Privacy Policy

Effective Date: November 3, 2023

VersiFi Trading, Inc. and its subsidiaries and affiliated companies (“VersiFi”, “Company”, “we”, “our”, or “us”) understands and respects our users’ need for privacy. This VersiFi Privacy Policy (“Privacy Policy”) explains how VersiFi collects, uses, and shares information we collect about you when you use our websites (including our company website www.VersiFi.io, the “Site”). When you visit our site and use our services, you trust us with your personal information, and you acknowledge reading and considering this privacy policy. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us [email protected].

We acknowledge that in collecting Your Personal Data We are bound by the laws of the British Virgin Islands and will process Your Personal Data in accordance with the British Virgin Islands Data Protection Act and, in respect of EU data subjects, the EU General Data Protection Regulation (“GDPR”). We confirm that VersiFi Trading, Inc. is the data controller for the purposes of the British Virgin Islands Data Protection Act. We take your privacy very seriously. In this privacy policy, we explain what information we collect, how we use it and what rights you have in relation to it. This Privacy Policy applies to all information collected through our and/or any related services including but not limited to sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”). Please read it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Site and our services.

1. What information do we collect?

1.1 Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering or expressing an interest in obtaining information about us or our products and services or otherwise contacting us.

1.2 Information automatically collected

We automatically collect certain information when you visit, use or navigate our Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes. We also collect information through cookies and similar technologies.

2. Principles of processing personal data

We fully respect Your fundamental rights and consider protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, we follow the following basic principles:

• We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency about the way We handle Your Personal Data.
• We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and We do not process it further in any manner incompatible with these purposes.
• We process Your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected.
• We make reasonable efforts to ensure that Your Personal Data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
• We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
• We may process Your Personal Data to fulfill our obligations under the Terms and Conditions and to comply with our legal obligations, for the following purposes:
  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose:
    • For the purposes of commercial communication, marketing and advertising of Our Services to new users or third-party Services via SMS, telephone, e-mail, internet, fax, mail, social media and / or any other appropriate communication channels.
    • For personified market research and/or analysis purposes to better understand Your needs, preferences, interests, experiences and / or habits as a consumer.

You have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy. Withdrawal of Your consent does not affect the lawfulness of the treatment of your data prior to its revocation.

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with any applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

We collect and processes the following Personal Data:

• At the point of Your Account registration:
  • Name and Surname
  • E-mail address
  • Mailing address
  • Telephone number
  • Date of birth
  • Scanned copy of a valid government-issued passport or ID Card
  • Information about used cryptocurrency addresses
• At the point of your access and use of the Website:
  • IP Address.
  • End user device data
  • General communication data.
  • Browsing data.
  • Information on user preferences regarding the Website

Any other Personal Data directly provided by You during Your interaction with Us.

3. Is your information transferred to third parties and/or internationally?

Our servers are located in the United States. If you are accessing our services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information with, which third parties may be in other countries.

However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. The processing of your personal data by third parties (data processors) is done under a contract compelling data processors to use the same level of data protection provided under this Privacy Policy. Furthermore, transfers of data to our data processors which are located outside of the EU/EEA or the British Virgin Islands are subject to Standard Contractual Clauses issued by the EU Commission.

More specifically, for the execution of the purposes mentioned in this Privacy Policy, We may provide access or transmit Your Personal Data to the following recipient: Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, like Google Analytics, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data about how you interact with the over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we controller that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• Other Users. When you share personal information or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the in perpetuity. If you interact with other users of our and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Site, and view your profile
  
  

4. Do We use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse cookies is set out in our Cookie Policy, as defined in Section 14. We use Google Analytics to collect information about your visit to the Site. Such information may include but is not limited to time of visit, pages visited, time spent on each page of the Site, referring site details, type of web browser, type of operating system, flash version, JavaScript support, screen resolution, screen color processing ability, network location, and IP address.

5. What is Our stance on third-party websites?

The Site may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the site. You should review the policies of such third parties and contact them directly to respond to your questions.

6. How long do We keep Your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your personal information for longer than 2 years unless required by applicable law.

When We have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then We will securely store your personal information and isolate it from any further processing until deletion is possible.

7. Data Security and Confidentiality

In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorized or accidental access, processing, deletion, alteration or other use, we apply appropriate internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

The processing of Your Personal Data by us is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.

Your Personal Data is processed solely by our authorized personnel, bound by strict obligations of confidentiality.

8. Do We collect information from minors? 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

9. What are Your Privacy Rights?

You have the right:

• To request access to Your Personal Data and information related to their processing and obtain a copy thereof.
• To request for the rectification of any inaccuracies or any missing Personal Data of yours.
• To request for the erasure of Your Personal Data.
• To request for the restriction of the processing of Your Personal Data in cases explicitly provided for by law.
• To request for the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format.
• To object to the processing of Your Personal Data in cases explicitly provided for by law.
• To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on You or significantly affects You.

Any requests relevant to the above must be addressed in writing to [email protected].

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of Your request, We will provide relevant justification.

If Your request does not meet the requirements of applicable law, We reserve the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject Your request.

If you believe Your rights are infringed under the GDPR, You have the right to file a complaint with the Office of the Information and Data Protection Commissioner at the following website: https://idpc.org.mt/en/Pages/contact/complaints.aspx. If you believe Your rights are infringed under the British Virgin Islands Data Protection Act, You have the right to file a complaint with the British Virgin Islands at the following website: https://bvi.gov.vg/services/filing-consumer-complaint.  Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

11. Do California residents have specific privacy rights?

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

12. Do We make updates to this Privacy Policy?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

13. How can I stop data collection?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, and if that is the case, we will notify you at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

14. Cookie Policy

We track user activity on our Site by setting cookies on your browsers. These cookies are set in order to remember preferences when you return to our site, such as form field values. By continuing to browse the site, you are agreeing to our use of cookies.

Our Site uses three types of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Further information about cookies and their purpose can be found by visiting: http://www.allaboutcookies.org/

We use the following first-party cookies:

• Session cookie
• Visitor cookie
• Opt In cookie

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Blocking cookies

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies or opt-out from being tracked by Google Analytics. However, if you use your browser settings to block all cookies (including essential or other cookies such as Google Analytics) you may not be able to access parts of our site and this may affect your use and experience of our Site.

Duration of cookies

Except for essential cookies, all cookies will expire after 10 years.

FAQs

• Do the cookies expire?
  • The cookie duration is set to 10 years.

• Do the cookies store any personal information (encrypted or otherwise)?
  • No. Cookies are simply a numeric identifier that allow us to recognize repeat users and have no meaning outside the marketing automation system.

• How can someone stop being tracked?
  • Cookies are set on users’ browsers. If cookies are disabled (generally or selectively), or if a browser extension is enabled, cookies may not be set properly and prospect activity may not be tracked.

• How can I reject and delete Cookies?
  • Most web browsers automatically accept cookies. However, you do not have to accept cookies and you can, should you choose to at any time, reject or block the use of cookies and delete all cookies currently stored on your computer or mobile device. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu, or by visiting: www.allaboutcookies.org.

15. Your obligations

By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.

If You are found to be in breach of Your obligations or if we have reasonable suspicion that the information You provide is false or incomplete or in any way contrary to applicable law or this Privacy Policy, We retain the right to reject Your application for registration or to suspend or terminate Your Account immediately without notice. In this case, You have no right to any compensation due to the rejection of Your application, or the suspension or termination of Your Account.