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Privacy Policy

Last Updated: March 31, 2023

Introduction

BLOK BE d.o.o., Kapucinska Ulica 31, Osijek, OIB: 98712426804 (hereinafter: 'BLOK BE') is a data controller according to this Privacy Policy. BLOK BE runs a digital asset exchange platform for purchases of stablecoins. The terms “we,” “us,” and “our” refer to BLOK BE and its affiliates. We are committed to protecting and respecting your (“you”, “your”, “customer”) privacy, as well as to safeguarding the data that our website visitors and service users share with us.

This Privacy policy sets how we collect, use and manage the personal information we receive from you, or a third party, in connection with our provision of services to you or which we collect from your use of our services ('Services') and/or our website (the 'Site').

By accessing and using our Service, you are accepting and consenting to the practices described in our Privacy Policy. Please read the following carefully. If you don’t agree with this Privacy Policy, you should not use our Site and Services.

We will also ask you to agree to our use of cookies in accordance with our Cookie Policy when you first visit our website. For more information about cookies, the types of cookies we use and how we use them please see our Cookie Policy.

We have incorporated firm security measures to ensure the protection of your personal data (“Personal Data”) against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

Data collection and use

We collect the Personal Data which you provide directly to us or which we generate when you open a BLOK BE Account, perform any transactions on our Platform, or use other BLOK BE Services or our website.

The data you provide us are by registering for a BLOK BE account, using our support on the Site or corresponding with us by phone, email or any other medium. This may include:

  • Contact information, such as full name, home address and email address, date and place of birth, mobile phone number;
  • Account information, such as username, password, account settings and preferences;
  • Financial information, such as bank account numbers, bank statement and trading information;
  • Identity verification information, such as images of your government-issued ID, passport, national ID card or driving licence;
  • Residence verification information, such as utility bill details or similar information;
  • Information regarding the way in which you use our Services, such as when you used our Services, and the specific Services used;
  • Information relating to communications with us, whether through our website or via email, over the phone or via any other medium.

Furthermore, we may collect and process Personal Data that you voluntarily and with your consent give to BLOK BE in our website’s forms, such as when you sign up for information and newsletters. You can unsubscribe from the newsletter by opening one of BLOK BE emails, which you received, and clicking “unsubscribe” at the bottom of the page.

Purpose of processing Personal Data

The information we collect and use are for the following purposes below:

  • Verification of your identity in accordance with applicable know-your-customer, money-laundering and other financial sector legislation or regulations;
  • Communication and establishment of a responsible commercial relationship with you;
  • Customized content by understanding your needs and your eligibility for products and services;
  • Information to you about new products and services;
  • Information to you about changes and enhancements to our Site;
  • Showing ads on other websites to you
  • Processing billing and collection of any fees;
  • Delivery of products and services to you;
  • Survey conduct and get feedback from you;
  • Monitor and improvement of our Site;
  • Compliance with our legal or regulatory obligations

Legal bases for processing your Personal Data

Legal basis for processing your Personal Data may be one of the following:

  • Keeping to our contracts and agreements with you
  • Legal obligations
  • Legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations
  • Legitimate interest
  • Consent

Regarding the personal data that we process based on your consent, we draw your attention that you can withdraw your consent at any time. In that case we will stop processing these personal data, but only for the period after the withdrawal of consent and only those personal data that we do not process on any other legal basis.

Security of information

Security and confidentiality of your Personal Data is of the utmost importance to us. To ensure it, we use a variety of security measures:

  • Only authorized staff are permitted access to your Personal Information and are required to treat the information as highly confidential;
  • Staff data protection and information security trainings;
  • Password protected directories and databases;
  • Security and data protection policies and procedures;
  • Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely;
  • 2-factor authentication;
  • Vulnerability Scanning to actively protect our servers from hackers and other vulnerabilities;
  • All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database;
  • Constant security review and improvement;
  • Other measures to mitigate risks identified during the risk assessment process.

However, it is important to notice that we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks.

You are responsible for keeping your BLOK BE account passcode and pin numbers safe and secure. Never share your account details with anyone else or let them sign in as you. If there is an unauthorised use or any other breach of security involving your information, you must notify us as soon as possible (see Contact Us).

Disclosures

Your information may be shared to third parties and legal and regulatory authorities only where it is necessary for us to lawfully carry out our business activities, such as:

  • With your consent or at your request;
  • When required to do so pursuant to any applicable law, regulations or rules;
  • Where required to provide services to you;
  • To protect the rights, property, or safety of us, our clients, or others;
  • With other financial institutions regarding a misdirect payment or financial crime;
  • With third parties providing services to us, such as market analysis, correspondent banks, fraud prevention agencies and other agents acting on our behalf;
  • If our legitimate business interests require disclosure;
  • In anonymised form as part of statistics or other aggregated data shared with third parties; or
  • To enforce or apply our Terms of Service and other agreements.

Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide BLOK BE Services or as required by law. By using our Services and accepting our Terms of Service, you consent to the disclosure of your Personal Information as described in this Privacy Policy.

Transferring your information

All data you provide to us is stored on our secure servers. Where we transfer our data outside of the EEA, we ensure that adequate safeguards are in place.

Your personal data is processed in the EEA but may be transferred worldwide, due to some of our third-party service providers who are engaged on our behalf. Personal Data and other data may therefore be exported outside of the jurisdiction in which you reside. Your Personal Data may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Data through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

Data retention

We have set policies and procedures for data retention in order to retain any personal information for no longer than required by applicable laws or regulations, for purposes for which it was obtained.

Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country and the applicable local legal or regulatory requirements.

When a users’ account is terminated or expired, we may need to maintain records for a significant period of time, as we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 5 years after our business relationship with you has ended.

Your rights

  • You may access, verify, correct and update your Personal Data held by us.
  • You may request the deletion of your Personal Information held by us.
  • You can ask us to suppress or block the processing of your personal information in certain circumstances.
  • You may request the transfer of a certain part of your Personal Data to another party.
  • You have the right to ask for reconsideration of any decision about you, that was based on an automated process.
  • If we are processing your Personal Data based on a legitimate interest you may challenge this.
  • You have a right to lodge a complaint with supervisory authority.

Marketing

Company news and updates, as well as relevant marketing information may be communicated to you. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under law in pursuit of our legitimate interests. If you do not wish to receive BLOK BE marketing material, you may unsubscribe at any time by clicking “unsubscribe” at the bottom of an email we sent you or by contacting us.

Updates to Privacy Policy

Our Privacy Policy may be revised, modified and/or updated, without prior notice. Any changes we make will be posted on this page, so it is advisable to review it frequently.

Contact Us

If you have any questions or comments regarding this Privacy Policy and/or practices, feel free to contact us at the e-mail address: support@blokbe.com, or by mail to the address Kapucinska ulica 31, Osijek. If you are not satisfied with the way we process your personal data, you can contact the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, Zagreb, e-mail: azop@azop.hr.