This document explains how we use your personal information.
coinspot.nl is a trade name of Finixio LTD. Finixio LTD is responsible for all personal data collected through this website.
We are committed to protecting the privacy of our customers and other website visitors. In this policy we explain how we hold, process and store your personal data.
- How we use your personal information
1.1 In this section you will find information about:
(a) what personal data we hold and process;
(b) in relation to personal data that we have not collected directly from you, where we got that data from and what types of data we have collected;
(c) the purposes for which we may process your personal data; and
(d) the legal grounds on which we process your data.
We do not pass on your data to third parties without your express permission.
1.2 Contact details / Application details.
We may use the contact details you provide to us ("contact details") processing. This contact information may include your name, address, telephone number and email address and may be provided through our website. We may use this contact information to manage your account with us and to contact you to discuss your use of our website, and how our website and content performed and functioned for you. We may also use this information to: (a) respond to questions you ask through our website or our live web support platform, LiveChat!; (b) provide you with a copy of or updates to our eBook.
The legal basis for this processing is our legitimate interest in answering your questions and ensuring the efficient administration and continuous operation of our website.
We may also use this information to provide you with information related to the services under our affiliate program. In the course of this process, we may provide your contact information to our third party affiliate tracking program provider, iDevAffiliate, Inc. Your contact details may be processed in this way for the purpose of performing our affiliate contract with you, or to take steps at your request prior to entering into a contract.
1.3 Profile data.
As part of our service to you, you may provide us with biographical information about yourself (“profile data”† This profile information may include your contact information, social media presence information, biographical information you upload, and a profile picture.
We may use this information to provide you services from our website and to monitor and manage your account with us. If you are a standard account holder, the legal basis for our processing is a legitimate interest.
If you are a PRO account holder or apply for a PRO account, your profile data may be processed in this way for the purpose of performing our contract with you, to provide services through our website or to take steps at your request before you enter into a contract.
Where you have given us permission to do so, we may also do the following: (a) disclose your profile picture and biographical information; and (b) use this information to carry out marketing activities, in particular to tailor the offers, advertisements and promotions that we bring to your attention, both when we contact you and through our website.
By signing up to our mailing list, you will receive emails that may contain company news, updates, related product or service information. If you would like to unsubscribe from receiving future emails at any time, you will find detailed unsubscribe instructions at the bottom of each email.
1.4 Sensitive Personal Information.
While using our services, you may give us sensitive information about yourself (“sensitive data”† However, we will only process this sensitive data if you give us permission to do so.
1.5 Transaction Data.
We may process information relating to payments made to you through our website (“transaction data”† The transaction details may include your contact details, your bank account details and the transaction details. The transaction data can be processed for the purpose of processing these payments and keeping correct records of these transactions.
The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and our company.
1.6 Website Data.
We may process data about your use of our website and services (“website data”† The Website Data may include your IP address, geographic location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Services. The source of the website data is our analytical tracking system. This website data may be processed for the analysis of the use of the website and the services.
The legal basis for this processing is our legitimate interests, which are to monitor and improve our website and services.
1.7 Notification Data.
We may process the information you provide to us in order to subscribe to our newsletters (“login information”). The notification data may be processed for the purpose of sending your newsletters.
The legal basis for this processing is consent.
1.8 Correspondence Details.
We may collect information in or in relation to communications you send us (“correspondence data”) processing. The correspondence data may include the communication content and metadata associated with the communication. Our website generates the metadata related to the communication via the contact forms on the website. The correspondence data may be processed for the purpose of communicating with you and keeping records.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and its business operations and communication with users.
1.9 Other Processing Activities.
In addition to the specific purposes for which we may process your personal data, as described above, we may also process your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another protect natural person.
2. Providing your personal information to others
2.1 Our partner service providers.
We may share your information with our partners who operate and support the technology we offer through our website (such as WordPress and Hubspot). We may also share your information with other companies within our group of companies, the Finixio Group.
We may use third party service providers to assist us in operating our business and website or to administer activities on our behalf, such as sending newsletters or conducting surveys. We may share your information with these third parties for these limited purposes, provided you have given us permission to do so.
2.2 Our Professional Advisers.
We may provide your personal data to our professional advisers to the extent reasonably necessary for managing risk, obtaining professional advice and managing legal disputes.
2.3 When we provide your personal data to a third party.
Where we share your personal data with a third party, we will ensure that such processing is protected by appropriate safeguards, including an appropriate data processing agreement with that third party.
2.4 To comply with legal obligations.
In addition to the specific disclosure of personal information as described above, we may also disclose your personal information where it is necessary to comply with a legal obligation to which we are required to comply, or to protect your vital interests or the vital interests of another individual.
3. Transfer of your personal data outside the European Economic Area
When your personal data is transferred outside the EEA, we will ensure that (a) the European Commission has made an “appropriate decision” regarding the data protection law of the country to which the data is transferred, or (b) we have concluded an appropriate data processing agreement with the third party in that country to ensure the appropriate protection of your data. In all cases, the transfer outside the EEA will be protected by appropriate safeguards.
4. Storage and deletion of personal data
4.1 Personal data that we process for any purpose or purposes will not be kept for longer than is necessary for that purpose or those purposes.
4.2 Unless we contact you and obtain your consent to keep your personal data for longer, we will keep and delete your personal data as follows:
(a) The contact details will be kept for 3 years from the date of our last contact or treatment, at the end of which time they will be deleted from our systems.
