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Bitsz team
February 25, 2025
~12 min read

1. INTRODUCTION

1.1. This POLICY (“Policy”) applies to all personal data of Users that the Bitsz Platform (“Platform”) may receive from Users during their use of the Platform.

1.2. Using the Platform—including registering an account—signifies your unconditional consent to this Policy and to the data collection and processing terms specified herein. If you disagree with these conditions, please refrain from using the Platform. By using the Services, you accept the terms of this Policy and our Terms of Use, and you consent to the collection, use, disclosure, and storage of your information as described herein. If you have not already done so, please review the Terms of Use, which include provisions that limit our liability and require disputes to be resolved on an individual basis rather than as a class or representative action. IF YOU DO NOT AGREE WITH ANY PORTION OF THIS PRIVACY POLICY OR OUR TERMS OF USE, PLEASE DO NOT USE THE SERVICES.


2. TERMS AND DEFINITIONS

2.1. Personal data – Any information that relates directly or indirectly to a specific or identifiable individual (Personal Data User), including standard data automatically received by the HTTP server when accessing the Platform and subsequent user actions (such as the host IP address, the type of operating system, and pages visited).

2.2. Terms of Use – The agreement between the User and the Operator containing all the necessary and essential conditions for using the Platform, granting access to the Platform, and utilizing its functionalities. This Policy is an integral part of the Terms of Use.

2.3. User (Personal Data User, User) – An individual who visits, downloads, registers an account on, or otherwise uses the Platform, regardless of whether they actively use its functionalities.

2.4. Operator – Angel Venture Partners Limited, registration number 238203, registered at Suite 3, First Floor, La Ciotat Building, Mont Fleuri, Mahe, Seychelles, which manages and owns the Platform.

2.5. Platform – The Bitsz Platform, including the website www.bitsz.io, and any associated ecosystems through which Bitsz provides cryptocurrency-related functionalities to Users.

2.6. Account – A User’s account on the Platform containing the User’s personal data and a set of access rights to the Platform’s functionalities.

2.7. Cookies – Pieces of data included in an HTTP request, intended for storage on the User’s device. They are used by the Operator to authenticate the User, store personal preferences and settings, track session state, and maintain usage statistics.

2.8. Destruction of personal data – Actions that render it impossible to associate personal data with a specific User without incurring excessive financial or organizational costs.

2.9. Processing of personal data – Any action or series of actions performed on personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.


3. GENERAL PROVISIONS

3.1. This Policy governs the processing of personal data when the Operator interacts with you in connection with your use of the Platform.

3.2. This Policy has been developed in accordance with:

  • 3.2.1. Applicable Law;
  • 3.2.2. Agreements concluded by the Operator;
  • 3.2.3. Other regulatory documents incorporating modern requirements for personal data protection.

3.3. This Policy is published on the Platform.


4. CATEGORIES OF PERSONAL DATA PROCESSED

4.1. The Operator may process the following personal data of Users:

  • 4.1.1. The User’s name (including last name, first name, and patronymic, if provided);
  • 4.1.2. Gender;
  • 4.1.3. Citizenship;
  • 4.1.4. E-mail address;
  • 4.1.5. Phone number;
  • 4.1.6. Identity document details;
  • 4.1.7. Date and place of birth;
  • 4.1.8. Registration address (as per passport/temporary registration) and actual residence address;
  • 4.1.9. Login credentials for using the Platform;
  • 4.1.10. Password for accessing the Platform;
  • 4.1.11. Financial information (including certificates of origin of funds, documents related to the use of funds, etc.) as required by global and local regulatory standards, including anti-money laundering (AML) procedures and know your customer (KYC) requirements;
  • 4.1.12. The IP address of the device used to access the Platform, along with details about the operating system, access time, and location;
  • 4.1.13. The type and version of the browser used;
  • 4.1.14. Transaction history on the Platform;
  • 4.1.15. Data from cookies;
  • 4.1.16. Information about content posted on the Platform and data regarding activity on the Platform.

5. PURPOSE OF PROCESSING PERSONAL DATA

5.1. Personal data collected from Users may be processed for the following purposes:

  • 5.1.1. Providing the functionalities of the Platform and verifying the User’s identity;
  • 5.1.2. Collecting and analyzing statistical data regarding the operation of the Platform;
  • 5.1.3. Protecting User accounts and archiving data;
  • 5.1.4. Enhancing the performance and functionality of the Platform;
  • 5.1.5. Complying with current legislative requirements;
  • 5.1.6. Informing Users about products, features, and updates on the Platform (including sales, marketing, or events), as well as sending important communications regarding the Platform’s operation;
  • 5.1.7. Communicating with Users about Platform operations through the Operator’s official channels, processing inquiries, and responding to requests;
  • 5.1.8. Maintaining a high level of User satisfaction by monitoring system performance;
  • 5.1.9. Planning commercial/business strategies;
  • 5.1.10. Ensuring website security;
  • 5.1.11. Modeling, reporting, evaluating, risk monitoring, researching current or new products, and identifying potential customers;
  • 5.1.12. Preparing reporting documents for financial transactions;
  • 5.1.13. Complying with retention, reporting, and disclosure obligations imposed by government authorities and ensuring adherence to their requests or decisions;
  • 5.1.14. Sending notifications to government authorities to investigate, detect, and prevent offenses;
  • 5.1.15. Resolving current and potential legal disputes and claims;
  • 5.1.16. Securing User accounts and maintaining system security;
  • 5.1.17. Fulfilling obligations under laws combating money laundering, corruption, fraud, terrorism, and other offenses;
  • 5.1.18. Reporting and providing information about contracts with third parties (e.g., service providers, agents, credit institutions);
  • 5.1.19. Developing marketing strategies, studying consumer demand, posting advertising materials on the Platform, and selling marketing materials.

