Privacy Policy

This privacy policy lists the data privacy practices and processes of Brokkr Ltd., a private limited company formed in the British Virgin Islands (“Brokkr”, “we”, “our”, or “us”) and includes detailed descriptions of the third-party services we utilize to collect and process your data. Brokkr is committed to handling your data responsibly and in compliance with all legal requirements. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, blog and other online or offline offerings. To make this Privacy Policy easier all the mentioned offerings are collectively called "Services".

YOUR ACCEPTANCE OF THIS POLICY

By accessing or using the Services, are accepting all aspects of this policy. If we require additional or direct consent from you to further process your personal information, we will ask for your consent for the collection, use, or disclosure of your personal information. We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data. If you do not agree with or you are not comfortable with any aspect of this policy, you should immediately discontinue access or use of our Services.

HOW WE MAY CHANGE THIS POLICY

We may revise this Privacy Policy at any time, so you should review this page periodically. If we update this policy, the “last modified” date will list the month when such update(s) were made. If we make any material changes to this policy, we notify our registered users via email. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

WITH WHOM WE SHARE YOUR PERSONAL DATA

In connection with our Services, to protect our legitimate interests, to fulfill legal requirements, or to perform under agreements we enter into (including our Terms), we may be required to share your personal data with our business partners (described in more detail below), as well as with public authorities in connection with a facially valid official law enforcement request. Specifically, such sharing of data may be necessary to respond to your inquiries, to execute a transaction you request, to provide access to additional information, or to inform you about new Services or offers. Further, to the extent we are legally required by public authorities or courts, we will share your personal data with them or other third-parties. The data sharing may include transfers to companies or organizations in countries without an adequate standard of data protection. In these cases, we transfer personal data in accordance with applicable provisions on the international transfer of personal data, such as, where applicable, the respective provisions of the EU General Data Protection Regulation (“GDPR”). By accessing our Services, you expressly allow us to export data outside of the jurisdiction in which you reside or are located when you utilize the Services.

Personal information we collect

You can use some aspects of our Services, including our websites, and obtain information about our Services without telling us who you are, however, when accessing any website, a user makes a connection with a webserver, which automatically logs and stores certain technical data including: that user’s internet protocol address (“IP Address”), the operating system of that user’s device, the time the website was accessed, or the web browser used to access the site. Logging this data is required in order to make the Services available to you and other users and ensure the functionality of the Services. To the extent we, thereby, process such personal data, we do so based on our legitimate interest to bring you the best possible user experience and to safeguard the security and stability of our systems.

DATA WE COLLECT AND PROCESS TO PROVIDE SERVICES TO YOU, SPECIFICALLY

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

We may collect the following personal information that you provide to us.

  • Registration and Account Creation. We may collect information when you register on our site and create an account, such as name, email address, mailing address, phone number, Ethereum address and (b) other information to help you with your experience.
  • Your Communications with Us. We may collect personal information, such as email address, phone number, Ethereum address or mailing address when you request information about our Services, fill out a form, use live chat, register for our newsletter, request customer or technical support, apply for a job or otherwise communicate with us.
  • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
  • Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

Any wallet you connect to our Services will provide us with such wallet’s: extended public keys, which are used to derive public digital wallet addresses (known as “xPubs”); transaction history; and digital asset balance. Some aspects of the Services may be inaccessible without a connected wallet.

The collection of words associated with a wallet, commonly known as “Seed Phrases” are extremely important because they provide a back-up method to access your wallet. Brokkr does not have access to or store Seed Phrases of its users. We highly encourage you to write down all Seed Phrases upon the time they are issued to you in connection with a wallet, and thereafter store them in a secure location. BROKKR MAY NOT BE ABLE TO ASSIST YOU IF YOU CANNOT ACCESS YOUR WALLET DUE TO A FORGOTTEN/LOST PASSWORD OR SEED PHRASE.

Where such processing of your personal data is not strictly necessary to perform our contractual obligations (such as in connection with providing financial services to you) or at your request, we will use this personal data based on our legitimate interest to: verify your identity; respond to your inquiry; process your registration, applications, or orders; develop, enhance, and improve the Services to bring you the best possible experience; or to safeguard the security and stability of the Services.

DATA WE COLLECT AND PROCESS TO ANALYZE AND IMPROVE THE USE OF THE SERVICES; OUR USE OF COOKIES

Based on our legitimate interest to bring you the best possible user experience, we collect and process certain data to analyze how our users use the Services to gain insight on how we may improve our Services. This data may include information on the type of web browser or device you use to access the website, the geographical region where you access the website, the date and time of your access, and the parts of the website you access.

We also use “Cookies”, which are text files that are downloaded to your computer or mobile device when you visit a website to analyze the use of the website, to optimize our Services, and to enable the use of marketing tools. You can prevent the storage of Cookies on your device and the collection of data. By adjusting your web-browser’s settings accordingly. Note, however, that some functions of the Services may be limited or unavailable if you disable the storing of Cookies.

