Privacy Policy

Privacy Policy

 

Last updated on December 7, 2023.

 

This Privacy Policy applies when you use DHCOINX https://dhcoinx.com/ (“DHCOINX”, “Website”, “Us”, “We”, or “Our”), contact DHCOINX, engage with DHCOINX on social media, or otherwise interact with DHCOINX.

The data controller of personal data collected on this Website is D&H MEDIA SERVICES SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (hereinafter: “Data Controller”), established and operating in accordance with the laws of the Republic of Poland, with its registration number KRS: 0001055088, NIP: 7011162135; having its seat at Street HOŻA, No. 86, Apt. 210, municipality Warsaw, Poland, 00-682. The company is entered in the Polish Register of Virtual Asset Service Providers under position RDWW-990, date of entry: 23.10.2023.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy outlines how we collect, use, and protect your Personal Data. By using our services and accepting this policy, you consent to us collecting and using your information as described below.

By using this Website, DHCOINX assumes that you agree to the collection and use of information in accordance with this Privacy Policy and agree to provide us an explicit consent to terms and the data practices described in this Privacy Policy including the processing, storage, and usage of your Personal Data.

 

1. Definitions and Interpretation

1.1. In this Privacy Policy, the following terms shall have the following meanings:

"Client," "Client," or "User" means a natural or legal person or another type of entity that registers for the Service or uses the Service as a Client, i.e. you.

"Personal data" is any information about an identified or identifiable natural person.

"Processing" means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.

"Data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data.

"Data processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

"GDPR" – means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

"Website" means https://dhcoinx.com/

"Sensitive personal data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or a natural person's sex life or sexual orientation.

"Consent" means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by an explicit affirmative action, signify agreement to the processing of personal data relating to them.

"Data subject" means the individual to whom the personal data relates.

"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.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict factors concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

 

2. Data Categories

2.1. We collect and process the following categories of Personal Data:

  • Client information: first name, date of birth, maiden name (where applicable), last name, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card, and/or passport;
  • Contact data:  billing address, email address, and contact number (telephone, mobile);
  • Financial information: client’s bank account and payment details, income source, tax residency;
  • AML/KYC Data: due diligence, KYC information and documentation about client: copy of ID card or passport, proof of residence (e.g. utility bill), KYC database checks, fraud database checks and any documentation or information which DHCOINX may, from time to time be required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and AML/KYC practices; and/or otherwise be mandated to collect by the competent authority or law enforcement agency (local or overseas) or implementing market’s best practices;
  • Transaction Data: the type of virtual currency involved, the order volume, price, value and, where applicable, the proceeds derived; client’s trading and transactional history on the Website, including withdrawals and order activity; and the payments which DHCOINX receives, or otherwise, charges client; details about the virtual currency and amounts credited to client’s account balances;
  • Cookies (functional): IP address, frequency of access;
  • Device Data: information about the computer or mobile device client uses to access DHCOINX services, including the hardware model, operating system and version, unique device identifiers, and mobile network information;
  • Marketing Data: client’s preferences in receiving marketing from DHCOINX and DHCOINX’s third parties and client’s communication preferences.

3. Legal basis and purpose of processing of Personal Data

3.1. These are the purposes for collection and processing of Personal Data:

  • Fulfillment of DHCOINX contractual obligations and legal obligations (obligations under Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU; Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC;
  • Provision of the information about your activities within the account;
  • Provision of services, including execution of requested transactions and related maintenance of the services you registered for and manage the account you hold;
  • Supporting and administering relations with clients, prevent disputes, and collect evidence (recording phone conversations), correspondence of business relations with the client;
  • Information about any changes and updates to the services you are provided with comply with applicable legislation;
  • Maintenance of actions in relation to legal claims;
  • Assessment and mitigation of risks related to anti-money laundering and terrorism financing regulations as well as transaction related risks;
  • Informing clients about our services;
  • Provision of additional or supportive services, as well as performance of client surveys and statistical analysis;
  • Improvement of the performance of our service;
  • Performance of direct marketing activities.

3.2. The above list may be extended depending on the development of the offered services.

 

4. Exercise of rights

4.1. You have the following rights under GDPR:

4.1.1. Right to withdraw consent: Data subjects have the right to withdraw previously given consent to process their personal data (GDPR Article 7).

4.1.2. Right to be informed: Data subjects have the right to be informed about the collection and use of their personal data (GDPR Articles 12 to 14).

4.1.3. Right to access: Data subjects have the right to view and request copies of their personal data (GDPR Article 15).

4.1.4. Right to rectification: Data subjects have the right to request inaccurate or outdated personal information be updated or corrected (GDPR Article 16).

