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As used herein, “Personal Information” means any information relating to an identified or identifiable natural person (each, a “Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.
PERSONAL INFORMATION WE COLLECT:
Section 326 of the USA PATRIOT ACT requires all financial institutions to obtain, verify, and record Personal Information that identifies each person who uses Bitcoin or cryptocurrency ATMs/Kiosks. This federal requirement applies to all new customers. This Personal Information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities. What this means for you: when you purchase Bitcoin or any other cryptocurrencies form TheCoinBros,LLC. we ask you for your phone number, name, and other identifying Personal Information.
Personal Information we collect may include the following:
Individual Customer – We attempt to collect, verify, and authenticate the following:
- Mobile phone number;
- Full legal name;
- Dat of birth (“DOB”);
- Proof of identity (e.g., driver’s license, passport or government-issued ID);
- Home address (not a mailing address or P.O. Box); and
- Additional Personal Information or documentation at the discretion of our Compliance Team, including in relation to criminal records or alleged criminal activity (which is special category data as defined in applicable data protection legislation).
HOW WE USE AND SHARE PERSONAL INFORMATION WE COLLECT:
The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve TheCoinBros,LLC.
We may share Personal Information with third-party service providers of the United States who help us operate our platform and systems, and detect fraud and security threats throughout the normal course of our business. Such third-party service providers are subject to strict confidentiality obligations. In addition, we may be compelled to share Personal Information with law enforcement, government officials, and regulators.
For example, we may use your Personal Information to:
- Provide you with our services, including customer support for TheCoinBros;
- Optimize and enhance our services for all customers or for you specifically;
- Conduct anti-fraud and identity verification and authentication checks (you authorize us to share your Personal Information with our third-party service providers, who may also conduct their own searches of publicly available Personal Information about you);
- Monitor the usage of our services, and conduct automated and manual security checks of our services; and
- Create aggregated and anonymized reporting data about our services.
We do not sell customer Personal Information to third parties for the purposes of marketing.
Be aware that bitcoin, ether, and other Digital assets are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public Digital Asset address. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such Personal Information about you. You agree to allow us to perform such practices and understand that we do so.
ACCESS, CORRECTION, RESTRICTION, DELETION AND PORTABILITY OF PERSONAL INFORMATION:
You have the right to ascertain whether we hold your accurate and current Personal Information, to obtain a copy of your Personal Information that you submitted as permitted by law, and to correct any of your data that is inaccurate. You may also request that we inform you of the type of Personal Information we hold with regard to you, subject to restrictions on our providing copies of certain data pursuant to our obligations under BSA and AML regulations and/or data provided to our legal counsel in defense of a claim against us. You may also request that we restrict or delete your Personal Information, subject to the restrictions on data deletion pursuant to relevant data retention and destruction restrictions under applicable laws and regulations, such as those related to the BSA and AML. Finally, in certain circumstances, you have the right to receive the Personal Information you have provided to us in an electronic format and to transmit that Personal Information to another data controller. For data access, correction, restriction, deletion, or portability requests, please email Coinbros@tutanota.com.
When handling a data access, correction, restriction, deletion, or portability requests, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.
QUESTIONS AND COMPLAINTS:
If you have questions or concerns, please feel free to call us at (909) 333-6756 OR email us at Coinbros@tutanota.com.