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Welcome to the Privacy Notice for TitanVault Innovations s.r.o.
TitanVault Innovations s.r.o. respects your privacy and is committed to protecting your personal data.
1. About us
2. Purpose of this Privacy Notice
3. The data we collect about you
4. Lawful basis
5. Purposes for which we will use your personal data
6. Marketing
7. Automated Decision-Making and Data Profiling
8. Disclosures of your personal data
9. International transfers
10. Data security
11. Data retention
12. Your legal rights
13. Glossary
TitanVault Innovations s.r.o. (referred to as "we", "us" or "our" in this Privacy Notice) is the owner of this website, and the controller of the personal data processed through this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.
If you have any questions about this Privacy Notice, our privacy practices, or how to exercise your legal rights, please contact our DPO in the following ways:
Name: Shao Liu Yang
Email address: pearwaga@titanvault.top
Telephone number: +447523601395
TitanVault Innovations s.r.o. address: Varšavská 715/36, Vinohrady, 120 00 Praha 2
This Privacy Notice explains how we look after your personal data, how we collect and process it through your use of our website or when you purchase one of our products or services. We might also collect personal data about you from other sources, such as other companies or publicly available information.
You can find out more in the The Data We Collect About You section below.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing Notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.
We keep our Privacy Notice under regular review. This version was last updated on 6th November 2023. Please contact us for a copy of this notice, or for previous versions, by contacting us at pearwaga@titanvault.top If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know through our website, or by email.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This 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 statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.
Personal data, or personal information, means any information which can be used to identify you. This includes:
It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal data about you. We have grouped these under the headings: Contact, Financial, Identity, Marketing and Communications, Profile, Technical, Transactional, and Usage. More details about these categories are available in the Glossary: Categories of Personal Data.
We might also collect personal data about you from different sources, as set out below.
When you open an account with us, correspond with us by post, phone, email, fill in forms, respond to surveys, take part in online discussions or contact us otherwise, you provide us with Contact Data, including information such as your billing address, email address and telephone number. When you purchase our products or services, or pay for other products or services when using our systems or products or service, you might provide Financial Data such as your bank account, payment card details, wallet address, or tax information.
When you apply for or use our products or services, or register to use our website, you provide us with information about yourself including your name, date of birth, digital identity. You might also include your photo or video form, or other information we require to conduct KYC/AML such as your passport or driving license. We call this Identity Data.
You might also provide information about members of your family, or work, or ask us to contact third parties on your behalf, in order to conduct our KYC and AML checks.
In carrying out KYC and AML checks and a periodic review of that information we may collect Special Categories of Personal Data about you in so far as this identifies you as a politically exposed person. In this connection we may also collect information about criminal convictions and offences. Where you have enabled location or GPS services, we will be able to see your location. We call this Location Data.
When you inform us of your marketing preferences or how you would like to receive information from us, or subscribe to our services, publications or social media, we call this Marketing Data.
When you register with us, you might create an account or profile using information such as a username and password. We call this Profile Data.
As you interact with our website, our systems automatically collect, information about your device, your platform, browser, and the other Technical Data described in the Glossary.
When your devices interact with our website, we may collect data by using cookies, pixels, tracking technologies, server logs and other similar technologies
Information about your transactions, such as payments or transfers made or received, assets held, transaction dates and times, the time taken to make the transfer/payment, currencies, exchange rates, messages sent and received,
Technical Data about your device. We call this Transaction Data. We also collect details of the person or entity you are transacting with (including some of their Identity Data, Technical Data, Financial Data and Contact Data).
How you have used our website, products and services. This includes information about your visit, such as the links you’ve clicked on, through and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page. We call this Usage Data. Information stored on your device, such as your contacts, location, historic use of your device, any information stored on your device, and details of other software or apps you use.
Information about your device and how it connects to other devices and networks and how you connect with the device. This includes the internet protocol (IP) address used to connect your computer to the internet, your login information, the browser type and version, the time zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use. We call this Technical Data.