4.1.5. Right to be forgotten/Right to erasure: Data subjects have the right to request their personal data be deleted. Note that this is not an absolute right and may be subject to exemptions based on certain laws (GDPR Article 17).

4.1.6. Right to restrict processing: Data subjects have the right to request the restriction or suppression of their personal data (Article 18).

4.1.7. Right to data portability: Data subjects have the right to ask for their data to be transferred to another controller or provided to them. The data must be provided in a machine-readable electronic format (GDPR Article 20).

4.1.8. Right to object: Data subjects have the right to object to the processing of their personal data (GDPR Article 21).

4.1.9. Right to object to automated processing: Data subjects have the right to object to decisions being made with their data solely based on automated decision making or profiling (GDPR Article 22).

 

5. Data disclosure

5.1. Any Personal data shall be disclosed only as described and for purposes stated in this Privacy Policy, and/or as permitted or required by law. Personal data may be disclosed to our subsidiaries, affiliated companies and subcontractors, our trusted third party providers and also to members of management bodies, employees, representatives, authorized persons of DHCOINX for any of the following purposes.

  • hosting and operating our Website;
  • providing you with our services (including providing a personalized display of our Website);
  • storing and processing such information on our behalf;
  • for marketing purposes according to this Privacy Policy;
  • performing research, technical diagnostics or analytics;

5.2. Personal data can also be disclosed, if we believe that disclosure of such information is helpful or reasonably necessary for: compliance with any applicable law, regulation, legal process or governmental request; for enforcement of our policies or other legal rights; for investigation, detection, prevention, or to take action against illegal activities, suspected fraud or security issues; for establishment or exercise of our rights.

 

6. Retention of Personal Data

6.1 DHCOINX will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

7. Personal Data we do not process

7.1. We do not collect or store any Personal Data about children under 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children, we will take reasonable measures to promptly delete such data from our records.

7.2. We do not process any Sensitive Personal Data, such as racial or ethnic origin, membership in political parties or political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health, sex life, or sexual orientation.

8. Security of Personal Data

8.1. We use a variety of physical, technical, and administrative security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration, or destruction as well as from other illegal actions of third parties.

9. User Account and data deletion request policy

Any User can request to have their account deleted. To do this a User needs to email us at admin@dhcoinx.com, with the heading “Delete my account and all data”.

Any request to delete the account and data is fulfilled within 30 days.

DHCOINX reserves the right to retain a User’s account and data for up to 90 days from the User's request for account and data deletion. This allows us to comply with any applicable law, regulation, legal process, or governmental request and investigation; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of the User’s or D&H Media Services terms of service, or threats to the security of the Services or the physical safety of any person. DHCOINX will delete the User account and all data when no longer legally obligated or reasonably required to retain it.

 

 10. Transfer of Personal Data outside the European Economic Area (EEA).

10.1. If you are located in the EEA, make a notice that your Personal Data may be transferred to countries outside the EEA.

10.2. We shall take additional measures in order to establish that your Personal Data is treated just as safely and securely as it would be within the European Union and under the Data Protection Legislation as follows:

  • choosing only partners and services that are compliant with the EU standards;
  • limiting access to your Personal Information to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data) including notifying you and the governing authority where DHCOINX is legally required to do so.

10.3. Your Personal Data may also be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

10.4. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

10.5. DHCOINX will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

11. Cookie Policy

11.1. We use at our Website cookies and other technologies in our related services. Cookies do not contain any information that personally identifies you, but Personal Data that we store about you may be linked, by us, to the information stored in and obtained from cookies.

11.2. The setting of cookies can be adjusted in the settings on your browser. Be aware that disabling cookies will affect the functionality of the Website and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the Website.

 

12. Third-party websites

12.1. DHCOINX is not responsible for protecting the client's privacy on websites of third parties, even if the client accesses such websites through links provided on this Website. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

13. Changes to this Privacy Policy.

13.1. We reserve the right to amend the Privacy Policy at any time, for any reason. The most recent Privacy Policy will always be published on our Website. Any changes to the Privacy Policy will be effective as of the moment of its appearance at the Website. The date the Privacy Policy was last modified will be stated on the policy. If we will be required by law to give you advance notice of any changes in our Privacy Policy, then we will do so. Your continued use of our Services shall mean your consent to the changes in the Privacy Policy and your wish to be bound by the updated terms of the Privacy Policy. You are responsible for periodically visiting our Website and reviewing this Privacy Policy to check for any changes.

 

14. How to contact us.

14.1. If you have any questions or concerns about this Privacy Policy or the way in which we handle your personal data, please contact us at: admin@dhcoinx.com.

14.2. We may need to ask you for specific information to confirm your identity and ensure your right to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to anyone who does not have the right to receive it.

 

D&H Media Services Pty Ltd