Privacy Policy – FiatBear

This Privacy Policy provides an overview of all information regarding the processing of personal data by FiatBear, a business registered under the laws of the Netherlands, hereafter referred to as FiatBear, we or us.

FiatBear is strongly committed to protecting your privacy and complying with your choices. You will be in full control of all data relating to yourself. Both personal and non-personal data and information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. Specifically, we are in compliance with the EU General Data Protection Regulation (the “Data Protection Legislation”). We strive to make you feel safe when we collect or share your data and therefore, we want to be transparent on how we collect, use, share and store the information about you and the choices available to you as data subject.

This Privacy Policy is about how we handle the personal information of users of FiatBear (the Privacy Policy). The Privacy Policy applies to the FiatBear website, located at fiatbear.com and app.fiatbear.com (jointly, the Website), as well as your use of or access to any of our (online) services.

1. When does this Privacy Policy apply?

This Privacy Policy applies to the processing of personal data of FiatBear users. We will provide you with a high level of control over your personal data and will clearly inform you when information that personally identifies you is asked for.

2. Usage of personal data

We use and collect your personal data for the following purposes:

  • To offer you the functionalities of the Website and for the technical and functional management thereof: We strive to make our Website easily accessible and to offer you the best possible experience and functionalities. We process technical data of everyone who visits and uses our Website in order to manage it and improve its performance. We may also need to process your personal data so that you can save your data (or preferences) to configure your device to give you a personalized experience. The functionalities of the Website are largely made available through the use of functional cookies. You can read more about our use of cookies in our Cookie Policy.
  • For relationship management and marketing: FiatBear uses the information in the contractual relationships database to send you updates you on developments within FiatBear. We also may use your personal data for the development, execution and analysis of market research and marketing strategies.
  • To provide user support: We want to offer you the best experience possible when using our services and Website. Therefore, we are ready to handle any questions or complaints you might have. When you get in touch with us at our office, via social media, via a contact form, or in any other way, we will use your personal data in order to reply to you, answer your question, or handle your complaint.
  • To process your payment: In order to use our services, you will need to enter into an subscription agreement for payment thereof. We will process your payment data in order to handle the payments, and for administrative purposes such as sending you invoices or refunds.
3. Legal bases for collecting your personal data

The legal basis we have in order to collect your personal data will depend on the type of data collected. In any case, it will be either of the following:

  • We need to perform our obligations under a contract with you
  • You have given us explicit consent
  • It is in our legitimate business interest
  • To comply with our legal obligations

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, and/or text message with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out.

4. Which personal data do we collect?

We collect the following types of personal data:

  • When you create an account, we collect and process email address and password.
  • When you enter into a subscription, we collect and process your full name, email, address., and contact details.
  • When you connect to your Kraken.com account, Bybit.com account, or any other accounts as we may from time to time add to our services, we will process all details contained on this account. We may also collect additional financial and investment information to confirm regarding the funding of your investment experience, understanding this account (balance, deposits) to verify that you can start copy trading, income level, and source. We will also keep track of funds.your trading history.
  • Your usage of our Website is analysed by Google Analytics, Microsoft Application Insights, and Stripe, which may collect personal data (read more in our Cookie Policy).
  • Upon entering into a contract for our services, we will collect your payment details, such as your credit/debit card details, billing address, and payment history.
  • When you get in contact with us, we collect information you give us during the communication.
5. How long do we retain your personal data?

Your personal data will be retained by us for as long as necessary to serve the legitimate

business purposes as set out above. We may need to retain personal data longer to comply with applicable laws, such as those relating to tax and accounting and anti-money laundering. If there is no ongoing interest in retaining your personal data, we will promptly delete or anonymise it where possible.

6. Which parties have access to your personal data?

Within FiatBear, our employees, contractors, agents and directors have access to personal data, but only to the extent necessary to properly perform their individual tasks.

FiatBear only shares personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions of FiatBear. They therefore act as our data processor. In all cases, we will ensure that third parties with access to your personal information have implemented appropriate technical and organizational measures to maintain our intended level of privacy and security. We will conclude the necessary agreement with the data processor(s), whereby we include obligations to ensure that your personal data is only processed so that the data processor can fulfill his duty to provide services to us.