We might also track your location if location services are enabled on your device. We call this Location Data.
We might also receive Technical Data about you if you visit other websites employing our cookies.
Our cookies will regularly collect this information in order to stay up to date (but only if you have given us permission). Please see our cookie policy below for further details.
When you apply for our use our products or services, or create an account with us, we might receive certain background and identity check information or KYC/AML data from third parties such as credit reference agencies, financial or credit institutions, official registers and databases, fraud prevention agencies and partners who help us to provide our services.
This includes your information to help us check your identity, information about your spouse and family (if applicable in the context of an application) and information relating to your transactions.
In carrying out KYC and AML checks and a periodic review of that information we may collect Special Categories of Personal Data about you in so far as this identifies you as a politically exposed person. In this connection we may also collect information about criminal convictions and offences.
We might receive information about you during the course of the transactions you engage in by using our website, products or services, from counterparties such as:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we might aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we might not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we might have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use your personal data only when we have a ‘lawful basis’ (or valid legal justification) to do so. The lawful bases we commonly rely on are:
The Lawful Basis section in the Glossary below provides more details.
We have set out below how we plan to use your personal data, and the legal bases we rely on to do so. Note that we might process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need additional details.
How we use your personal data
1.Providing our services and products Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transaction We use your personal data when providing our products and services to you, including:
Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transaction:
Managing our relationship with you Data categories: Contact, Identity, Marketing & Communications,
We will use your personal data to:
Lawful basis for Data categories: Contact, Identity, Marketing & Communications:
Administering and protecting our business and website Data categories: Technical
We use your personal data to manage our website including,
Lawful basis for Data categories: Technical:
4. Providing location-based services
Data categories: Location
Where you have enabled location-based services, we can
Lawful basis for Data categories: Location:
Improving our products and services
Data categories: Contact, , Identity,
Location, Transactional.
We use your personal data to help us develop and improve our current products and services. This allows us to continue to provide products and services that our customers want to use.
Lawful basis for Data categories: Contact, Identity, Location, Transactional:
6.Marketing and providing products and services that might interest you
Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transactional.
We use your personal data to do the following:
Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices (the How do you use my personal data for marketing? section below explains how to do this).
Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transactional:
Helping with social interactions Data categories: Contact, Identity, Location, Marketing & Communications
We use your personal data to help with social interactions through our services. Lawful basis for Data categories: Contact, Identity, Location, Marketing & Communications:
Fraud prevention
Data categories: Contact, Identity, We use your personal data to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your account.
Lawful basis for Data categories: Contact, Identity:
9. Meeting our legal obligations, enforcing our rights and other legal uses Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Technical, Transactional. We use your personal data:
You can find out more in the Do you share my personal data with anyone else? section below.
Sometimes, we’re legally required to ask you to provide information about other people. For example, we might ask you to explain:
Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Technical, Transactional:
10. Preparing anonymous statistical datasets We prepare anonymous statistical datasets about our customers’ transaction patterns:
These datasets may be shared internally or externally with others. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.
We’ll provide anonymised statistical information that explains the broad categories of merchants that customers in that country spend their money with. We’ll also provide information about how customers top up their accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify any individual customer.
Lawful basis for Preparing anonymous statistical datasets:
You will receive marketing communications (by post, push notification, email and text message ) from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. Where national laws require us to get your consent to send marketing messages, we’ll do so in advance. We might use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you might want or need, or what might be of interest to you. This is how we decide which products, services and offers might be relevant for you (we call this marketing). You can object to profiling for direct marketing purposes.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can find out more in the Do you share my personal data with anyone else? section below.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We use cookies to analyse how you use our website. For more information about the cookies we use, please see our Cookie Notice below.
We may also use pixels or web beacons in the direct marketing emails that we send to you. These pixels may track whether our email was delivered and opened, and whether links within the email were clicked. They may also allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our email campaigns, and for analytics. You can control whether you receive direct marketing emails by contacting us.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website might become inaccessible or not function properly.
