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Effective as of June 22, 2020 This Privacy Policy informs and explains to you how we collect, store, and process any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for your identification or identifiability (hereinafter the “Personal Data”) at Bitexox Protocol Systems OÜ (hereinafter – “Bitexox”, “we”, “our”). Privacy and data protection are core principles on which we have our website https://bitrexox.com and any of our AppStore or Google Play applications “Bitexox Wallet” (hereinafter the “Application”). We have implemented various technical and organizational measures to be compliant with applicable personal data, privacy, and data security legislation in the countries where we operate or where the applicable law applies to us. This Privacy Policy sets forth the basic rules and principles by which we process your Personal Data, and mentions our responsibilities while processing your Personal Data according to transparency obligations. We do not intend to collect personal data of children or persons under the age of 13 (thirteen) years old. Contact details and Questions Any questions about this Privacy Policy, the processing of Personal Data or data subject’s requests shall be directed to: Bitexox Protocol Systems OÜ (registry code 14519622) Address: Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111 Email:support@bitrexox.com
Principles Our Application is based on principles relating to the processing of the Personal Data and we commit to the following principles relating to the processing of the Personal Data: – we process your Personal Data lawfully, fairly and in a transparent manner by providing this Privacy Policy and showing legal bases for the processing of your Personal Data; – we collect the Personal Data for specified, explicit and legitimate purposes mentioned in this Privacy Policy; – we process Personal Data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed, especially we don’t require you to register or log in, we don’t have access to your funds (private keys), we don’t require your name or email address. – we collect accurate and, where necessary, kept up to date Personal Data when applicable and relevant; – we store your Personal Data for no longer than is necessary for the purposes for which the Personal Data are processed; – we use and ensure appropriate security of the Personal Data Registration/Login Not Required Bitexox does not require you to register or log in. Private Keys Stay on Device Your private keys will stay on your device. Categories of Collected Personal Data We collect the following categories of your Personal Data: – Your identification information necessary for your identification such as nickname and email. This information is necessary for your identification when you subscribe to our newsletters or leave a comment on the Application. – Device Information. We may collect information about the device you use to access our Application, including the hardware model, operating system and version, unique device identifiers, and mobile network information. This information will never be communicated to third parties unless you provide prior specific consent. – Analytical Information that includes information about how you use the Application. – Information you may provide to us. Your email address, virtual currency addresses, and any other information you choose to provide will never be communicated to third parties unless you provide prior specific consent. Processed Personal Data We process personal data when you interact with the Application or use our services, especially when: – you use our services; – you browse any page or section of the Application; – you communicate with us or leave a query; – you leave a comment on the Website; – you subscribe to our newsletters/updates; – you receive notification from us; – we need to share your personal data with the authorized third-parties to provide the services; and – we measure or analyze the Application’s traffic. Purposes and Legal bases for the Processing of Your Personal Data We process your Personal Data for the following purposes: – Providing services. We need to provide services via the Application. Legal basis: contract. – Performing transactions. Legal basis: contract. – Providing newsletters/offers/updates which may be interesting to you. Legal basis: consent for newsletters; legitimate interests for offers and updates. – Compliance with applicable regulatory rules. Legal basis: legal obligation. – Keeping the Application running (managing your requests, remembering your settings, hosting, and back-end infrastructure). Legal basis: legitimate interests. – Preventing frauds, illegal activity, or any violation of the terms or Privacy Policy. We may disable access to the Application, erase or correct personal data in some cases. Legal basis: legitimate interests. – Improving the Application (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Application, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your Personal Data and in some cases using third parties to