Privacy Policy

Last updated: 25/08/2023

We (“We”, “Us” or “Our“) are committed to securing your Personal Data and your privacy.

This privacy policy (the “Policy”) has been created to inform you about how We manage, collect, stores and use the information you provide in connection with the website http://bitvestment.software/ (the “Website”).

We will uphold the following principles:

• To be transparent in respect of the collection and processing of Personal Data about you:

It is important to Us that you have at all times all the information required for you to make educated decisions about the processing of Personal Data about you when you visit our Website. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing.

In addition, if We find you are required to be provided with specific information, We will provide it to you in the appropriate time and place.

We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: [email protected]

• To process Personal Data about you solely for the purposes outlined in the Policy:

The purposes for which We may process Personal Data about you include, inter alia, to make the Website available to you and provide you with the services involved therein , to enhance the user experience in the Website, to improve the  Website and the services involved therein, to protect Our rights and interests, to perform business and administrative activity that supports the Website, and/or to uphold any legal and/or regulatory requirements.

• To invest significant resources in order to respect your rights in connection with Personal Data about you:

We apply significant resources to allow you to exercise your rights as a data subject. Therefore, you may approach Us any time you wish to review Personal Data about you, have Us amend it, erase it, cease using it for specific purposes or in general, or transfer it to you or to a third party, all as described in the Policy. We will fulfill your wishes in accordance with the law and the Policy.

• To secure Personal Data about you:

While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures aimed at ensuring that the Personal Data about you is secured.

Our Complete Privacy Policy

1. The Scope of this Policy

This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, process it, etc.

In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

The Website is intended for general audience and are not directed at children under the age of 18. We do not knowingly collect or solicit information from anyone under the age of 18 or knowingly allow such persons to access the Website. If We learn that information about a child was collected, We will take reasonable steps to delete such information as soon as possible.

2. When Do We Collect Personal Data About You?

We collect Personal Data about you whenever you use the Website or interact with Us in any manner. In some instances, you will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about you by way of observation of your use of the Website.

3. No Obligation To Provide Personal Data To Us And Its Implications

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with some or all of the services involved in the website, will prevent your use of the Website, and/or will cause the malfunctioning of the services involved in the Website.

4. What types of Personal Data do We collect? Personal Data We collect upon each browsing onto the Website: 

• Website activity information – We automatically gather certain data out of your use of the Website. The information that We gather about you in this context includes any interaction that you will make with the Website, including the Website’s pages that you will visit, Your interaction with such pages, the content that you will view, and the like.
  • Technical usage and log information – as you navigate through and use the Website, We may also use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns. This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used, information regarding the device you used. Some of this information may not identify you personally, and therefore not constitute Personal Data.
  • Communication information – when you contact us, including via the Website, you may provide Us with your name, certain contact information (such as email address) and the content of your communication with Us.

5. The Purposes Of The Processing Of Personal Data And Their Legal Basis

We processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

We will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which We may process Personal Data about you are as follows:

1. Processing is necessary for the purposes of the legitimate interests pursued by the Us or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.
2. Processing is necessary for compliance with a legal obligation to which We are subject.

If you wish to receive more information detailing how processing is being necessary for the purposes of the legitimate interests pursued by Us or by a third party, you may approach Us by sending a notice to [email protected] at any time.

The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:

	Purpose	Legal Basis
1	In order to make the Website available to you and provide you with the services involved therein	Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party
2	In order to respond to your queries, requests, and/or complaints Processing of Personal Data about you is required in order to respond to queries you have concerning your use of the Services.	Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party.
3	In order to comply with any legal obligations or judicial or administrative orders We process Personal Data about you in order to comply with Our various legal obligations.	Processing is necessary for compliance with a legal obligation to which We are subject to.
4	In order to improve the Website and the services involved therein We may use Personal Data about you in order to improve the Website and/or the services involved therein. Such processing will include, inter alia, any crash logs or other malfunction reports obtained in respect of the Website.	Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party.
5	In order to perform and maintain various activities supporting the provisions of Our Services Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.	Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party.
6	In order to perform analysis, including statistical analysis We use various analytical measures (including statistical ones) to make decisions on various issues.	Processing is necessary for the purpose of the legitimate interests pursued by Us or by a third party.
7	In order to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims We may process Personal Data about you in order to protect Our interests, rights, and assets, or those of third parties, according to any law, regulation, or agreement, including any of Our terms and conditions and policies.	Processing is necessary for the purpose of the legitimate interests pursued Us or by a third party.

6. Transfer Of Personal Data To Third Parties

We may share Personal Data about you with third parties that provide Us services, such as storage and hosting providers, IP address information, analysis of user experience and research, analytical, technical, and diagnostic services.

We may share Personal Data about you with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims.

In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the We are a part of, or in the event of any similar transaction (including the sale of Our assets and/or of any company within the group of companies of which We are a part of), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of Us and/or of any company within the group of companies of which We are a part of.

7. Cookies and Third Party Services

We may use certain third party services, such as analytics companies or companies delivering advertisements in our Website, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.

Cookie (which is a small text file) is installed on the device via which you visit or access the Website. The cookies shall allow to collect information about you and your behavior, in order to improve your user experience, to remember your preferences and settings, and to customize and offer you products and services that may interest you. Cookies may also be used to collect statistics and perform analytics.

