Privacy policy
We the company kluz Ltd. (hereinafter "kluz Ltd.", "We", "Us") operate the website https://kluz.io This Privacy Policy is intended for users' enlightenment and describes how we process users' data and what rights users have as data subject.
For the purposes of the data protection laws that apply to us, including the GDPR, CLA, We act as the Data Controller for the Personal data that We collect and process to enable users to make use of Our Services.
The purpose of this Privacy Policy is to transparently provide users with an explanation as to the legal basis for collecting and processing users' Personal data, the categories of Personal data that may be collected, what happens to the personal data that We may collect, how long We are required to retain Personal data, who We may share Personal data with and to also explain users' rights as a data subject.
This Policy in the field of Personal data processing and confidentiality of personal information (hereinafter referred to as the "Policy") applies to https://kluz.io website (hereinafter referred to as the "Website") and is aimed to govern the information received (gathered) about the user while using the Website or any of the sites, services, services, programs and products of kluz Ltd. (hereinafter - the Services), as well as during the execution kluz Ltd. or its affiliates of any agreements and contracts concluded with the user in connection with the use of the Services.
1. Definitions and Personal data procession
"Privacy Policy" means this Privacy Policy updated from time to time and made public on Our Websites and through Our mobile applications.
"Personal data" in accordance with this Policy means any any information that can either itself identify "Data Subject" as an individual (hereinafter - "user" or "users") as well as the information that can be connected to user indirectly by linking it to.
"Personal data procession" or "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
kluz Ltd. stores and processes Personal data for as long as it is necessary to achieve the purpose for which it was collected.
"Third party" means a natural or legal person, public authority, agency or body other than the Data Subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorized to process personal data.
"Consent" of Personal data procession shall mean any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
"Cookie" means a small text file placed on User's computer or device by Our Website when user visits certain parts of Website.
"Automatic processing" includes the following operations if carried out in whole or in part by automated means: storage of data, carrying out of logical and/or arithmetical operations on those data, their alteration, erasure, retrieval or dissemination.
"Services" mean all Our products: Website, Applications.
2. Categories of Personal data being processed
A summary of the Personal Data that We process, when We collect it, how We use it and why We use it (i.e. the legal basis for processing) is listed below:
Directly Provided information: We may collect information you provide directly to us. For example, we collect information about you when you create an online account, complete a transaction, fill out a support form, respond to surveys, post messages to our forums or communicate with us in any other way. The types of information we may collect are as follows:
• Contact information, such as your name, mailing address, telephone number, and email address. Financial information, such as virtual currency account information.
• Government identification numbers, such as your social security number or a state-issued identification number.
• Biographic or demographic information, such as your date of birth, gender, occupation, employment status and any other information you choose to provide about yourself.
Transaction information: We collect information about the transaction performed by you via Kluz website or any third party affiliated or not affiliated with Kluz, including the amount of funds associated with a trade, wallet addresses, transaction identifiers, the types of trades executed and other transaction information.
Device and Log information: We collect information about the device you use to access the Company services, including device identifiers, type of operating system, and the type of browser used. We also log information about your use of the Company services, including access times, pages viewed and IP address.
Cookies: To enhance the quality of Our services, We use technologies, such as Cookies. Cookies do not typically contain any information that personally identifies users, but personal information that We store about users may be linked to the information stored in and obtained from Cookies.
We use Cookies to learn about users' traffic patterns and Website usage to help Us develop the design and layout of the Website in order to enhance users' experience browsing Our Website.
We use the following types of cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of Our websites.
Through cookies, Personal data is being processed for the purposes as described in Section 3 ("Purposes") in the following way:
• Cookies are to be deleted when user closes the browser (session cookies).
• Cookies remain stored on end user device even after the browser was closed (permanent cookies).
User can delete Cookies if wishes; while certain Cookies are necessary for viewing and navigating on Our Website, most of the features will be still accessible without Cookies. In order to restrict it to certain cookies, users can use browser settings. * *Details can be found in browser helpdesk (usually accessible via the F1 key on keyboard).
3. Cookies
To enhance the quality of Our services, We use technologies, such as Cookies. Cookies do not typically contain any information that personally identifies users, but personal information that We store about users may be linked to the information stored in and obtained from Cookies. We use Cookies to learn about users' traffic patterns and Website usage to help Us develop the design and layout of the Website in order to enhance users' experience browsing Our Website. We use the following types of cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of Our websites.