do this). Legal basis: legitimate interests. – Customer support (notifying you of any changes to the Application, services, solving issues, any bug fixing). Legal basis: legitimate interests. Blockchain Transactions Your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. Secure Communication with our Servers, Confidentiality, and Security Measures We have security and organizational measures and procedures to secure the data collected and stored and to prevent it from being accidentally lost, used, altered, disclosed, or accessed without authorization. All of our servers support HTTPS. We allow disclosure of your personal data only to those employees and companies who have a business need to know such data. They will process the Personal Data on our instructions and they are obliged to do it confidentially under confidentiality agreements. You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for your login information and password. You shall keep them confidential. In case if your privacy has been breached, please contact us immediately. We have procedures in place to handle any potential data breach and we will inform a regulator of a breach if we are legally required to do so. Communication with Third-Party Servers Exchange rates, balances, transactions, and other blockchain information may be read from or related to third-party servers. We cannot guarantee the privacy of your Internet connection. Location of the Processing of Personal Data and Third-Party Services The Personal Data is collected and processed by the company incorporated in Estonia. The Application contains links to third-party sites. The Privacy Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them. There are the following third parties: – third parties providing exchanges services such as Changelly, ChangeNOW, and Simplex – email service providers to notify you and for direct marketing purposes such as Kickoff and SendGrid; – website analytics companies to analyze data and improve our services and the Application such as Yandex Metrics and Google Analytics; – platforms which we use for the support services such as Telegram; – social media companies to promote and be present in social media such as Twitter, YouTube, Telegram, GitHub, medium. Cookie Policy Our Cookies Policy is available here. Aggregate Usage Statistics We may collect Bitexox services usage information in order to improve function or UI, but will only use this information in an aggregated, anonymized fashion, and never in association with your name, email, or other personal data. Optional Extra Personal Data You may choose to provide us with the Personal Data in order to participate in certain programs, activate features, or obtain other benefits but you will always be able to use the basic features of Bitexox without providing personal data. If you provide us with the Personal Data then, notwithstanding any part of this Privacy Policy, we may use that information in order to provide you with services or to improve the functioning or UI of Bitexox. Your Rights as Data Subject You can exercise the following rights by contacting us. You have the right to access information about you, especially: – the categories of Personal Data; – the purposes of the processing of the Personal Data; – third parties to whom the Personal Data disclosed; – how long the Personal Data will be retained and the criteria used to determine that period; – other rights regarding the use of your Personal Data. You have the right to make us correct any inaccurate Personal Data about you. You can object to using your Personal Data for profiling you or making automated decisions about you. We may use your Personal Data to determine whether we should let you know the information that might be relevant to you. You have the right to the data portability of your Personal Data to another service or website. We will give you a copy of your Personal Data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the Personal Data to the other service for you. You have the right to be “forgotten”. You may ask to erase the Personal Data about you if it is no longer necessary for us to store the data for purposes of your use of the Application. You have the right to lodge a complaint regarding the use of your Personal Data. You can address a complaint to your national regulator (the list of the regulators are accessible via https://edpb.europa.eu/about-edpb/board/members_en). Once we receive any of your requests we will consider and decide on it within one month unless there is a justified requirement to provide such information faster. This term may be extended according to the applicable law. We may request specific information from you to confirm your identity when necessary and reasonable. This is a security measure to ensure that the Personal Data is not disclosed to any person who has no right to receive it. You do not need to pay a fee to access information or other rights but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances. Support Requests If you contact support then as part of the support request we may