Privacy Statement
1. Introduction to this Privacy Statement
This is the Privacy Statement of BOTS Slovakia s.r.o. (Corporate Identification Number: 53 601 033 and address: Bulharská 139, 821 04 Bratislava) (“BOTS Slovakia”, “we”, “us” and “our”), and it applies to us as long as we process Personal Data that belongs to individuals (“you”, “Client”).
You share different types of personal data with us when you use the services provided by BOTS Slovakia, execute transactions, view our website, and contact us.
In our Privacy Statement, you can read about how we handle your personal data. You will also find information about what personal data we process and what we do with it. In addition, you can read about your privacy rights; for example, the right to access information, the right to rectification and various forms of right to object.
We update this Privacy Statement regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into consideration, as well as that we remain ahead of the changing regulatory environment.
It shall be pointed out that none of the processing purposes set out in this Privacy Statement involves automated decision-making and profiling as defined in Article 22 of the GDPR.2. Purpose of this Privacy Statement.
2. Purpose of this Privacy Statement
We, at BOTS Slovakia, understand that your personal data is important to you. Through this Privacy Statement, we aim to explain in a clear way what data we collect, why we collect it, how we use it, process it, store it and protect it.
The Privacy Statement applies to all Clients of BOTS Slovakia, these are all individuals who either are using, have used or have expressed a desire to use the services provided by BOTS Slovakia.
3. How does BOTS Slovakia obtain your personal data?
BOTS Slovakia collects the personal data of its Clients through:
A) direct interactions (such as when you have been asked to provide information or you make a purchase order or sale order);
B) data from third parties (such as information on third-party websites or other information Clients may have made publicly available, or information provided by third-party sources, such as government entities);
C) automated tracking technologies (such as information automatically collected about Clients’ interaction with the Website).
4. Why does BOTS Slovakia collect your personal data?
BOTS Slovakia collects Client data on the basis of its legal obligations stemming from Act No. 297/2008 Coll. Act on protection against money laundering and terrorist financing and on the amendment to certain acts (Zákon č. 297/2008 Z. z. o ochrane pred legalizáciou príjmov z trestnej činnosti a o ochrane pred financovaním terorizmu a o zmene a doplnení niektorých zákonov v z.n.p.) in accordance with Art. 6(1)(c) GDPR and in order to prevent the misuse of the services for the purpose of money laundering, terrorist financing, fraud, or other financial crimes according to Art 6(1)(f) GDPR. Therefore, BOTS Slovakia identifies all of its Clients and obtains from them various sources of personal data, such as their name, date of birth, address and a copy of their ID document in order to conduct customer due diligence and to prevent fraudulent conduct or behaviour that contravenes international sanctions and to comply with regulations against money laundering, terrorism financing and tax fraud.
BOTS Slovakia also collects Client data on the basis of its performance obligation stemming from the Agreement between BOTS Slovakia and the Client, according to Art. 6(1)(b) GDPR: We collect information from you that is needed in order for us to be able to provide you with our services - this contains provisions of informing you about the ongoing exchange services.
BOTS Slovakia maintains its services and develops new products. Data generated by the use of the services to ensure continued development, enhancement of user experience and efficient operation. It is legitimate interest of BOTS Slovakia to ensure continued development, enhancement of user experience and efficient operation of its services, therefore the legal basis for data processing is Article 6(1)(f) of the GDPR.
Any additional sources of data (such as cookies or marketing: email or sms subscription) that are collected on the basis of Clients’ consent according to Art. 6(1)(a) GDPR, which Clients are free to give or refuse.
5. What kind of personal data is collected by BOTS Slovakia?
Prior to using our services, Clients provide BOTS Slovakia with (some of) the following data, which BOTS Slovakia stores and processes.
Natural persons:
A) First and last name as written in their Passport;
B) Copy of the passport or identity card;
C) E-mail address;
D) Phone number;
E) Residential address;
F) Date and Place of Birth;
G) A visual image of the face of the Client;
H) A visual image of the Client’s identity document;
I) The answers to a series of questions regarding the Client’s source of wealth;
J) Additional information on the source of funds of Transactions;
K) Additional documents, data, or information that may be necessary to establish a Client’s identity and their verification.
L) Information that is obligated to collect concerning the Know You Customer process (which can also contain information on possible fraud that has been committed).
M) PEP Verification questionCompanies:
A) Number of their Chamber of Commerce registration;
B) Statutory name;
C) Registered address;
D) Identity of UBO(s);
E) Answer to a PEP verification question;
F) Answer to a Source of Funds and Area of Activity question;
G) Representatives;
H) Organization chart of the company going up all the way to the natural person owners (UBO(s));
I) Chamber of Commerce extract;
J) Passport copies of the UBO(s);
K) Proof of the powers of representation of the representatives;
L) Additional documents, data, or information that may be necessary to establish a Client’s identity and their verification.