‍*In connection with the above, we use the following third-party services to collect and analyze the data of our users:*

  • We use Google Analytics, a web analytics service provided by Google. Google Analytics uses Cookies to collect the information required to evaluate your use of our websites to analyze your use of the websites and to provide other services that support our analysis and improvement of the use of the websites, in which we have a legitimate interest. We use Google Analytics only with IP Address anonymization enabled. This means that your IP Address will be shortened beforehand. Only in exceptional cases will the full IP Address be transmitted to a Google server in the USA and shortened there. Accordingly, Google only stores the information collected via Cookies in anonymous form and processes it in aggregated form. For further information on how Google Analytics anonymizes IP Addresses click here. Additionally, you can prevent Google Analytics from using your data by installing a browser add-on to disable Google Analytics here. Lastly, details on data protection and your options in connection with Google Analytics can be found here.
  • We use the tool Hotjar (“Hotjar”) for additional improvements to our Services, in which we have a legitimate interest. Hotjar specifically tracks users' behavior on www.brokkr.finance and doesn’t have access to our trading app. We use Hotjar to analyze our user testing and updating our website and it’s design. More information about data protection on Hotjar can be found here.
  • We also use a tool by Grafana Labs, ("Grafana") to add additional analytics inside of our application, to aggregate data into dashboards to be able provide better Services for our users. The dashboards provide aggregated overview and are anonymized. Grafana privacy practices can be found here.

DATA WE COLLECT AND PROCESS IN ORDER TO COMMUNICATE WITH YOU

If you provide us with your email address, either through our registration process, by inputting it in a field associated with a prompt about being added to our mailing list (e.g., “Let’s stay in touch” or similar language), or otherwise responding to an express request to contact you, we will, based on your consent, send you certain commercial information about Brokkr generally, such as our email newsletter, updates on our Services or other products, blog posts, or other related communications. However, at any time you may opt-out of receiving these communications by utilizing the “unsubscribe” function in any email sent to you by us, or by contacting us here with the subject line “Unsubscribe”. Brokkr does not engage in direct marketing.

In furtherance of the above, we use the following third-party services to communicate with our users:

  • For transactional emails, such as account creation emails, password resets, purchase receipts, and other account notifications, we use Mailchimp (“Mailchimp”). Further information on data protection connected to Mailchimp’s services can be found here.
  • We use Google Tag Manager to generate tags for our websites and applications. These tags help us tailor marketing our Services to potential new customers. In connection with Google Tag Manager, we use advertising technologies by Google’s AdWords platform. Google sets conversion Cookies in accordance with our settings in Google Tag Manager. This is necessary for checking the effectiveness of the respective advertising campaigns. We have a legitimate interest in this. We also use Google Tag Manager to set re-targeting tags. These tags enable us to target users with information about our Services when they visit different websites. For information about your options in connection with Cookies, see the section above titled “Data we collect and process to analyze and improve the use of the Services; use of Cookies”. Lastly, for information on how Google handles personal data can be found here.

HOW WE PROCESS AND PROTECT YOUR PERSONAL DATA; HOW LONG WE STORE IT

We collect, process, and protect your personal data responsibly and in accordance with applicable laws and best practices. We apply adequate technical and organizational security measures, commensurate with the level of known risk, in order to protect the confidentiality and integrity of the personal data we collect when using the Services. Specifically, we store all of the personal data you provide to us in an encrypted fashion and only allow access to certain employees or contractors who are required to perform the purposes for which you provide the personal data to us or as set forth in this policy.

We store your personal data only for as long as this is necessary: we retain this indefinitely to assist our provision and maintenance of our Services, however, subject to the prior sentence, you may request that we delete your account information by emailing us at the address below.

THE RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA

You have certain rights regarding the personal data that we collect and process about you. In particular, generally, you have the following rights:

  • to access or receive certain information about your personal data we collect in machine readable format;
  • to have your personal data rectified;
  • to object to the processing of your personal data, or to ask us to restrict processing; or
  • to have us delete your personal data.

If the GDPR applies to you (i.e., if you reside in the EU or are an EU data subject) and we collect or process your personal data to perform a contract with you (such as providing the Service) or based on your consent, you also have the right to receive a copy of your personal data for the purpose of transferring such data to a third-party.

Please note, however, that your rights are subject to exceptions or derogations. Specifically, we may need to further process and retain your personal data to perform a contract with you, to protect our legitimate interests (such as the establishment, exercise or defense of legal claims), or to comply with legal requirements. To the extent permitted by law, namely, to protect the rights and freedoms of others or to protect our own legitimate interests, we may therefore refuse to satisfy your request or we may satisfy your request with qualifications. Lastly, you have a right to submit a complaint with a competent supervisory authority.

WHO WE ARE AND HOW TO CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

privacy@brokkr.finance