Through cookies, Personal data is being processed for the purposes as described in Section 4 ("Purposes") in the following way:
• Cookies are to be deleted when user closes the browser (session cookies). • Cookies remain stored on end user device even after the browser was closed (permanent cookies).
User can delete Cookies if wishes; while certain Cookies are necessary for viewing and navigating on Our Website, most of the features will be still accessible without Cookies. In order to restrict it to certain cookies, users can use browser settings. *
*Details can be found in browser helpdesk (usually accessible via the F1 key on keyboard).
4. Purpose
We collect, process and store only such Personal data that is necessary for the provision of the Services in strict accordance with applicable law. By giving consent of processing his/her Personal data listed above user confirms that We are allowed to process his/ her personal information for the following purposes:
• Identification of a party under agreements and contracts with kluz Ltd.. • Provision of Services and deliverance full-featured associated Content. • Compliance with legal obligations that We are subject to (e.g. obligations to keep certain information under tax laws).
• Fulfillment the contractual obligations of kluz Ltd. to the user.
• Communication with the user, including the sending of notifications, requests and information regarding the use of the Services, the provision of Services, as well as the processing of requests and applications from the user.
• Improving the quality of Services, ease of use, development of new Services. • Conducting statistical and other studies based on anonymized data.
5. Consent
The Personal data can be processed only after receiving clear "Consent" of Personal data procession from user.
This Policy applies only to the Website and Services and We do not control and are not responsible for third party websites to which the user can click on the links available on the Website. On such sites, the user may collect or request other personal information, and other actions may be performed.
The user's consent to the processing of personal data is valid indefinitely from the moment of acceptance of terms of this Policy in full.
6. Storage
If you are located in EU, you specifically and voluntarily consent to the transfer of your personal information to our servers in Seychelles for storage, collection and use of your personal data, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing us at: [email protected]
7. Personal data procession termination
Personal data procession shall end and the collected data itself shall be deleted immediately after it is no longer required by law or for executions of purposes described in Section 4. In determining the necessary Personal data retention period.
Your personal data will be deleted in 14 days after had been collected.
8. Personal data protection
When Personal data provided through Our Website, this information is transmitted across the internet securely using industry standard encryption. Personal data will be held encrypted on secure servers.
9. Third parties
We may also share users' Personal Data with our third party providers that provide customer support services in connection with goods, content and Services distributed via Websites. User's Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary for performing customer support services. We may also share certain information (including user's IP address and the identification details with our third party network providers that provide content delivery network services. Our content delivery network providers enable the delivery of digital content users have requested, e.g. when using Website, by using a system of distributed servers that deliver the content to users, based on users' geographic location.
We do not share user's Personal data with any third party except for the reason described above or unless this is required by the law.
10. Children
We neither provide Services, nor process Personal data of children. We will not knowingly collect Personal data from children under the age of 18 (eighteen) year old. Insofar as certain
countries apply a higher age of consent for the collection of Personal Data. We encourage parents to instruct their children to never give out personal information when online.
11. Users' rights
With respect to Personal data procession the users from EU have the following rights: • The "right to information" – user has the right to request kluz Ltd. for information about what Personal data (about him or her) is being processed and the rationale for such processing. For example, user may ask for the list of processors with whom his or her Personal data is shared.
• The "right to access" - user has the right to get access to his or her Personal data that is being processed. This request provides the right to see or view user's own Personal data, as well as to request copies of such data.
• The "right to withdraw Consent" - user has right to withdraw a previously given Consent for processing of his or her Personal data.
• The "right to be forgotten" – users have the right to ask kluz Ltd. for the deletion of their Personal data. Upon receiving such request, user's Personal data shall be deleted without undue delay (unless personal data is stored in accordance with the law). • The "right to rectify" – users have the right to rectify inaccurate Personal data without undue delay.
• The "right to object" – user has the right to object to the processing of his/her Personal data.
• The "right to object automated procession" - user has the right to object to a decision based on automated processing. Using this right, a user may ask for his or her request to be reviewed manually, because he or she believes that automated processing may not consider the unique situation of user.
• The "right for data portability" - user has the right to ask for transfer of his or her Personal data. As part of such request, user may ask for his or her Personal data to be provided back (to him or her) or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.
In case user wishes to exercise any of the aforementioned rights, he or she shall contact Us (contact details below).
12. Contact details
Users can contact Our data protection officer at the address below: kluz Ltd.
Address: Suite 1 Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles
13. CHANGES TO THIS PRIVACY POLICY
Any changes that We make to Our Privacy Policy in the future will be posted on Our app and Website.