Furthermore, BOTS Slovakia stores and processes with regard to its clients, (some of) the following data:
A) Fiat-cryptocurrency transfer history;
B) Trade history;
C) IP address;
D) Bank account number/IBAN, BIC number;
E) Appstore/Google Playstore account information of its Clients;
F) Information about devices, operating system, online behaviour and preferences data: such as the IP address of your mobile device or computer, the type, version and brand of device used to visit our website, the operating system and browser version you use, your cookie settings, your mobile advertising ID and the pages you visit on our website.
G) Data about your interests and needs that you share with us, for example when you contact our support team or contact us/address us in any way such as through social media (Facebook, Twitter, Instagram, Google and Youtube). We follow public messages, posts, likes and responses to and about BOTS Slovakia on the internet.
6. Your duty to provide data
The provision of personal data for the processing purposes set out in this privacy statement is in general a necessary condition for the provision of our services. Where the provision of personal data for certain purposes is possible on a voluntary basis, then we will provide specific information thereon and will ask for specific consent.
It shall be further noted that we undertake to request only the personal data that is strictly necessary for the relevant purpose. Failure to provide the necessary personal data may cause delays in the availability of certain products and services.
7. What do we do with your personal data?
The personal information collected is used for the purposes which Clients have provided it for and might be further used for statutory or other legitimate purposes only. BOTS Slovakia uses Clients’ personal data in the following ways:
A) performing the obligations arising from the agreement between BOTS Slovakia and Clients, administering the relationship with Clients, such as providing and managing their access to and use of the services and Website (this processing is necessary for the performance of the Agreement between BOTS Slovakia and the Client);
B) improvement of BOTS Slovakia’s services and development of new products, (this processing is necessary for the purposes of BOTS Slovakia’s legitimate interests);
C) marketing, such as providing Clients with marketing or advertising communications BOTS Slovakia considers relevant for them (this processing is based on Clients’ given consent);
D) providing online chat rooms, message boards & other communication channels to Clients (this processing is based on Clients’ given consent); and
E) other general business support purposes, including but not limited to procurement, financial and fiscal management, risk and compliance management, and external reporting (this processing is necessary for compliance with a legal obligation to which BOTS Slovakia and its exchange provider partners are subject to, or that is otherwise lawful under the applicable data protection laws or for BOTS Slovakia’ legitimate interests).
8. Who do we share your data with and why?
To be able to provide the best possible services and further its business operations, BOTS Slovakia may share certain Client data internally or with selected third parties incorporated inside or outside of the European Union. Parties BOTS Slovakia might share data with include:
A) service providers; e.g. for managing or hosting services and/or underpinning technology for the services BOTS Slovakia provides;
B) business partners; e.g cryptocurrency exchange provider partners, payment service providers, etc.
C) other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance-related matters; or
D) governmental authorities and regulators, as required under the applicable law.
Whenever we share your personal data externally with third parties in countries outside of the European Economic Area (EEA) we ensure the necessary safeguards are in place to protect it. For example, we rely upon, amongst others:
- Requirements based on applicable local laws and regulations;
- EU Model clauses, when applicable, we use standardised contractual clauses in agreements with service providers to ensure the processing of personal data transferred outside of the European Economic Area complies with the GDPR.
9. Your Rights and how we respect them
As your personal data is processed, you also have privacy rights.
To the extent provided under the GDPR, your rights include the following:
A) Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
B) Right to rectification (‘correct your personal information’): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
C) Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by the applicable law.
D) Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with the Client’s consent, or based on an agreement with BOTS Slovakia.
E) Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period.
F) Right to object: the right to object to the processing of your personal information. The reasons for an objection should relate to your particular situation, and be related to processing based on the legitimate interest condition.
G) Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time.
Clients may exercise the rights above or request further information on the Privacy Statement by contacting the Data Protection Officer via Privacy@revenyou.io. We aim to respond to your request as quickly as possible. In some instances, this could take up to one month (if legally allowed). Should we require more time to complete your request, we will let you know how much longer we need and provide reasons for the delay.
You can also contact the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky) via email statny.dozor@pdp.gov.sk.
10. How long do we keep your personal data?
Clients’ personal information will be processed to the extent necessary for the performance of BOTS Slovakia’s obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with the 18/2018 Coll., Act on the Protection of Personal Data and on Amendments and Supplements to Certain Acts (18/2018 Z.z., Zákon o ochrane osobných údajov a o zmene a doplnení niektorých zákonov). When BOTS Slovakia no longer needs your personal information or is not required by the applicable laws to store it, BOTS Slovakia will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that Clients can no longer be identified from it.
11. How do we protect your personal data?
We take appropriate technical and organisational measures (policies and procedures, IT security etc.) to ensure the confidentiality and integrity of your personal data and the way it's processed. We apply an internal framework of policies and minimum standards across all our businesses to keep your personal data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments.
In addition, BOTS Slovakia limits access to personal information by our employees. Furthermore, BOTS Slovakia employees are subject to confidentiality obligations and may not disclose your personal data unlawfully or unnecessarily. To help us continue to protect your personal data, you should always contact BOTS Slovakia if you suspect that your personal data may have been compromised.
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