Some of the cookies We may use are session cookies, which are downloaded temporarily to your device and last until you close your web browser, while others are persistent cookies, which last on your device after you cease browsing the Website and can be used to help the Website remember you as a returning visitor when you return to the Website.

Types of cookies:

The cookies We may use are classified according to their functionality, as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are strictly necessary to enable you to navigate the Website and use features you have requested. They are used to provide you with Our content, products, and services that you have requested. Such cookies are essential to help your device download or stream information so that you can navigate around the Website, use its features, and return to pages you have previously visited.	These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Website. These cookies are deleted when you close your web browser (session cookies).
Functionality Cookies	These cookies are used to recognize you when you return to the Website and allow Us to remember your choices and preferences.	These cookies survive the closing of your web browser, and last until their applicable expiry time.
Performance Cookies	These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website.	These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.

The Cookies incorporated in our Website are as follows:

Party	Name	Retention	Type	Function
Tracking of statistical data (anonymized)	_ga	2 years	Non-functional	Analytics and Performance Related Cookies
Tracking of statistical data (anonymized)	_gid	24 hours	Non-functional	Analytics and Performance Related Cookies
Tracks which elements are clicked most on a website (anonymized)	_gat_gtag_*	1 minute	Non-functional	Analytics and Performance Related Cookies
Hotjar web analytics	_hjSessionUser_{site_id}	365 days duration.	Non-functional	Analytics and Performance Related Cookies

Blocking and removal of cookies

You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note, however, that if you do so, some or all of the Website’s features and functionalities might not perform as intended.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

We shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us.

In order to ensure that Personal Data about you is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.

9. Transfers Of Personal Data To A Third Country Or An International Organization

Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, We shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.

If you are an EEA (European Economic Area) resident, please note that these safeguards and protection will be available if any of the following are met:

• The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR“).
• The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
• The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You may request that We will provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following  address: [email protected]

10. Protection Of Personal Data About You

We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.

We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of your Personal Data, and We will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Data about You including, but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.

We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties.

Any transfer of Personal Data via the internet cannot be fully secured. Therefore, We cannot ensure the protection of Personal Data about you when transferred via the internet to Us.

11. Links To Websites of Third Parties

The Website may provide links to other websites and/or applications. Some of these websites and/or applications are owned or operated by Us, and some of them are operated or owned by third parties. In the latter case, We do not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities.

This Policy only applies to this Website and not to any other website or application referred to in this Website. Whenever you access such websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you.

12. Your Rights In Respect Of The Personal Data About You

Generally, you have the right to request that We provide you with confirm whether Personal Data about you is being collected by us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict you consent to certain processing of your Personal Information.

Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: [email protected].

Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.

At any time, You may approach Us by sending a notice to the email address [email protected], in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

The Company may provide You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Our’s or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests.

Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials are tailored to offer You products and services which We think may be of more interest to You.

In addition, You may withdraw Your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: [email protected]. or by clicking the unsubscribe option in any marketing material sent to You. You can withdraw Your consent from receiving marketing materials via push notifications in Your mobile device’s settings page.

Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our services or for other legitimate non-marketing reasons.

If You reside in the U.S.A, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights You might have:

	Right	Scope
1	Right to know	You have the right to receive the following information: The specific pieces of Personal Data We have collected about You.What types of Personal Data collected;categories of personal data collected;What are the types of sources of the Personal Data collected;the purpose of collecting the Personal Data;Types of third parties with whom We share Personal Data, if any; and
2           3	Right of Erasure           Right to non selling or sharing	You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Website or Services otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information. You may ask Us to not sell or share Your Personal Data.
4	Right to Non-Discrimination for the exercise of Your privacy rights	You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA.
5	Right to designate an authorized agent to submit CCPA requests on Your behalf	You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below.

In order to exercise Your rights, please contact us using the following details: [email protected]

If you are an EEA resident please read this section below:

You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address: 

Right of access

You have the right to receive from Us confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from Us rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.

We shall provide a copy of the Personal Data about you undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, We may not fulfill your request or do so in a limited manner.

Right to rectification

You have the right to obtain from the Us the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.

Right to erasure

You have the right to obtain from Us the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) the Personal Data has been unlawfully processed; or (e) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the We are subject.

This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which We  are subject; or (b) for the establishment, exercise, or defense of legal claims.

Right of restriction of processing

You have the right to obtain from Us the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling Us to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) We no longer need the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; or (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by Us or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

Right to data portability

You have the right to receive the Personal Data about you, which you have provided to Us, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from Us to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and Our rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

Right to withdraw consent

Where the processing of your Personal Data is based on your consent, You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.

Your rights in respect of Personal Data about you as outlined in this section 12 may be restricted by European Union or Member State law to which We are subject.

We shall provide you with the information requested according to your rights outlined in this section 13 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

The information requested according to your rights outlined in this section 12 shall be provided free of charge, unless stated otherwise in this section 12. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

We may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section 12, if We have reasonable doubts concerning the identity of the natural person making the request.

13. Changes To This Policy

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify you of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our Website.