Privacy policy

Introduction
PureBTC Limited (CN 2797345, RM 903, Dannies House HSE, 20 Luard RD, Wanchai, Hong Kong) (“PureBTC Limited” or “we” or “us” or “our”) owns and operates website and its subdomains (collectively referred to as “Website”).
We are a data controller and we respect your privacy and understand the importance of maintaining the confidentiality of your personal data and other information stored about you.
This Privacy Policy sets out key information regarding how we process your data and your rights regarding your data.
General provisions
This Privacy Policy applies to the processing of your personal data when you visit and use the Website or services offered by us and linked to this Privacy Policy. 
Personal data means information that identifies you personally such as your name, contact details or other data that can be linked with such information to identify you directly or indirectly.
This Privacy Policy covers our collecting and processing of any personal data you provide us directly as well as our business partners share with us.
By using the Website or by clicking to accept or agree to the Privacy Policy when this option is made available to you, you explicitly accept and agree to this Privacy Policy. If you do not agree to your data being used in the manner described in this Privacy Policy, please do not use our Website or services.
We may change this Privacy Policy from time to time and publish updated versions, together with notices of changes where appropriate. 
This Privacy Policy has been drafted in English and has been translated into other languages. In the event of any discrepancy between the English and the translated texts, the English text shall prevail and be used to solve doubts of interpretation.
Personal data we collect
We may collect and process personal data in respect of your use of and interactions with us and the Website to provide you with a service and to respond to you, including the following:
When you visit and use our Website
We may use various technologies to collect information which may include cookies and other similar technologies. The purpose of collecting cookies is to remember information about you, such as your use of the Website, your language preference or login information. 
For more details about cookies please read our Cookies Policy.
We automatically receive and record non-sensitive information about your device when you visit the Website, regardless of whether you have registered for an account or not by just browsing the Website. 
Depending on how you access and use our Website we may collect, including but not limited to, your technical and device information, cookies, the referring website and the page you requested. 
We may also collect information about your location and your online activity on the Website (usage data).
When you register an account
When you decide to use our services/Website by establishing an account, we may collect your First name, Last name, email address, and telephone number. 
In the future, when it is needed to verify your account, we may request additional information to verify your identity to be able to offer the services and protect the legitimate interests of us, site visitors and other users, in particular, by requesting identity documents, registration documents, documents confirming powers, public court documents, data from the company houses and registers of different jurisdictions, etc. (depending on the nature of the services).
When you contact us
We collect personal data from or about you when you communicate with us (for instance, by emailing us), request technical or customer support or otherwise communicate. The categories of personal data collected may include your name and email address, as well as any other relevant information contained in the body of your communication.
When you sign up for updates
The processing of personal data collected as a result of your subscription to our newsletter is based on your consent, which you can withdraw at any time by contacting us as prescribed in Contact us section below.
How we use data we collect and receive
As part of the processing there will not be any automated decision-making.
We may rely on different lawful bases when processing personal data, in particular: 
To fulfil contracts
If you enter into a contract with us (for example, creating an account as a part of services provision) we need to process personal data to fulfil the corresponding contract on the provision of the services.
Where we have a legal obligation
For instance, we may process personal data to protect, investigate, deter and report fraudulent, unauthorized or illegal activity as well as to process data in cases required by applicable legislation.
Where we have your consent
For instance, we may ask for your consent to send you marketing communications relating to services and other activities we run. If your personal data is processed on the basis of your consent, you can revoke it by contacting us as prescribed in Contact us section below.
Where we have a legitimate interest
We may process personal data where it is necessary for our legitimate interests, in particular, in the following situations:
account management and record-keeping and correspondence in relation to services you receive from us.
to respond to any enquiries, information requests or complaints you make to us or that are made about you.
to provide you with and maintain the quality of our Website, to analyse the use of our Website to help guide improvements as well as to improve our operations, Website and services.
to ensure the reliability and security of the Website, the protection of our Intellectual Property Rights and other rights.
fraud detection and checks, the tracking of Website traffic.
ensuring the functionality of the Website.
to send you marketing communications where we have a commercial relationship with you and you have not objected to receiving such communications from us.
to enforce Terms of Use and Service Terms (if applicable).
to assist with internal record keeping.
to assist in the prevention of or detection of a crime or equivalent malpractice.
to assist in the identification and prosecution of offenders.
We proportionate any possible impact on you and your rights before we start processing your personal data relying on our legitimate interests. We do not use your personal data in cases where our interests begin to prevail over the impact that they may have on you (except in cases where we have your consent, or when this is required or permitted by law or related to the fulfilment of the contract with you).
How we share information with others
We do not rent or sell your personal data to anyone.
We may share information with third parties in order to achieve the purposes set out in the Privacy Policy.
All third parties to whom we may provide personal data must protect this data under corresponding applicable laws and regulations and to the extent that we protect corresponding data.
We do not share your personal data with third parties that we believe are unable to provide their customers or potential customers with an appropriate level of data protection. 
All third parties to whom we may provide your personal data (e.g. providers who help us provide and improve the Services/Website we provide to you) receive the minimum amount of personal data that is reasonably necessary for them to provide services to us and, accordingly, to you. 
We may provide your personal data when required by law and/or regulatory authority requirements. 
We also may also reveal your personal data to third parties if you request or authorize it or to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
Please note that the level of protection of personal data in some countries may not coincide with the level established in your jurisdiction and by using our Website or our services you agree to such transfer. If you are located in a territory where your consent is required for the transfer of your personal data to another jurisdiction, then by using our Website or our services, you give us your explicit and unambiguous consent to such transfer or storage, and/or processing of information in other jurisdictions.
Security and storage of personal data
We define and implement the reasonable technical and organizational measures necessary to maintain the security of personal data, according to the nature of the personal data processed and the circumstances of the processing, to avoid non-authorised processing or access, alteration or loss of personal data.
By sending sensitive or confidential e-mail messages or information which are not encrypted, you accept the risk of such uncertainty and possible lack of confidentiality over the Internet.
We retain personal data for only as long as we need it to provide the services, to perform contractual obligations, for our own administration and internal business purposes, to achieve purposes described in this Privacy Policy and for any periods that are mandated by law, after which, we take steps to delete or anonymize information. 
Third parties or publicly available sources
We may also obtain information from other sources and combine that with information we collect through or in connection to our Website. For example, we may collect information about you from third parties, including but not limited to social media platforms and publicly available sources, in particular: KYC Data from publicly available sources such as public court documents, the company houses and registers of different jurisdictions as well as from electronic data searches, online KYC search tools, anti-fraud databases and other third party databases, sanctions lists, outsourced third-party KYC providers and general searches carried out via online search engines (e.g. Google, Yandex).
Third-Party Links
Our Website may include links to third-party websites, plug-ins and applications. 
Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.
We recommend you to read privacy statements of all third-party sites before using such sites or providing any personal data or any other information to or through these sites.
Your rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for your as data subjects.
As a rule, your rights include:

  • the right to be informed.
  • the right to correct (rectify) the record of your personal data maintained if it is inaccurate.
  • the right to access your personal data.
  • the right to withdraw consent.
  • the right to erasure. You may request that we erase that data or cease processing, subject to certain exceptions.
  • the right to file a complaint with the appropriate data protection authority if you have appropriate concerns.
  • the rights to object to processing where we are relying on a legitimate interest, subject to certain exceptions. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • the right to request the restriction of processing of your personal data, subject to certain exceptions.
  • the right to data portability. When technically feasible, we will—at your request—provide your personal data to you or transmit it directly to another controller, subject to certain exceptions.

Detailed information and advice about your specific rights can be obtained from the data protection regulator in your country.
You may exercise your rights by contacting us as provided in the Contact us section below. Please note that we may require to receive proof of your identity before we can respond to your request.
We may refuse, restrict or defer the provision of information where we have the right to do so under the applicable data protection legislation.
Changes and updates of our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our privacy practices, so we encourage you to review this Privacy Policy periodically. 
We reserve the right to amend Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on this site. 
We may email periodic reminders of our notices and may email you and other users. 
The provisions contained in the updated Privacy Policy supersede all previous notices or statements regarding our privacy practices and conditions that govern the use of this Website/Services. 
By continuing using our Website or services, you agree to the conditions contained in the updated Privacy Policy. 
Contact us
If you have any requests regarding your personal data or any questions regarding this Privacy Policy or if you would like more information about how we collect, use and store your personal data or you can contact us at any time.
Our details:
PureBTC Limited 
CN 2797345
RM 903, Dannies House HSE, 20 Luard RD, Wanchai, Hong Kong
Email: info@berfee.com

Last Updated and Effective Date – 01.06.2021