We might make automated decisions about you. This means that we might use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of our services and to ensure decisions are fair, consistent, and based on the right information.
Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a person. You can find out more about this in the What are my rights? section below.
For example, we might make automated decisions about you that relate to:
Our legal basis is one or more of the following:
We might share your personal data with the parties set out below, for the purposes set out in the Purposes for which we will use your personal data section above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Internal: We share your personal data within the ZenoFi Group where they act as processors and joint controllers, to the extent systems, resources and operations are shared. This is to provide you with the best service, send you information about our products and services we think you’ll be interested in hearing about, or to comply with our regulatory requirements. Our legal bases are contract, legal obligation and legitimate interest. The ZenoFi Group has offices in the United Kingdom and Lithuania.
People, wallets or entities you transfer money or assets to: Where you make a payment or transfer from your account, we’ll provide the recipient with your details alongside your transfer (for example, your name, IBAN, wallet address, unique identifier). This is because, like all financial institutions, we’re required by law to include certain information with transfers. Our legal bases are contract and legal obligation. These entities might be located globally, and outside the United Kingdom.
People, wallets or entities who send you money or assets: When you receive a payment or transfer into to your account, we’ll provide the payer or sender with your details (for example, your name, IBAN, wallet address, unique identifier). Our legal bases are contract and legal obligation. These entities might be located globally, and outside the United Kingdom.
Credit reference agencies: when conducting KYC/AML checks or when you apply for credit from us, these agencies might act as processors or joint controllers. Our legal bases are contract and legal obligation. If you are in the United Kingdom, these include Equifax and Experian.
Financial crime prevention service providers, acting as processor and joint controllers. These include identity verification service providers, fraud prevention and financial crime agencies, or other entities required by law or in connection with an investigation. Our legal bases are contract and legal obligation. The entities are located in the UK and elsewhere.
Professional advisors: acting as processor or joint controller including lawyers, bankers, auditors and insurers based in the United Kingdom, Lithuania and elsewhere who provide consultancy, banking, legal, insurance, payroll management and accounting services. Our legal bases are contract and legal obligation.
Government bodies, such as regulators, law enforcement authorities, competition authorities, and tax authorities, acting as processor or joint controller, to check your identity, protect against fraud, keep to laws (including tax laws, anti-money laundering laws, data protection or cyber security laws or any other laws), and confirm that you’re eligible to use our products and services. Our legal basis is legal obligation. These bodies include HMRC (the UK Tax Authority), the FCA (the UK financial authority), the ICO (the UK data regulator), and similar authorities in other countries.
Social media and advertising companies. When we use social media for marketing purposes, we might share your personal data (limited to only your name, email address) to check if you also hold an account with them; to send your our adverts, where we think that one of our new products or services might interest you; to send our adverts to people who have a similar profile to you. When we use advertising partners, we might share your personal data with them as described above, but we hash the personal data before we send it, and the social media platform we share it with is only allowed to use that hashed personal data as described above. Our legal basis is legitimate interests (to ensure our advertising is as effective as possible). The recipients can be located inside and outside the UK, including Ireland and the USA.
Where you ask us to share your personal data with a third party. For example, you might authorise third parties to act on your behalf (such as a lawyer, accountant or family member or guardian under a power of attorney). Our legal basis would be contract, legal obligation or legitimate interest. The entity would be located wherever you had sourced them.
Purchasers of our portfolio or assets: third parties to whom we might sell, transfer or merge parts of our business or our assets. Alternatively, we might seek to acquire other businesses or merge with them. Our legal basis would be contract and legitimate interest.
Suppliers: service providers, including but not necessarily limited to:
Many of our business processes are international, and the parties we interact with are based outside the EU, so your personal data will involve a transfer of data outside the EU.
