7) To ensure quality control
We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
8) To ensure network and information security
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
9) For research and development purposes
We process your personal information to better understand the way you use and interact with DEFI BULL's Services. In addition, we use such information to customize, measure, and improve DEFI BULL's Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.
10) To enhance your experience
We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
11) To facilitate corporate acquisitions, mergers, or transactions
We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
12) To engage in marketing activities
Based on your communication preferences, we may send you marketing communications (e.g. emails) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
13) To protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our locations, to maintain security at such locations you may be photographed or videotaped.
14) For any purpose that you provide your consent.
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, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, 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 authorization. If you choose to limit the use of your personal information, certain features or DEFI BULL Services may not be available to you.
For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively "EEA Residents") at the time their personal information is collected, our legal bases for processing your information under the EU General Data Protection Regulation ("GDPR") will depend on the personal information at issue, the specific context in the which the personal information is collected and the purposes for which it is used. We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so. In some rare instances, we may need to process your personal information to protect your vital interests or those of another person. Below is a list of how ACFX uses your personal information, as described above in Section 5, with the corresponding legal bases for processing. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "Contact us" page.
| Section & Purpose of Processing | Legal Bases for Processing |
|---|---|
| (2) To enforce our terms in our user agreement and other agreements (4) To provide DEFI BULL's Services (5) To provide Service communications (6) To provide customer service (7) To ensure quality control | Based on our contract with you or to take steps at your request prior to entering into a contract. |
| (9) For research and development purposes (10) To enhance your experience (11) To facilitate corporate acquisitions, mergers, or transactions (12) To engage in direct marketing activities | Based on our legitimate interests. When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws. |
| (1) To maintain legal and regulatory compliance (3) To detect and prevent fraud and/or funds loss (8) To ensure network and information security (13) To protect your or our's vital interests | Based on our legal obligations, the public interest, or in your vital interests. |
| (10) To enhance your experience (12) To engage in third party marketing activities (14) For any purpose to which you consent | Based on your consent. |
We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. DEFI BULL will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:
Where we believe it is necessary in order to protect the vital interests of any person. If you establish a DEFI BULL Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a DEFI BULL website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies. For more information see the "Third-Party Sites and Services" section below.
We understand how important your privacy is, which is why DEFI BULL maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize 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 unauthorized access to or use of your account.
Furthermore, 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 email, 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 that your data is no longer secure, please contact us using the contact information provided in the "Contact us" section.
We store your personal information securely throughout the life of your DEFI BULL 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.
If you authorize one or more third-party applications to access your DEFI BULL Services, then information you have provided to DEFI BULL may be shared with those third parties. A connection you authorize or enable between your DEFI BULL account and a non-DEFI BULL account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, DEFI BULL will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using DEFI BULL Services. Please note that third parties you interact with may have their own privacy policies, and DEFI BULL is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and DEFI BULL is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.
Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party's privacy practices. Please review the privacy notice of any third party that will gain access to your personal information. DEFI BULL is not responsible for such third party conduct.
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, DEFI BULL will require the user to close his or her account and will not allow the user to continue using our Services. 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.
To facilitate our global operations, DEFI BULL may transfer, store, and process your personal information within our Affiliates, third-party partners, and service providers based throughout the world, including Ireland, Germany, Singapore, Japan, the UK, the US, the Philippines, and possibly other countries. We will protect your personal information in accordance with this Privacy Policy wherever it is processed and will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with DEFI BULL, you acknowledge and agree to your personal information being processed in this way.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via our Support Portal.
Data transferred out of the EU
We rely primarily on the European Commission's Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area ("EEA"), the United Kingdom and Switzerland (collectively "European Personal Information"), to the extent the recipients of the European Personal Information are located in a country that the EU considers to not provide an adequate level of data protection. This includes transfers from our EU-based DEFI BULL operating entities to our US-based operating entity. We may also rely on an adequacy decision of the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.
