Last updated: 19 October 2022
Thank you for using Bitkit (the " App "). The App is made available by Synonym Software Ltd., registered in the British Virgin Islands under company number 2056692 and having its registered office at Trinity Chambers, PO Box 4301, Road Town, Tortola VG1110, British Virgin Islands, (" Synonym ", " we ", " our ", or " us ").
Synonym acts as data controller for your Personal Information and has appointed Rickert Rechtsanwaltsgesellschaft mbH, whose registered office is Colmantstraße 15, 53115, Bonn, Germany, as its EU/UK representative.
1. Our Processing of Your Personal information.
Please note that when you download the App via a third-party platform (e.g., via the Apple App Store or the Google Play Store), certain information required for the download (such as your username, e-mail address, user account number, time of download, and individual device identification number) may be transferred to the platform together with additional information which the platform may collect. We have no influence on and are in no way responsible for any data collection or processing activities carried out by such third-party platforms.
1.1. Information we learn from you when you use the App.
To establish and maintain our relationship with you and to support your use of the App, we may learn from you certain information about yourself. This information is either required by law, necessary for us to be able to enable you to use certain features of the App (e.g., if you utilise the ‘Pay to contacts’ feature, we may learn your Bitcoin wallet address), or is relevant for certain specified purposes, described in greater detail below. As we add new features and services, you may be asked to provide, or we may learn, additional information.
We may collect the following types of information from you:
1.2. Information we collect about you automatically.
To the extent permitted under applicable law, we may also obtain Personal Information automatically, such as whenever you interact with the App and use our services. This information helps us, for example, to address customer support issues, improve the performance of the App, provide you with a streamlined and personalized experience, and restrict access by persons prohibited from utilizing the App. Personal Information collected automatically includes:
1.3. Information we receive about you from other sources.
From time to time, we may obtain information about you from our affiliates or third-party sources as required or permitted by applicable law through your use of the App and/or your use of third-party services, such as other wallet providers or node operators, and/or through publicly available sources. These sources may include:
2. Aggregated Data.
3. How your Personal Information is used.
Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience. We generally use Personal Information to create, develop, operate, deliver, and improve the App. This being said, we may use your Personal Information in the following ways:
3.1 Compliance with legal and regulatory obligations
Certain of our core services may be subject to laws and regulations requiring us to collect, use, and store your Personal Information in certain ways. This includes legal obligations imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g., financial services laws, corporation laws, privacy laws and tax laws. There are also various supervisory authorities whose laws and regulations apply to us.
These obligations may apply at various times, including client registration, wallet transaction, and systemic checks for risk management.
3.2 To ensure network and information security
We process your Personal Information to enhance security, monitor and verify identity or service access, combat malware or security risks and to comply with applicable security laws and regulations.
3.4 To enable us providing the App to you
We process your Personal Information to allow you to use the App and its features, for example, by seeding or hosting redundant data that you control within the App.
We also process your Personal Information when you contact us to resolve any questions, disputes or to troubleshoot problems. Without processing your Personal Information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of our services and/or the App. If and to the extent necessary, we send administrative or wallet-related information to you to keep you updated about our services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your wallet and/or the App that may affect how you can use the App. You may not opt-out of receiving critical service communications, sent for legal or security purposes.
3.5 To ensure quality control
We process your Personal Information for quality control and staff training to make sure we continue to provide you with accurate service and information. If we do not process Personal Information for quality control purposes, you may experience issues on the App and services such as inaccurate transaction records or other interruptions.
3.6 For the purpose of safeguarding legitimate interests
We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. It is, for example, in the interest of our organization to conduct and manage our business; this includes protecting our interests and enforcing agreements with others, as well as comply with industry best practices. We might have legitimate interest to process Personal Information in other contexts. We ensure that we balance any potential impact on you and your rights before we process your Personal Information on that basis. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Please also consult the section "Your rights" below.
We process your Personal Information in this context
3.7 For any purpose that you provide your consent.
We will not use your Personal Information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under applicable law, we may request your permission to allow us to share your Personal Information with third parties. In such instances, you may opt out of having your Personal Information shared with third parties, or allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your Personal Information, certain features or the App may not be available to you.
4 Legal Basis for processing your Personal Information
For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively " EEA Residents ") at the time their Personal Information is collected, our legal bases for processing your information under the EU General Data Protection Regulation (" GDPR ") will depend on the Personal Information at issue, the specific context in the which the Personal Information is collected and the purposes for which it is used.
Section & Purpose of Processing
Legal Bases for Processing
Section3.1 – Compliance with a legal and regulatory obligations
Section3.2 – To ensure information security
Based on our legal obligations, or the public interest.
Section3.4 – To provide the App and allow you to use its features
Section3.5 – To ensure quality control ( to the extent strictly necessary to provide the App )
Based on our contract with you or to take steps at your request prior to entering into a contract
Section3.6 – For the purpose of safeguarding legitimate interests
Based on our legitimate interests (as balanced, as described under Section3.6)
Section3.6.2 – Personalization (to the extent that we asked for your consent)
Section3.7 – For any purpose that you provide your consent
Based on your consent
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the "How to contact us" heading below.
5 Security and confidentiality of your Personal Information.
We are committed to protecting your privacy. The App's systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Information you entrust to us, as well as procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
For example, we use computer safeguards such as firewalls and data encryption and we authorize access to Personal Information only for those contractors or employees who require it to fulfill their job responsibilities.
Unfortunately, the transmission of information via digital networks such as the Bitcoin blockchain, Lightning Network, and Hyperswarm network is never completely secure. While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us through the App; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access.
We take care to allow your Personal Information to be accessed only by those who require access to perform their tasks and duties, and to share your Personal Information only with third parties who have a legitimate purpose for accessing it. We will never sell or rent your Personal Information to third parties without your explicit consent. As necessary, we will share your Personal Information with:
7 International Transfers.
Your Personal Information may be processed and stored in a foreign country or countries and the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
8 Data Retention
We have data retention and deletion policies designed to retain Personal Information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business needs. Because of those retention requirements, we might not be able to honor erasure requests.
If we no longer process your Personal Information for the described purposes, we will remove it from our systems and records or make it completely anonymous so that you can no longer be identified from it. Your data will not be erased or made completely anonymous if and as long as we have to store your data in order to fulfil legal or regulatory obligations, e.g., legal retention requirements, which may arise from applicable national legislation.
9 Your Rights
9.1 General provisions
Depending on applicable law where you reside, you may be able to assert certain rights related to your Personal Information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Synonym has absolute discretion in providing you with those rights.
Your rights to Personal Information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
9.2 Special provisions for EEA Residents
If you are an EEA resident you have a number of rights in relation to how we process your Personal Information:
10 Third-Party records
Please be aware that your transactions may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks which are not controlled or operated by Synonym, we are not able to erase, modify, or alter Personal Information from such networks.
If you are an EEA Resident and you have any concerns about how we handle your Personal Information, please contact us in the first instance by email at email@example.com. You can also contact our EU/UK representative [ insert email address ]. We will do our best to resolve your concern. You can also submit a complaint to the national supervisory authority within your jurisdiction, details of which can be found here.