incidentally collect your personal data but we will endeavor to keep that information secure and confidential. Support information may be managed using a third-party service and further terms of that service may apply to your support request. Retention Policy We store the Personal Data as long as we need it and the retention practice depends on the type of data we collect, regulatory burden, and how we use the Personal Data. The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, tax and accounting laws, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. In some circumstances, we may anonymize your Personal Data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Changes to the Privacy Policy Bitexox reserves the right to change this Privacy Policy at any time. Any changes will be posted so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We will inform you about the changes when it is possible.
Disclaimer: Bitexox Wallet does not provide any virtual asset services or any financial services, nor does it provide any advisory, mediation, brokerage, or agent services. Virtual asset services are provided to Bitexox Wallet customers by third-party service providers, whose activities and services are beyond Bitexox’s control. We urge all Bitexox Wallet customers to familiarize themselves with the terms and conditions of third-party virtual asset service providers before engaging in a business relationship. We also note that Bitexox Wallet is not a creator and does not have any control over any of the virtual currencies that Bitexox Desktop and Mobile Wallet Applications allow Bitexox Wallet customers to use. Bitexox Wallet customers' balances and actual transaction history are supported by separate blockchain explorers of each cryptocurrency. Bitexox Wallet does not collect or store any private keys, backup phrases, or passwords. Furthermore, Bitexox Wallet does not hold, collect, or transfer any assets from or to its customers' wallets in any form. By downloading Bitexox Desktop and/or Mobile Light Wallet Applications and browsing the website, you acknowledge that: (1) any use of Bitexox is subject to these Terms of Service; (2) you have carefully read, understand and agree with these Terms of Service; (3) you are of legal age and you are able to form legally binding contracts. If you don’t agree with the Terms of Service (“Terms”), you can not use Bitexox. Bitexox reserves the right to modify these Terms at any time and at our sole discretion. In case of any changes, we will change the date of the last update at the beginning of these Terms. Please check this page regularly for updates. 1. Parties 1.1. This agreement is between you ( ‘You’ or ‘Your’) and Bitexox Protocol Systems OÜ (‘Bitexox Wallet’), registry code 14519622, Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111. Bitexox Wallet is a Blockchain Platform which consists of a set of desktop and mobile applications (‘Software’) and website https://bitexox.com/. All of the services provided by Bitexox Wallet we identify in this document as ‘Services’ 1.2. It’s your own responsibility to read the Terms of Service carefully before you start to use Bitexox. 2. Definitions and Services offered Bitexox is an innovative cryptocurrency infrastructure, which consists of: 2.1. Bitexox Desktop Light Wallet Applications Bitexox has created means for users to access and transfer ownership of virtual currency tokens (‘Cryptocurrency’), such as Bitcoins. By entering into this agreement You will receive a license to use any of the Bitexox Desktop and Mobile Light Wallet Applications. You should only use the Bitexox Desktop or Mobile Light Wallet Application if you are familiar with cryptocurrencies. We highly recommend learning the basics of the specific cryptocurrency that You plan on using the Bitexox Desktop or Mobile Light Wallet Application for, before running the application. 2.1.1. You Own Your Private Keys Bitexox does not store Your private keys, backup phrases or passwords (“Private Information”) on it’s servers. It is very important that You backup and save your Private Information. We urge you to write down your backup phrase and store it offline in two different places. If You lose Your Private Information, it will not be possible for Bitexox to recover it for You and You may lose access to Your Virtual Currencies. Bitexox Wallet don’t have access to your wallet, your funds, your transactions or any other information. If You do not understand the above paragraph then we strictly recommend that You learn more about Virtual Currencies before using the Bitexox Desktop and Mobile Light Wallet Applications. If you do not maintain a backup of your Bitexox Wallet data outside of the Services, you will not be able to access the Virtual Currency associated with your Wallet. 