Under these conditions, the following third parties will have access to your personal data. Please click on the relevant links to review their respective privacy policies:

  • Information regarding your use of the website and other information gathered through cookies is shared with web analytics, session recording, and online marketing services. Read more about the use of cookies in our Cookie Policy.
  • We use Mailjet as a third-party service provider to send customer emails. Mailjet will have access to your email address and name.
  • Information regarding your payment details, transactions, and contact details, is shared with our third-party payment processor, Stripe.
  • We may use professional advisors such as insurers, accountants, consultants, and legal professionals. Our accountant will only get access to anonymized information.
  • When your activity gives us any indication to do so, we may disclose information with the relevant authorities necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to safety, or violations of the Terms of Service.
  • We may collect, process, analyse and share aggregate or de-identified information about used with third parties for marketing, advertising, research or similar purposes.
  • If we are in any negotiation with a third party which will involve the transfer of all or substantially all of our assets, we may transfer certain personal data as required.

In all other cases, your personal information will not be provided to third parties, unless required by law. FiatBear will never sell your personal data.

7. Transfer of your personal information

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Whenever we transfer your personal data to countries outside of the European Economic Area (EEA), we will do so in accordance with the Data Protection Legislation. Any party located outside of the EEA will have to enter into the Standard Contractual Clauses alongside any data processing agreement they enter into (unless exempted).

8. Security

Your personal information is stored securely at all times. We value the protection of your privacy. We have taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We further ensure that personal data is only accessible to those specific persons who are authorized based on their function.

We only select the third-party IT-service providers that have proper security facilities in place. In addition, we have implemented measures to guarantee your safe visit to and use of our Website. This way we prevent misuse of your data. These measures include computer security and protected files and facilities. Your connection to our Website is safe through activation of Secure Socket Layer (SSL).

FiatBear has taken the necessary technical and organizational measures to prevent, identify, report and deal with data protection breaches. However, in the event that a data breach occurs, FiatBear will, without undue delay and where possible, not later than 72 hours after being notified, report the breach of personal data to the relevant Data Protection Authority.

9. Your rights

As the owner of the personal data, you have the following rights:

  • Right of access: You have the right to receive a copy of the personal information we hold about you to verify that we are lawfully processing the data.
  • Right to correction: You may request any incomplete or incorrect information that we may have about you to be corrected or supplemented.
  • Right to be “forgotten”: If there is no good reason to keep your personal information, we will stop processing. You also have the right to ask us to delete your personal information.
  • Right to limit the processing of your personal data: You can submit a request not to process your personal data, either temporarily or permanently.
  • Right to portability: You can submit a request to transfer your personal data to a person or institution designated by you.
  • Right to object to processing: Under certain circumstances you can object to the processing of personal data altogether.
  • Right to withdraw consent: You also have the right to withdraw your previously granted permission to process your personal data or to object to the processing of your personal data by FiatBear.

Every request is subject to applicable law, which means that we may have to store the personal information. We also want to remind you that you have the right to make a complaint to your national Data Protection Authority if you think we are not compliant with the applicable data protection legislation.

If you want to exercise any of your rights as set out above, you can do so here at any time:

FiatBear:

10. How can you access your personal data?

If you want to know what personal data we have about you, you can ask us for details and a copy (if we hold personal data). This is known as a “subject access request”. All subject access requests should be made in writing and sent by email.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. Minors

We insist on not processing any personal data of children under the age of 16, unless this is explicitly consented to by a parent or legal guardian. However, as it is hard to detect whether we are doing so, we strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly.

12. External Links

Our Website may display links to other websites. Unless these other websites are affiliated with FiatBear, we are not responsible for the privacy policies that these other websites use, nor for their content and security. We advise you to inform yourself by reading the privacy policies on these websites.

13. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Website following the alterations. For major updates, we will ask you to reconfirm your consent. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 7 June, 2023.

14. Questions or comments?

If you still have questions after reading this Privacy Policy or if you have suggestions or comments about its content, you can always contact us via: [email protected].

Please let us know if, for any reason, you believe we have not adhered to the principles in this Privacy Policy. We will do our best to promptly make corrections.