We collect Personal Data and Anonymous Data, as described below.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.
● We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, photographs, biometric information (including but not limited to device fingerprinting), company name, and password when you use our Site.
● We may also collect other Personal Data provided by third party identity verification services or via social networking websites.
● If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
● Certain services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
● If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
● We also collect other types of Personal Data that you provide to us voluntarily when seeking support services, such as email, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
● We may collect other data, including but not limited to, referral URLs, your location, blockchain analytics information related to blockchain addresses you provide.
Some information is collected automatically by our servers:
● Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
● As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
● We retain information on your behalf, such as transactional data and other session data linked to your Account.
When you register for or otherwise use our Services, we may receive information about your criminal convictions which we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to close your Account but we will notify you if this is the case at the time.
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
● Where we need to perform the contract we are about to enter into or have entered into with you;
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
● Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
● facilitate the creation of and secure your Account on our network;
● identify you and perform identity verification through a service provider;
● provide improved administration of our Site and Services;
● improve the quality of experience when you interact with our Site and Services;
● send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
● send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
● identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
● notify you about important changes to our Terms; and
● respond to your inquiries related to employment opportunities or other requests.
All data collected automatically will be used to administer or improve our services.
● We use IP address to make our Site and Services more useful to you, and to perform identity verification.
● We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
RtFinex does not sell user data to any third party.
We provide you with choices regarding certain Personal Data that RtFinex uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Personal Data to determine what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
By using our Services or requesting information from us, you opt-in to receive marketing communications, except in Vermont.
Vermont customers can opt-in to receive promotional offers by contacting us.
We will obtain your express consent (opt-in) before we share your Personal Data with any company outside of the RtFinex group for that company's own marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
● It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of RtFinex, our users, or the public.
● We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
RtFinex may contain links to other third party websites which are regulated by their own privacy policies. RtFinex is not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Site.
We share your Personal Data within the RtFinex group of companies which are based in various locations globally. If you are based in Europe, this will involve transferring your data outside the European Economic Area (EEA)
In addition, many of our external third parties are also based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
● We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
● We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
● In respect of transfers to entities in the US, we may transfer Personal Data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
You can update your information by contacting support and making a request.
We will retain your information for as long as your Account has not been closed or as needed to provide you access to your Account. If you wish to close your Account, open a ticket in our support center. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.
We take the protection of your personal information seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information. RtFinex servers and business operations are entirely located in the United States.
Please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:
If you wish to exercise any of the rights set out above, please contact us
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 rights 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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Unfortunately, if you're under 18, you can't use our Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we'll delete it immediately.
For Vermont customers:
In accordance with Vermont law, RtFinex will not share your non-public personal financial information with nonaffiliated third parties, except as required or permitted by law, or if you specifically consent to the disclosure. In addition, RtFinex will not share credit reports with third parties, including affiliates, except with your express consent.