2.1.2. Transactions The only authentic record of Virtual Currency transactions is the applicable Virtual Currency’s blockchain. The Bitexox Desktop and Mobile Light Wallet Applications provide functionality that allows You to send Virtual Currency transfer instructions. Bitexox does not guarantee that Your transactions will be delivered, because Your transaction from Bitexox Desktop and Mobile Light Wallet Applications shall be added and stored in any Virtual Currency blockchain. You must ensure that Your transactions conform to the applicable rules of the Virtual Currency software. There may be transaction fees (e.g. mining fees) associated with Your Virtual Currency transactions that are required by the virtual currency system You engage with. Bitexox shall not be responsible for any losses You incur due to transaction fees or losses that occur due to incorrectly set transaction fees (i.e. too low or high). Bitexox does not have access to Your transactions (or anyone else’s). 2.1.3. No Control Over Blockchains Bitexox is not the creator of and does not have any control over any of the Virtual Currencies that the Bitexox Desktop and Mobile Light Wallet Applications allow You to use. Your balance and actual transaction history are supported by each cryptocurrency block explorers (ex. https://btgexplorer.com/, https://etherscan.io/ and etc.). All cryptocurrency rates available in the application are supported by https://coinmarketcap.com/ and https://www.cryptocompare.com/. 2.1.4. Third Party Integrations The Bitexox Desktop and Mobile Light Wallet Applications contain libraries developed by third parties. Bitexox may provide third-party libraries to You as part of the Bitexox Desktop and Mobile Light Wallet Applications solution but shall not be considered to be the owner or licensor of the third-party libraries. Third-party services are used for in-wallet Virtual Currencies exchange operations and in-wallet buying Virtual Currencies operations. Bitexox Wallet retains the exclusive right to add to, modify, or cancel the availability of any Third Party Service. 2.2. In-wallet exchange operations. By using the exchange within the wallet (‘Bitexox Exchange’), You agree with the Terms of Use of the respective third-party partner. Please refer to and respect the relevant third party licenses: Built-in Bitexox Exchange is provided by ChangeNOW, not by Bitexox Wallet itself. The original Terms of Use are available at https://changenow.io/terms-of-use Although the Bitexox Desktop and Mobile Light Wallet Applications make it easy to engage with the integrated third parties, Bitexox shall not be responsible for any consequences stemming from Your use of third-party integrated services. If You need assistance with a third-party integration then You should contact the third-party along with contacting our support. The estimated amount which is presented to You in the Wallet prior making an exchange is not final. It can differ from the final amount due to market fluctuations. 2.2.1. By using the service within the wallet for buying cryptocurrencies (‘Bitexox Buying Crypto Service’), You agree with the Terms of Use of our third-party partner Simplex, who are provided Bitexox Buying Crypto Service. The rules described in the Terms of Use of our partner Simplex apply to You in full. Please refer to and respect the relevant Simplex Terms of Use available here https://www.simplex.com/terms-of-use/. Simplex payment processing is subject to local bank policies. Issuer banks may decline the payment on their own terms. For more information please consult Simplex FAQ available here https://www.simplex.com/kbtopic/faq/. 2.3. Loyalty Program. Bitexox is the sole owner and creator of Loyalty Program, which now consists of Airdrop program (‘Bitexox Airdrop’) and Cashback Membership Program (“Bitexox Membership”) 2.3.1. Bitexox Airdrop. By participating in Bitexox Airdrop you acknowledge that you have read, agreed and followed Bitexox Airdrop rules https://bitexox.com/airdrop. If You break the rules and/or perform any prohibited actions, such as: registering multiple emails for the airdrop; using paid traffic for attracting referrals; any faking, including faking original Bitexox Airdrop; any other types of spamming and scamming; You will be eliminated from the Airdrop program with no right to register again. Bitexox Wallet reserves the right to eliminate You from the Airdrop program or/and refuse reward payment at any given time and for any reason without further explanations. Bitexox Wallet reserves the right to change the Airdrop rules at any time and in our sole discretion. 2.3.2. Bitexox Membership. By participating in Bitexox Membership you acknowledge that you have read, agreed and followed Bitexox Membership rules https://bitexox.com/cashback-program. Bitexox Wallet reserves the right to eliminate You from Bitexox Membership and/or refuse in cashback payment at any given time and for any reason without further explanations. Bitexox Wallet reserves the right to change the Bitexox Membership rules at any time and in our sole discretion. 