(b) Profile data is retained for 2 years from the date of our last contact or treatment, at the end of which time it will be deleted from our systems.
(c) Sensitive data will be kept for 2 years from the date of our last contact or treatment, at the end of which time it will be deleted from our systems.
(d) Website data will be retained for 2 years from the date of our last contact or transaction with you, at the end of which time it will be deleted from our systems.
(e) Application data will be kept for 2 years from the date of our last contact or treatment, at the end of which time it will be deleted from our systems.
(f) Notice Data will be retained for 2 years from the date of our last contact or treatment, at the end of which time it will be deleted from our systems.
(g) Correspondence data will be kept for 2 years from the date of our last contact or treatment, at the end of which time it will be deleted from our systems.
4.3 We may retain your personal data where this is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
5.1 We may update this Policy from time to time by posting a new version on our website.
5.2 You should check this page from time to time to ensure that you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.
6. Your rights
6.1 You may instruct us to provide you with any personal information we hold about you; the provision of such information is subject to the rules:
(a) your request is not found to be unfounded or excessive, in which case a fee may be charged; and
(b) the supply of appropriate proof of your identity (for this purpose we will normally accept a lawyer or bank certified photocopy of your passport plus an original copy of a utility bill showing your current address).
6.2 We may withhold the personal information you request to the extent permitted by law.
6.3 The rights you have under the data protection law are:
(a) the right of access;
(b) the right to correction;
(c) right to erasure;
(d) the right to restrict processing;
(e) the right to object to the processing;
(f) the right to data portability;
(g) the right to lodge a complaint with a supervisory authority; and
(h) the right to withdraw consent.
6.4 Your right to access your data.
You have the right to ask us to confirm whether or not we are processing your personal data and to access the personal data and any additional information. This additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You can request a copy of your personal information. The first copy is provided free of charge, but we may charge a reasonable fee for additional copies.
6.5 Your right to correction
If we have incorrect personal data, you have the right to have these inaccuracies corrected. If this is necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
6.6 Your Right to Erasure.
In certain circumstances, you have the right to have your personal data that we hold about you erased. This is done without undue delay. These circumstances include the following: it is no longer necessary for us to retain that personal data in connection with the purposes for which it was originally collected or otherwise processed; you withdraw your consent for any processing that requires consent; the processing is for direct marketing purposes; and the personal data has been unlawfully processed.
However, there are certain general exclusions from the right to erasure, including where the processing is necessary: for the exercise of the right to freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
6.7 Your right to restrict processing.
In certain circumstances you have the right to restrict the processing of your personal data. This is the case when: you believe that the personal data we hold about you is incorrect; your data is unlawfully processed, but you do not want your data to be erased; it is no longer necessary for us to keep your personal data for our processing, but you do require that this personal data be processed in connection with a legal claim; and you objected to the processing and wait for that objection to be verified. Where processing is restricted for any of these reasons, we may continue to store your personal data.
However, we will only process it for other reasons: with your consent; in connection with a legal claim; to protect the rights of another natural or legal person; or for reasons of overriding public interest.
6.8 Your right to object to the processing.
You can object to the processing of your personal data by us on the basis of your particular situation, but only to the extent that our legal basis for the processing is necessary for: the performance of a task carried out in the public interest, or in the exercise of from any official authority assigned to us; or the purposes of our legitimate interests or those of any third party. If you object, we will stop processing your personal data unless we are able to: demonstrate compelling legitimate grounds for the processing, and those legitimate reasons outweigh your interests, rights and freedoms; whether the processing relates to a legal claim.
6.9 Your right to object to direct marketing.
You can instruct us at any time not to process your personal data for marketing purposes.
In practice, you will usually expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with the option to opt-out of using your personal information for marketing purposes.
You can object to the processing of your personal data for direct marketing purposes. If you object, we will stop processing your personal data for this purpose.
6.10 Your right to object for statistical purposes.
You can object to the processing of your personal data for statistical purposes based on your particular situation, unless the processing is necessary for the performance of a task carried out in the public interest.
6.11 Automated Data Processing.
To the extent that the legal basis for the processing of your personal data is consent, and to the extent that the processing is automated, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if doing so would adversely affect the rights and freedoms of others.
6.12 Submitting complaints to a supervisory authority.
If you believe that our processing of your personal data infringes data protection law, you can lodge a complaint with a supervisory authority responsible for data protection. You can do this in the EU Member State of your habitual residence, the place where you work or the place of the alleged infringement.
6.13 Right to Withdraw Consent.
To the extent that the legal basis on which we rely for the processing of your personal data is consent, you have the right to withdraw such consent at any time. Withdrawal does not affect the lawfulness of the processing before the withdrawal.
6.14 Exercising your rights.
You can exercise any of your rights in relation to your personal data by notifying us in writing, in addition to the other methods listed above.
7.2 For more information about cookies and how to disable them, please refer to the Interactive Advertising Bureau's information at www.allaboutcookies.org.
8. Our details
8.1 This website is owned and operated by Finixio LTD.
8.2 We are registered in England and have our registered office at
ST. Magnus House, 3 Lower Thames ST, London, EC3R 6HA
8.3 You can contact us:
(a) by post, using the above postal address;
(b) via the contact form on our website;
(c) by telephone, at the contact number published from time to time on our website; or
(d) by email, using the email address published on our website from time to time.
9. Privacy Officer
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK data protection regulator.