5.2. Processing is limited to achieving specific, predefined, and legitimate purposes. Processing data for incompatible purposes is prohibited.

5.3. The transfer of personal data to third parties is limited to what is necessary to fulfill the purposes for which the data was collected.

5.4. The Operator may delegate processing of personal data to third parties only with the User’s consent, as required by applicable law and/or pursuant to an agreement with the User.

5.5. When outsourcing, the Operator specifies the scope of actions, processing purposes, and obligations regarding confidentiality and security, including necessary protective measures.

5.6. The Operator restricts access to personal data only to authorized individuals who require it to perform their official functions.


6. PROCESSING METHODS

6.1. The Operator processes your personal data based on and in connection with:

  • 6.1.1. Agreements, statements, and other documents related to the Terms of Use;
  • 6.1.2. Notices from Users;
  • 6.1.3. Communications with call center and technical support;
  • 6.1.4. Data from third-party service providers, subsidiaries, branches, and partner companies.

6.2. The Operator ensures that personal data is recorded, systematized, accumulated, stored, updated, and retrievable.

6.3. In processing personal data, the Operator undertakes actions such as collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction to comply with the Terms of Use and provide access to the Platform.

6.4. Personal data is stored on electronic media.

6.5. Data must be stored securely to prevent loss or misuse, and only in a manner that permits identification of the User as required for the processing purposes, unless otherwise mandated by current legislation or the Terms of Use.

6.6. Confidentiality measures apply to both paper and electronic media.

6.7. The Operator may process personal data by:

  • 6.7.1. Manual processing;
  • 6.7.2. Automated processing;
  • 6.7.3. Transmitting data via the Operator’s internal network (accessible only to designated employees);
  • 6.7.4. Transmitting data via public information and telecommunication networks;
  • 6.7.5. Not transmitting the data;
  • 6.7.6. Mixed processing methods.

6.8. The Operator does not make decisions solely based on automated processing that result in legal consequences for the User or affect their rights and legitimate interests.

6.9. Any decision that results in legal consequences for the User or affects their rights and legitimate interests, based exclusively on automated processing, may only be made with the User’s written consent or as provided by regulatory acts, with adequate measures to protect the User’s rights.


7. USER RIGHTS

7.1. Users have the right to:

  • 7.1.1. Access information regarding the personal data processed by the Operator through their Account, including the purposes and methods of processing;
  • 7.1.2. Update or modify their personal data, or delete data posted in their account on the Platform;
  • 7.1.3. Request corrections or clarifications of their personal data from the Operator;
  • 7.1.4. Require that all parties previously provided with incorrect or incomplete data be notified of corrections;
  • 7.1.5. Obtain information about third parties to whom personal data has been transferred;
  • 7.1.6. Receive details about the processing of their personal data within the scope permitted by the Operator;
  • 7.1.7. Request personal data in a structured, commonly used, and machine-readable format and transfer it to another operator;
  • 7.1.8. Request deletion or destruction of all or part of their personal data, impose processing restrictions, or withdraw consent for processing;
  • 7.1.9. Seek compensation for damages resulting from unlawful processing of personal data.

7.1.10. Note that deletion of personal data or withdrawal of consent may result in the inability to use certain or all functionalities of the Platform.


8. CHILDREN’S PERSONAL INFORMATION

The Operator and the Platform are not intended for individuals under 18 years of age. We do not knowingly solicit or collect information from minors. If you are under 18, please do not provide any personal information via the Bitsz Platform. If it is discovered that a User under 18 has provided personal information, the Operator will require the account to be closed and will take steps to promptly delete the information.


9. INFORMATION ABOUT PERSONAL DATA PROTECTION REQUIREMENTS

9.1. When processing personal data, the Operator implements necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, or any other unlawful actions. These measures include, but are not limited to:

  • 9.1.1. Appointing a responsible person for personal data processing;
  • 9.1.2. Limiting access to personal data by employees;
  • 9.1.3. Using software to authenticate Users and record their actions;
  • 9.1.4. Implementing antivirus controls and other measures to guard against malicious software;
  • 9.1.5. Employing backup and recovery tools;
  • 9.1.6. Regularly updating software to ensure the security of processed data;
  • 9.1.7. Encrypting personal data during transmission over the Internet;
  • 9.1.8. Restricting access to technical equipment installation sites;
  • 9.1.9. Utilizing secure storage locations for physical media containing personal data.