Where appropriate, We will notify You of the changes when You next visit Our Website. This Privacy Policy was last updated on 30th September 2020.
For the purposes of the data protection laws that apply to us, including the GDPR, CLA, We act as the Data Controller for the Personal data that We collect and process to enable users to make use of Our Services.
The purpose of this Privacy Policy is to transparently provide users with an explanation as to the legal basis for collecting and processing users' Personal data, the categories of Personal data that may be collected, what happens to the personal data that We may collect, how long We are required to retain Personal data, who We may share Personal data with and to also explain users' rights as a data subject.
This Policy in the field of Personal data processing and confidentiality of personal information (hereinafter referred to as the "Policy") applies to https://kluz.io website (hereinafter referred to as the "Website") and is aimed to govern the information received (gathered) about the user while using the Website or any of the sites, services, services, programs and products of kluz Ltd. (hereinafter - the Services), as well as during the execution kluz Ltd. or its affiliates of any agreements and contracts concluded with the user in connection with the use of the Services.
1. Definitions and Personal data procession
"Privacy Policy" means this Privacy Policy updated from time to time and made public on Our Websites and through Our mobile applications.
"Personal data" in accordance with this Policy means any any information that can either itself identify "Data Subject" as an individual (hereinafter - "user" or "users") as well as the information that can be connected to user indirectly by linking it to.
"Personal data procession" or "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
kluz Ltd. stores and processes Personal data for as long as it is necessary to achieve the purpose for which it was collected.
"Third party" means a natural or legal person, public authority, agency or body other than the Data Subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorized to process personal data.
"Consent" of Personal data procession shall mean any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
"Cookie" means a small text file placed on User's computer or device by Our Website when user visits certain parts of Website.
"Automatic processing" includes the following operations if carried out in whole or in part by automated means: storage of data, carrying out of logical and/or arithmetical operations on those data, their alteration, erasure, retrieval or dissemination.
"Services" mean all Our products: Website, Applications.
2. Categories of Personal data being processed
A summary of the Personal Data that We process, when We collect it, how We use it and why We use it (i.e. the legal basis for processing) is listed below:
Directly Provided information: We may collect information you provide directly to us. For example, we collect information about you when you create an online account, complete a transaction, fill out a support form, respond to surveys, post messages to our forums or communicate with us in any other way. The types of information we may collect are as follows:
• Contact information, such as your name, mailing address, telephone number, and email address. Financial information, such as virtual currency account information.
• Government identification numbers, such as your social security number or a state-issued identification number.
• Biographic or demographic information, such as your date of birth, gender, occupation, employment status and any other information you choose to provide about yourself.
Transaction information: We collect information about the transaction performed by you via Kluz website or any third party affiliated or not affiliated with Kluz, including the amount of funds associated with a trade, wallet addresses, transaction identifiers, the types of trades executed and other transaction information.
Device and Log information: We collect information about the device you use to access the Company services, including device identifiers, type of operating system, and the type of browser used. We also log information about your use of the Company services, including access times, pages viewed and IP address.
Cookies: To enhance the quality of Our services, We use technologies, such as Cookies. Cookies do not typically contain any information that personally identifies users, but personal information that We store about users may be linked to the information stored in and obtained from Cookies.
We use Cookies to learn about users' traffic patterns and Website usage to help Us develop the design and layout of the Website in order to enhance users' experience browsing Our Website.
We use the following types of cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of Our websites.
Through cookies, Personal data is being processed for the purposes as described in Section 3 ("Purposes") in the following way:
• Cookies are to be deleted when user closes the browser (session cookies).
• Cookies remain stored on end user device even after the browser was closed (permanent cookies).
User can delete Cookies if wishes; while certain Cookies are necessary for viewing and navigating on Our Website, most of the features will be still accessible without Cookies. In order to restrict it to certain cookies, users can use browser settings. * *Details can be found in browser helpdesk (usually accessible via the F1 key on keyboard).
3. Cookies
To enhance the quality of Our services, We use technologies, such as Cookies. Cookies do not typically contain any information that personally identifies users, but personal information that We store about users may be linked to the information stored in and obtained from Cookies. We use Cookies to learn about users' traffic patterns and Website usage to help Us develop the design and layout of the Website in order to enhance users' experience browsing Our Website. We use the following types of cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of Our websites.
Through cookies, Personal data is being processed for the purposes as described in Section 4 ("Purposes") in the following way:
• Cookies are to be deleted when user closes the browser (session cookies). • Cookies remain stored on end user device even after the browser was closed (permanent cookies).