3. Your Obligations You shall: be of the age of majority in Your local jurisdiction; and, be responsible for Your own Virtual Currency; and, backup/write down Your Private Key and Backup Phrase and keep it private; and, carefully guard Your Private Keys and Backup Phrase in case of usage Bitexox Desktop and Mobile Light Wallet Applications and, ensure that Your device(s) are fully updated and do not contain viruses, malware or otherwise malicious software. You shall not: violate any laws when using Bitexox Desktop and Mobile Light Wallet Applications; or, circumvent or attempt to circumvent the security measures Bitexox Wallet are using to protect other accounts, computer systems, or networks connected to the Bitexox Desktop and Mobile Light Wallet Applications; or, deposit Virtual Currency into addresses for tokens and/or coins that are not supported by the Bitexox Desktop and Mobile Light Wallet Applications; or, use Bitexox in a manner likely to infer with other Bitexox users or virtual currency nodes (e.g. excessive API calls or network spam); 4. Limited Intellectual Property License This agreement licenses Bitexox services to You on a personal, non-exclusive, royalty-free, non-transferable, worldwide-basis, for the purpose of managing virtual currencies. You are not permitted to redistribute any of Bitexox Services, modify any code or use any Bitexox content, including images and text, as part of any other software or project of any kind. 5. Specifically Disclaimed Risks Using Virtual Currency software necessarily entails many risks. Bitexox specifically disclaims and shall have no liability to You for the following risks: operating system failures (mobile or desktop); and, interactions between Your hardware, software, and the Bitexox; and, cloud backup software (e.g. certain Android distributions) may upload your private information to third party services; and, malware, viruses or other malicious software on Your device that is able to take control of or interfere with Bitexox; and, communication delays between Your Bitexox Desktop and Mobile Light Wallet Application and a node or relay service for a virtual currency (and vice versa); and, failure to achieve a certain market value/price for a virtual currency token, whether through a third-party service or any other kind of transaction; and, theft of virtual currency tokens. 6. No Warranty Bitexox is provided to You at no cost, “as-is ” and without any warranty whatsoever, to the maximum extent permissible by law. Without limiting the generality of the foregoing, Bitexox does not warrant that Bitexox is fit for Your purpose, even if You have previously provided notice of Your intended purpose, and does not warrant that Bitexox will operate in a bug-free manner. 7. Limitation of Liability IN NO EVENT WILL BITEXOX WALLET BE LIABLE TO YOU FOR: ANY LOST PROFITS, REVENUE OR DATA, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, OR DAMAGES OR COSTS DUE TO LOSS OF PRODUCTION OR USE, BUSINESS INTERRUPTION, OR PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES ARISING OUT OF OR IN CONNECTION WITH THE SERVICES, WHETHER OR NOT BITEXOX WALLET HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND REGARDLESS OF THE THEORY OF LIABILITY ASSERTED, WHICH HAVE RESULTED FROM: (I) YOUR USE OF, OR CONDUCT IN CONNECTION WITH, OUR SERVICES; (II) ANY UNAUTHORIZED USE OF YOUR WALLET ADDRESS AND/OR PRIVATE KEY DUE TO YOUR FAILURE TO MAINTAIN THE CONFIDENTIALITY OF YOUR WALLET; (III) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE SERVICES; OR (IV) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT ARE FOUND IN THE BITEXOX WALLET SOFTWARE OR THAT MAY BE TRANSMITTED TO OR THROUGH OUR SERVICES BY ANY THIRD PARTY (REGARDLESS OF THE SOURCE OF ORIGINATION). 8. Cap on Liability. UNDER NO CIRCUMSTANCES WILL BITEXOX WALLET BE LIABLE TO YOU FOR DAMAGES ARISING OUT OF THE SERVICES EXCEEDING $50. 9. Indemnity You agree to indemnify Bitexox against any claims, damages, losses or legal fees incurred due to Your use (or misuse) of Bitexox. 10. Non-Waiver No action or inaction on the part of Bitexox shall be considered a waiver of any right or obligation by Bitexox. 11. Amendment This agreement may be amended by Bitexox by providing You with 30 days’ notice of any proposed change. If You do not agree to the amended terms then Your sole remedy shall be to cease using Services of the website. 12. Assignment You may not assign this agreement. Bitexox may assign this agreement to 11 days’ notice. 13. Discontinuance of Services. We may, in our sole discretion and without cost to you, with or without prior notice, and at any time, modify or discontinue, temporarily or permanently, any portion of our Services. You are responsible for storing outside of the Software Your 12-word backup phrase. Saving your backup phrase and private keys pairs associated with your Bitexox Wallet will allow you to access the blockchain and your funds at any place and time. This backup will allow You to fully restore Your Bitexox Wallet at any time without cost or loss of the Virtual Currency. Bitexox Wallet shall not be held responsible or liable for any loss of Virtual Currency in the event that we discontinue or deprecate the Services. 13. Entire Agreement This is the entire agreement between the parties and supersedes any other agreement, representations (or misrepresentations), or understanding, however, communicated.