Last updated: June 12, 2018
1.1 As used herein, the following terms are defined as follows:
1.1.1 “The Company”, “BitMart”, “We” and “Us” refer to GBM Global Holding Company Limited, a company incorporated under the laws of Cayman Islands, and operates the website https://www.bitmart.com (hereinafter referred to as “this Website” or “the Website”), which is a platform dedicated to the transaction of digital assets and the provision of related services.
1.1.2 “Digital Asset” refers to a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
1.1.3 “User” refers to all natural persons who log onto this Website. For the convenience of wordings in this Policy, users are also referred to as “you” or any other applicable forms of the second-person pronouns.
1.1.4 “User Account” refers to a user-accessible account offered via the Company’s services, including without limitation, the hosted wallet services where Digital Assets are stored.
1.1.5 “Personal Information” or “Personal Data” or “your data” refers to any information relating to you as an identified or identifiable natural person, including but not limited to your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
3. COLLECTION OF PERSONAL INFORMATION
3.1 BitMart may collect and use the following Personal Information from you to provide services:
- Full legal name;
- Home address, including country of residence;
- Email address;
- Mobile phone number;
- Date of birth;
- Proof of identity (e.g., driver’s license, passport, or government-issued identity card);
- S. Social Security Number or any comparable identification number issued by a government;
- Other Personal Information that is deemed helpful in verifying whether you are eligible to register on BitMart website;
- Other Personal Information that is deemed helpful in ensuring our compliance with legal obligations under applicable anti-money laundering (AML) obligations, including but not limited to the U.S. Bank Secrecy Act (BSA) and/or the European Union’s 4th AML Directive;
- Other Personal Information that is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.
3.2 BitMart may also collect, receive, and use the following Personal Information from you to monitor and improve the function of BitMart website, enhancing your experience in using BitMart services:
- Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
- Log Information – Information that is generated by your use of BitMart services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
- User Account Information – Information that is generated by your BitMart account activities including, but not limited to, instructions regarding funding and disbursement, orders, trades, account balances, and other transactional information;
- Correspondence – Information that you provide to us in written or oral correspondence, including opening a BitMart User Account, engaging customer support, and initiating other kinds of communications to contact us;
- Other information that we may receive from other third parties, including but not limited to banks or financial institutions that you use for transaction purposes.
3.3 Personal Information you provide while using BitMart services may be retained, even if your registration is left incomplete or abandoned.
4. USE OF PERSONAL INFORMATION
4.1 BitMart uses the Personal Information we collect for the following carefully considered business purposes, which also benefit our Users:
- To provide you with our services through our website;
- To identify and confirm your identity when you use our website;
- To improve and upgrade the services of our website, including but not limited to improvements made per service requests and user feedbacks;
- To maintain and analyze statistics relating to the use of our website and/or any cooperation with governmental agencies, academic institutions, and public affairs agencies;
- To personalize your experience while using BitMart services;
- To facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is solely and expressly for the purpose of completing the transaction per your instruction);
- To regularly send e-mail and other kinds of communications or notifications (the email address that you provide while using BitMart services may be used to receive updates to your transactions and updates, newsletters, new product or service information, and other kinds of communication, unless BitMart receives specific instructions from you regarding your email preference);
- To meet other purposes as specified in the User Agreement listed on BitMart website and any and all legal means adopted for satisfying such purposes.
4.2 BitMart does not sell, trade, transfer Personal Information to external parties, or allow external parties to do so on BitMart website. However, to the extent necessary for 1) proper functioning of BitMart website and improvement of BitMart services 2) compliance with any of the applicable laws, regulations, rules or any order of courts or other competent authorities or 3) due protection of the rights, property, or safety of us or other persons, the following parties shall be excluded from such promise: our affiliates and trusted third party vendors we engage to help us operating our website, managing our business, or providing services directly and indirectly to the Users, provided that such parties understand and agree to keep such Personal Information confidential. Nevertheless, your Personal Information will not be provided to external parties for marketing, advertising or other purposes, unless an authorization is directly obtained from you.
5. PROTECTION OF PERSONAL INFORMATION
5.1 We adopt appropriate physical, electronic, technical and managerial measures to protect and safeguard your Personal Information. We will, to the greatest extent possible, ensure that any Personal Information collected through our Website shall be free from being subject to the nuisance by any external parties. The security measures that we may take include but are not limited to:
- Physical measures: Records of your Personal Information will be stored in a properly locked place against loss, theft, unauthorized use, disclosure, or modification.
- Electronic measures: Electronic data that contain your Personal Information will be stored in properly encrypted computer systems and storage media that are subject to strict login/access restrictions.
- Technical measures: Proper encryption techniques, including but not limited to Secure Socket Layer Encryption technology, may be used to protect your Personal Information.
- Managerial measures: Only staff members duly authorized by us can access your Personal Information, and these staff members are duly trained and monitored to comply with our internal code of ethics concerning personal data protection.
- Other measures that we deem necessary in ensuring the safety of your Personal Information.
5.2 To help us protect your Personal Information, you should maintain the secrecy of your logon ID and password you may have set up while using BitMart services. We shall not be held liable for damage or loss of any kind caused directly or indirectly by your own failure in maintaining the secrecy of your logon information.
6. DATA RETENTION
6.1 As BitMart and its affiliates may be subject to various legal, compliance and reporting requirements, including but not limited to national AML requirements, we record and store some of your personal and transactional data beyond the closure of your User Account. Your Personal Information will only be accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will constantly monitor and delete data that is no longer required by any relevant law or jurisdiction in which we operate.
8. RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
10. CONTACT US
10.1 If you have any requests, comments, or questions, please contact us via email to firstname.lastname@example.org, which is the sole official email through which we communicate with our Users. BitMart will not be responsible for your failure in using effective contact channels, or any act or omission related.
10.2 We will only publish announcements and information on the basis of the valid and effective contact information on our Website or post announcements on our Website; therefore, we shall not be held liable for any loss arising from your trust in the information that has not been obtained through the above-mentioned means or methods.