1. About this Policy
The BTX website (the “Site”), the Exchange, or any other applications or software is used by BTX to provide the Services.
2. Collection of information
When You download the Qoin application (the “Qoin App”) and elect to use the Exchange, BTX will collect information to verify your identity. BTX is required to comply with all binding laws including but not limited to the Australian and New Zealand Anti-Money Laundering and Countering of Financing of Terrorism laws. The information we collect from You may include:
a) formal identification, which includes full name, date of birth and residential address;
b) source of funds;
c) transaction details;
d) ownership structures;
e) tax identification details; and
f) other information considered relevant.
We will retain the information and documents and may be required to disclose them to government agencies as required by law. We may not be permitted to advise you of the instances when we are required to disclose the information.
BTX will automatically collect information about You when you visit the Site, the Exchange or use the Services. For example:
a) technical information, including the Internet Protocol (IP) address used to connect your device to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in and versions, operating system and platform;
b) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information which include scrolling, clicks and mouse-overs, methods used to browse away from the page any phone number used to call us.
We will not collect any sensitive information about You, for example, revealing your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability which we consider are unnecessary to our function. Exceptions to this include:
a) where You have given express consent to us to do so and the personal information is reasonably necessary for us to carry out our functions or activities;
b) the use of the information is required by law or legal process.
Please note if we are unable to collect personal information we reasonably require, we may not be able to do business with You or the organisation with which You are connected.
Information we receive from third parties: We work with third parties and we may receive information about You from them, for example, business partners, sub-contractors in technical payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify You when we receive information about You from them and the purposes for which we intend to use that information.
Our Site or our communication from time to time contain links to third party websites over which we have no control. If You follow a link to any of these websites, please note that they have their own practices and policies. We encourage You to read these privacy policies or statements of these websites and understand your rights. We accept no responsibility or liability for any practices of third-party websites.
Cookies are used to collect anonymous data, BTX may use “cookies”. Cookies are small pieces of information that are stored by your web browser on your computer’s hard drive. Cookies allow a website to store and reference specific types of information while you are visiting it, and to keep your session “live” when you are logged in. We may store your website activity in cookies which may be used by third party vendors, including Google, to serve ads based on your behaviour on our Site. BTX cookies contain no personal information or financial information. Most web browsers automatically accept cookies, although your browser preferences may be changed to prevent this if you so desire, however disabling cookies may affect the functionality of the site.
We only retain personal data for so long as is necessary. Data may be archived so long as the purpose for which the data was used still exists.
3. Use of information by BTX
a) We use this information to improve our marketing efforts. To do this we analyse Site usage and customise our and Site’s content and layout.
b) We use this information to deliver, improve and develop our technology.
c) To research, design and launch new features or products.
d) To present content and information in our Site in the most effective manner for you and for the device You use.
e) To provide You with alerts, updates, materials or information about our products and services or other types of information You either requested or signed up to.
f) Communicating with You and responding to your questions and requests.
g) We may also use this information to directly market to You new products and services (via e-mail and other on and off-line communications). This also includes sending You the information about products and services by post, telephone or any form of electronic communication.
If You do not wish to receive these communications from us, please notify us by e-mail at [email protected] or call 1300 132 012 to opt out.
4. Who will see or have access to your information
For the purposes of providing you with access to our Site, the Exchange and Services we may also share information with third parties such as employees, any of our subsidiaries, contractors, auditors, advisers, agents, financial institutions, service providers and suppliers.
In the event of a security incident involving unauthorised access, use or disclosure of personal information where a third party with whom we share personal information is involved, we will seek to work cooperatively with them to protect the personal information we have shared with them.
We may disclose to third parties’ aggregate anonymous statistics regarding our users, traffic analyses and other information regarding or collected through our Site. Other than in this anonymous form, we will not disclose your personal information without first obtaining your permission except as follows:
We collect and store personally identifiable information using encryption technology that encrypts the information You input before it is sent to us via the Internet. In addition, all the information we collect on the Site is stored on our secure data centres on servers within Australia, Germany and the United States of America. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. We restrict access to personal information to our employees, service providers and contractors on a strictly need to know basis and to ensure that those persons are subject to contractual confidentiality obligations.
Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site, the Exchange and through the Services. Any transmission is at your own risk.
b) Keeping your personal information secure
BTX’s security measures are designed to assist in ensuring that your personal information is not accessed by unauthorised personnel, lost or misused. If You reasonably believe that there has been an unauthorised use or disclosure of your personal information, please let us know by contacting our Privacy and Data Protection Officer (contact details below).
5. Correcting, changing and updating your information
You may gain access to personal information that BTX has collected about You by using the contact details provided. You may request to have any of your personal information corrected or updated by sending an e-mail to priva[email protected] or calling us at 1300 132 012.
6. Keeping your personal information accurate
The personal information we hold about You (such as name and email address) is kept so that we may correctly identify You. We take all reasonable steps to ensure that personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If You believe that any of your personal information is not accurate, up-to-date, complete, relevant and not misleading, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable time.
7. How long we hold your personal information
We will retain your information for as long as you are an active User or as necessary to comply with our legal obligations, resolve issues, address queries and enforce our agreements. If You no longer wish to use our App or Site, You may request that your Q Wallet be deactivated by contacting the Privacy Officer using the contact details provided above.
8. Breaches of security
Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with the Privacy Act requirements.
9. How you can access, change or delete personally identifiable information
You have a right to get a copy from us of the personal information we hold about You. If you wish to receive a copy of this information, please address your request to the Privacy Officer. We will deal with your request promptly and in any case at least within 30 days of the date of receiving it. We will give access to the information in the manner You request, where reasonable and practicable. This will be subject to any exemptions allowed under the Privacy Act. We will correct or delete inaccurate or incomplete personal information we hold about You at your request.
11. Contacting BPS about Privacy matters
When contacting us you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or we are required or authorised under Australian law to only deal with individuals who have identified themselves.
12. Privacy Officer Details and Feedback