User can delete Cookies if wishes; while certain Cookies are necessary for viewing and navigating on Our Website, most of the features will be still accessible without Cookies. In order to restrict it to certain cookies, users can use browser settings. *
*Details can be found in browser helpdesk (usually accessible via the F1 key on keyboard).
4. Purpose
We collect, process and store only such Personal data that is necessary for the provision of the Services in strict accordance with applicable law. By giving consent of processing his/her Personal data listed above user confirms that We are allowed to process his/ her personal information for the following purposes:
• Identification of a party under agreements and contracts with kluz Ltd.. • Provision of Services and deliverance full-featured associated Content. • Compliance with legal obligations that We are subject to (e.g. obligations to keep certain information under tax laws).
• Fulfillment the contractual obligations of kluz Ltd. to the user.
• Communication with the user, including the sending of notifications, requests and information regarding the use of the Services, the provision of Services, as well as the processing of requests and applications from the user.
• Improving the quality of Services, ease of use, development of new Services. • Conducting statistical and other studies based on anonymized data.
5. Consent
The Personal data can be processed only after receiving clear "Consent" of Personal data procession from user.
This Policy applies only to the Website and Services and We do not control and are not responsible for third party websites to which the user can click on the links available on the Website. On such sites, the user may collect or request other personal information, and other actions may be performed.
The user's consent to the processing of personal data is valid indefinitely from the moment of acceptance of terms of this Policy in full.
6. Storage
If you are located in EU, you specifically and voluntarily consent to the transfer of your personal information to our servers in Seychelles for storage, collection and use of your personal data, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing us at: [email protected]
7. Personal data procession termination
Personal data procession shall end and the collected data itself shall be deleted immediately after it is no longer required by law or for executions of purposes described in Section 4. In determining the necessary Personal data retention period.
Your personal data will be deleted in 14 days after had been collected.
8. Personal data protection
When Personal data provided through Our Website, this information is transmitted across the internet securely using industry standard encryption. Personal data will be held encrypted on secure servers.
9. Third parties
We may also share users' Personal Data with our third party providers that provide customer support services in connection with goods, content and Services distributed via Websites. User's Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary for performing customer support services. We may also share certain information (including user's IP address and the identification details with our third party network providers that provide content delivery network services. Our content delivery network providers enable the delivery of digital content users have requested, e.g. when using Website, by using a system of distributed servers that deliver the content to users, based on users' geographic location.
We do not share user's Personal data with any third party except for the reason described above or unless this is required by the law.
10. Children
We neither provide Services, nor process Personal data of children. We will not knowingly collect Personal data from children under the age of 18 (eighteen) year old. Insofar as certain
countries apply a higher age of consent for the collection of Personal Data. We encourage parents to instruct their children to never give out personal information when online.
11. Users' rights
With respect to Personal data procession the users from EU have the following rights: • The "right to information" – user has the right to request kluz Ltd. for information about what Personal data (about him or her) is being processed and the rationale for such processing. For example, user may ask for the list of processors with whom his or her Personal data is shared.
• The "right to access" - user has the right to get access to his or her Personal data that is being processed. This request provides the right to see or view user's own Personal data, as well as to request copies of such data.
• The "right to withdraw Consent" - user has right to withdraw a previously given Consent for processing of his or her Personal data.
• The "right to be forgotten" – users have the right to ask kluz Ltd. for the deletion of their Personal data. Upon receiving such request, user's Personal data shall be deleted without undue delay (unless personal data is stored in accordance with the law). • The "right to rectify" – users have the right to rectify inaccurate Personal data without undue delay.
• The "right to object" – user has the right to object to the processing of his/her Personal data.
• The "right to object automated procession" - user has the right to object to a decision based on automated processing. Using this right, a user may ask for his or her request to be reviewed manually, because he or she believes that automated processing may not consider the unique situation of user.
• The "right for data portability" - user has the right to ask for transfer of his or her Personal data. As part of such request, user may ask for his or her Personal data to be provided back (to him or her) or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.
In case user wishes to exercise any of the aforementioned rights, he or she shall contact Us (contact details below).
12. Contact details
Users can contact Our data protection officer at the address below: kluz Ltd.
Address: Suite 1 Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles
13. CHANGES TO THIS PRIVACY POLICY
Any changes that We make to Our Privacy Policy in the future will be posted on Our app and Website.
Where appropriate, We will notify You of the changes when You next visit Our Website. This Privacy Policy was last updated on 30th September 2020.