For example, if you make (or receive) an international transfer, we’ll send (or receive) funds or assets to (or from) banks or wallets outside the EU. We might also send your personal data outside the EU to abide by global legal and regulatory requirements, to provide ongoing support services, to credit reference agencies, fraud prevention agencies, law enforcement authorities or to enable us to provide you with products or services you have requested. Whenever we transfer your personal data outside the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
We have implemented appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include:
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our website or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our web and payment-processing services.
If you use a password for our website, you will need to keep this password confidential. Please do not share it with anyone.
When you use our public services, which includes our social network accounts and our community forum, do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.
How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We might retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes and AML purposes. In some circumstances you can ask us to delete your data. See the section below Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we might use this information indefinitely without further notice to you.
You have the right to be told how we use your personal data. This Privacy Notice is one way in which we provide this information to you. If you ask, we’ll provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.
You have the right to access your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we might need to verify the accuracy of the new data you provide to us.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we might have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
As a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it. If you've closed your account, we might not be able to delete your entire file because these regulatory responsibilities take priority. We’ll always let you know if we can't delete your personal data.
You can object to your personal data being processed where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we might demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you object to us using personal data which we need in order to provide our services, we might need to close your account as we won’t be able to provide the services.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can request that a human person review any automated decision we made about you, where that automated decision significantly affects you.
If you wish to exercise any of the rights set out above, please contact us at pearwaga@titanvault.top Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we might charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We might also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
CATEGORIES OF PERSONAL DATA
Contact Data
Financial Data
Location Data
We might track your location using GPS technology, or collect this data from your device
Marketing Data.
Profile Data
Technical Data
Information on transactions and your use of our services and products and details about payments and transfers to and from you, including:
Usage Data Information about how you use our website, products and services, including:
Last Updated: 6th may 2024
Welcome to the Cookie Notice for TitanVault Innovations s.r.o.
Cookies are text files that are placed on websites. Each cookie includes the name of the website and a unique ID. They can be stored on your browser or the hard drive of your computer if you agree. Cookies track things like how long a visitor spends on our website and what visitors do on our website (which pages they visit and which buttons they click on, for example). Cookies collect this information and share it with the website owner.
Our website may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Some of the cookies we may use on our website are 'persistent' cookies. This means that they remain on your device until you erase them or they expire. The rest of these cookies are 'session' based which are more temporary in duration. This means they will be erased when you close your internet browser.
3. Types of cookies:
4. The cookies we use
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie name: Marketing & Analytics Cookies
Type: Targeting
Purpose:
More information
Time limit: 20 years
Cookie name: Functional Cookies
Type: Functional
Purpose:
More information
Time limit: No time limit
Cookie name: Necessary Cookies
Type: Strictly necessary
Purpose:
More information
Time limit: Length of visit
We share the information collected with our website hosting service, Webflow, Inc. located in the USA.
You can manage your cookies preferences by emailing us at pearwaga@titanvault.top You can also manage your preferences by changing your browser settings on your device to refuse the use of all or some cookies. However, if you block all cookies (including necessary cookies), you may not be able to use all or some parts of our website. You may also find that you are shown information on our website that is less interesting to you.
Please note, other organisations, such as advertising networks, may also use cookies to track you across different websites. We have no control over these cookies. They might include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies: Sum & Substance (3rd Party KYC Tool) is utilised by TitanVault Innovations s.r.o. in order to verify and identify customer identities. They have a separate website to TitanVault Innovations s.r.o. and therefore may present with separate cookies. To deactivate the use of third party cookies, you may visit the relevant page on their website in order to manage the use of these types of cookies.
If we change the cookies we use, we will update this Cookies Policy. You always can find the latest version of this Policy on our website.
If you have any questions or concerns about our use of cookies, please send us an email at pearwaga@titanvault.top
COMPANY DETAILS:
TitanVault Innovations s.r.o
Company Number: 21340986
Address: Varšavská 715/36, Vinohrady, 120 00 Praha 2