DEFI BULL. is responsible for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party, DEFI BULL. will enter into a written agreement that the third party provides at least the same level of protection for the personal information as required under applicable data protection laws.
DEFI BULL, also participates in and has certified its compliance with the EU-US Privacy Shield Framework. Under the Privacy Shield Framework, DEFI BULL, is subject to the authority of the Federal Trade Commission. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.
European data subjects with inquiries or complaints relating to our Privacy Shield certifications should first contact DEFI BULL via our Support Portal or by emailing us. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, the International Centre for Dispute Resolution ("ICDR"), operated by the American Arbitration Association ("AAA").
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.
Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, DEFI BULL has absolute discretion in providing you with those rights.
Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
How to make a privacy request
You can make privacy rights requests relating to your personal information by contacting us via our Support Portal. When we receive an individual rights request via Support Portal, we may take steps to verify your identity before complying with the request to protect your privacy and security.
How to lodge a complaint
If you believe that we have infringed your rights, we encourage you to first submit a request via our Support Portal so that we can try to resolve the issue or dispute informally.
In the UK, the relevant data protection authority is Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113, casework@ico.org.uk.
In Ireland, the relevant data protection authority is the Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co; email: info@dataprotection.ie
In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. To the extent we share you personal information in this way, you may receive the following information:
Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section. This section describes the categories of personal information DEFI BULL has collected, the categories of personal information DEFI BULL has disclosed, and a description of California residents' rights.
| Personal Information Category (corresponds to categories in CCPA §1798.140(o)(1)) | Sources of Personal Information and Why We Collect this Information (see Section 5 above for more information) | Disclosure of Personal Information (see "Why We Share Personal Information With Other Parties” heading above for more information) |
|---|---|---|
| (A) Identifiers such as Personal Identification Information | Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 2, 3, 4, 5, 6, 8, 9, 11, and 12 | - Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates |
| (B) Customer records such as signature | Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 2, 5, 6, and 11 | - Third party identity verification services - Financial institutions - Service providers |
| (C) Protected classifications under California and federal law, including gender, age and citizenship | Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsection 1 | - Third party identity verification services - Professional advisors |
| (D) Commercial information such as records of services purchased, obtained, or considered | Information you provide us; Information we collect from you automatically; Information collected from third parties; Why we collect this information: see Section 5, subsections 3, 4, 5, 6, 8, 9, 10, 11 and 12 | - Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates |
| (E) Biometric information | Information you provide us; Why we collect this information: see Section 5, subsection 1 | - Third party identity verification services - Financial institutions |
| (F) Usage Data | Information we collect from you automatically; Why we collect this information: see Section 5, subsections 2, 3, 4, 6, 7, 8, 9, 10, and 12 | - Third party identity verification services - Service providers - Professional advisors - our Affiliates |
| (G) Online Identifiers | Information we collect from you automatically; Why we collect this information: see Section 5, subsections 1, 3, 9 and 12 | - Third party identity verification services - Service Providers |
| (H) Sensory data, such audio, electronic, visual information | Information you provide to us; Why we collect this information: see Section 5, subsections 3, 4, 5 and 7 | Not applicable |
| (I) Professional or employment-related information | Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 12 | - Third party identity verification services - Service providers - our Affiliates |
| (J) Inferences about preferences, characteristics, predispositions, etc. | Information you provide us; Information we collect from you automatically; Why we collect this information: see Section 5, subsections 9, 10, 12 | - Service providers - Professional advisors - our Affiliates |
California Residents' Rights
Under the CCPA, you may have the following consumer rights. Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA:
Should DEFI BULL engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account settings. You can exercise your rights by contacting us via our Support Portal so that we may consider your request.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise your rights, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such a request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4121 to 4130. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.
Do Not Track
Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, we do not currently process or respond to "DNT" signals.
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us on our Support page, at https://defibull.app/ , or by writing to us at the address of your operating entity (provided above).