10. PRIVACY

The Operator commits to keeping all disclosed information strictly confidential and takes all necessary measures to prevent any unauthorized or unlawful disclosure or use.


11. COOKIES POLICY

11.1. The Operator uses cookies and similar technologies when you visit the Bitsz Platform or receive marketing emails. This section explains what these technologies are, why we use them, and your rights regarding their use.

11.2. Cookies are small files, usually comprising letters and numbers, that are downloaded to your computer or mobile device when you visit certain websites. When you return to these sites or visit others using the same cookies, your device is recognized. Cookies cannot access data on your hard drive or read cookies set by other websites.

11.3. We use first- and third-party cookies to recognize you as a Bitsz User, customize Bitsz services, content, and advertising, measure advertising effectiveness, and collect information about your device to reduce risk, prevent fraud, and enhance trust and security.

11.4. We may also place cookies from third-party service providers who might use information about your visits to other websites to target advertisements for products and services offered by the Operator.

11.5. The Operator does not control the types of information collected and stored by these third-party cookies. Please review the third party’s website for more details on their cookie practices.

11.6. Types of cookies used:

  • 11.6.1. Necessary cookies: Essential for the Platform’s functionality and cannot be disabled. They are typically set in response to User actions that constitute a request for services (e.g., setting privacy preferences, logging in, or completing forms) and may include cookies used to prevent fraud. Blocking these cookies may affect site functionality.
  • 11.6.2. Analytical cookies: Allow the Operator to count visits and traffic sources, helping to measure and improve the Platform’s performance. These cookies collect aggregated, anonymous data about page popularity and navigation. Disabling these cookies prevents the Operator from monitoring site performance.
  • 11.6.3. Functional cookies: Enable the Operator to remember your choices and customize the Platform to provide relevant content (for example, remembering your preferences).

12. DESTRUCTION OF PERSONAL DATA

12.1. Destruction of personal data is carried out in the following cases:

  • 12.1.1. Upon achieving the processing purposes or when those purposes no longer exist, within a period not exceeding thirty days from the moment the processing purpose is fulfilled—unless otherwise provided by an agreement between the User and the Operator;
  • 12.1.2. In the case of unlawful processing or lawful revocation of consent, within a period not exceeding ten working days from the discovery of such an incident;
  • 12.1.3. Upon expiration of the data storage period, as determined by applicable law and the Operator’s internal policies, including withdrawal of consent for processing;
  • 12.1.4. In response to an order from an authorized personal data protection body or a court decision;
  • 12.1.5. The Operator reserves the right, at its discretion, to destroy copies of personal data, including in cases of unauthorized access by third parties.

13. TRANSFER TO THIRD PARTIES

13.1. The Operator may transfer personal data to the following parties, consistent with the purposes of processing:

  • 13.1.1. Its employees and Platform developers;
  • 13.1.2. Partners, consultants, lawyers, auditors, courts and/or law enforcement agencies, as well as government agencies and organizations for legal and financial reviews;
  • 13.1.3. Persons, institutions, or organizations with legitimate grounds to access personal data under applicable law;
  • 13.1.4. Providers of hosting, web analytics, technical support, and marketing services;
  • 13.1.5. Subsidiary, affiliated, or interdependent entities of the Operator;
  • 13.1.6. Credit organizations;
  • 13.1.7. Other third parties specified in the User’s Consent to the processing of personal data.

14. CROSS-BORDER TRANSFER OF PERSONAL DATA

14.1. By using the Platform, you consent to the cross-border transfer of your personal data to other countries for processing at the location of the data controller, for the purposes specified in Section 5 of this Policy.

14.2. The Operator may transfer personal data to other states—regardless of whether they provide reliable protection of Personal Data Users’ rights—as long as such transfers are consistent with the purposes specified in Section 5.

14.3. Prior to any cross-border transfer, the Operator will verify that the destination country offers adequate protection for the rights of Personal Data Users.

14.4. Transfers to countries that do not meet these requirements can only occur with your written consent and/or pursuant to an agreement to which you are a party.

14.5. The Operator will make reasonable efforts to ensure that third parties with access to personal data through cross-border transfers implement the necessary technical and administrative measures to protect the data.


15. USER REQUESTS

15.1. Users may submit requests regarding the use of their personal data by contacting the Operator at: [email protected].

15.2. The Operator will review and respond to your request within thirty (30) days from receipt.

15.3. All correspondence received from Users (written or electronic) is treated as confidential and will not be disclosed without your written consent. Personal data provided in such requests will only be used to respond to your inquiry, except as otherwise provided by law.


16. THIRD PARTY RESOURCES

16.1. The Operator may include links to third-party websites on the Platform that may redirect you to external sites. The Operator is not responsible for the collection, processing, or deletion of personal data by these third parties, nor for the content of these sites. Please review the privacy policies of these third parties for more details on their practices.


17. FINAL PROVISIONS

17.1. The period for processing personal data is equal to the duration of the Operator’s obligations or until you withdraw your consent or the Operator ceases operations.

17.2. You may withdraw your consent by sending a written request to the Operator, in a form that reliably identifies you (or your representative) and establishes the authority of the representative.

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