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Privacy Policy

PRIVACY POLICY

Ivy Net Ltd (“we” or “us” or “Ivyn”) are committed to protecting and respecting your privacy.

1. SCOPE OF POLICY

1.1 This policy together with the Terms of Use apply to your use of:

a) our website at ivyn.com (the “Site”);
b) the Ivyn Digital Currency Mobile App (“App”) once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”); and
c) any of the services accessible through the App or the Site (the “Services”).

1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

Controller

We are the data controller responsible for your personal data.

Data Protection Officer

We have appointed a data protection officer (“DPO”), dr. Kata Stier. Our DPO has a number of important responsibilities including:

  • monitoring Ivyn’s compliance with the GDPR and other data protection laws;
  • raising awareness of data protection issues, training Ivyn staff and conducting internal audits; and
  • cooperating with supervisory authorities on our behalf.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us via compliance@ivynet.eu.

Complaints

You have the right to make a complaint at any time to the Office of Information and Data Protection Commissioner (IDPC), the Maltese supervisory authority for data protection issues (www.idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.

So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:

  • Always keep your data safe and private.
  • Never sell your data.
  • Allow you to manage and review your marketing choices at any time.

2. COOKIES

2.1 We use cookies to distinguish you from other users of the App or the Site. This helps us to provide you with a good experience when you use the App or browse our Site and also allows us to improve the App and our Site. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

3. INFORMATION WE COLLECT ABOUT YOU

3.1 We will collect and process the following data about you:

a) Information you give us “Submitted Information“: This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail and/or the Site). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site (such as a Top Up, Instant Transfer, Digital Currency Exchange), participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.

b) Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:

(i) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting “Device Information“;

(ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;

(iii) transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;

(iv) information stored on your Device, including if you allow Ivyn access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically re-collect this information in order to stay up-to-date;

(v) details of your use of our App or your visits to our Site including transaction details relating to your use of our services, the time, date and location of the place the transaction was entered into.

c) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Ivyn Services like marketing or education), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include information which helps us to verify your identity or information relating to your payment transactions.

d) If you allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date.

4. USES MADE OF THE INFORMATION

4.1 Below is a summary of the key types of data that we make use of as part of the Ivyn Services. For more information on how these types of data are used and for which purposes then please see the table below.

We use information held about you in the following ways:

(a) Submitted Information: We will use this information:

  • to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Digital Currency Exchanges, and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. Please see the section on ‘Third Party Services’ below for more information;
  • to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
  • to notify you about changes to our service;
  • to facilitate social interactions through our services and to make you aware if any of your contacts who are Ivyn Users and have location services enabled, are in the same area as you. You can switch off location services in relation to this feature in the privacy settings of the payments section of the Ivyn Digital Currency App;
  • to make you aware if any of your contacts who are Ivyn Users have utilised any of Ivyn’s products or features. You can ask us to stop sending you marketing pushes at any time by adjusting your marketing preferences via the privacy section of the Ivyn Digital Currency App; and
  • to ensure that content from our site is presented in the most effective manner for you and for your computer.

(b) Device Information: We will use this information:

  • to administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Site and the App to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our Site and the App safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them;
  • to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
  • to comply with our regulatory obligations.

c) Location Information: We will use this information:

  • to deliver relevant advertising to you, for example, information on nearby merchants;
  • to protect against fraud.

d) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:

  • to help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Ivyn Account;
  • to process applications for products and services available through us including making decisions about whether to agree to approve any applications; and
  • for the purposes set out above (depending on the types of information we receive).

4.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

4.3 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a subsection of our users (for example, women in Paris). In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.


Purposes for which we will use your personal data

4.4 We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via compliance@ivynet.eu if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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