This Coinmotion Oy’s (hereinafter Coinmotion Oy may also be referred to as ‘we’ or ‘us’) privacy policy describes the personal data processing activities of Coinmotion Oy as the controller (hereinafter ‘Privacy Policy’). This Privacy Policy contains Coinmotion Oy’s records of processing activities as the controller, and it also acts as communication from us to our data subjects (hereinafter our data subjects may also be referred to as ‘you’) through which we inform the data subjects of the ways Coinmotion Oy processes their personal data. Thus, this Privacy Policy contains at least the information that Articles 13, 14 and 30 of the EU’s General Data Protection Regulation (679/2016) (hereinafter ‘GDPR’) require of us.

Coinmotion Oy aims to ensure that this Privacy Policy is always publicly, transparently and easily applicable at Coinmotion Oy’s websites.

1) CONTROLLER

Name: Coinmotion Oy
Business ID: 2469683-1
Address: Kauppakatu 39, 40100 Jyväskylä

2) PERSON IN CHARGE OF DATA FILES

Name: Jani Ultamo

Contact details: [email protected]

3) CATEGORIES OF DATA SUBJECTS

Coinmotion Oy’s Privacy Policy concerns the following categories of data subjects:

1. persons who use or wish to use Coinmotion or act as representatives of the legal entities that use or wish to use Coinmotion;
2. persons who use or wish to use Bittiraha or act as representatives of the legal entities that use or wish to use Bittiraha
3. persons who use or wish to use Coinmotion instant or act as representatives of the legal entities that use or wish to use Coinmotion instant;
4. persons who use or wish to use Coinmotion Payments or act as representatives of the legal entities that use or wish to use Coinmotion Payments;
5. persons who use or wish to use Denarium or act as representatives of the legal entities that use or wish to use Denarium;
6. persons who use or wish to use Bittimaatti or act as representatives of the legal entities that use or wish to use Bittimaatti;
7. persons who are employed by Coinmotion Oy or seek employment from Coinmotion Oy; and
8. persons who contact us through email or other similar means.

4) CATEGORIES OF PERSONAL DATA

The data files concerning the data subjects of Sections 3.1) – 3.7) may contain the following categories of personal data:

• contact information, such as full name, address, phone numbers and e-mail addresses;
• nationality, age, gender, title or profession and mother tongue;
• employment history;
• personal identification numbers;
• bank account data;
• cryptocurrency ownership data;
• information relating to our Know Your Customer and anti-money laundering policies, such as the reason for the use of our services, the political status of a person and the identification data of a person;
• user information, such as username, password and other unique identification browsing;
• search information and other information concerning your use of our services;
• information regarding the customer relationship, such as billing and payment information, product-, service- and ordering information, information regarding customer feedback, contacts and cancellation;
• data about your device, such as information about the device you use, the type of your device, your IP-address and various diagnostic data;
• location information, such as GPS-coordinates, data of your wireless connection (SSID) and strength of your Wi-Fi signal; and
• possible other information gathered with the data subject’s consent.

The data files concerning the data subjects of Section 3.8) may contain the following categories of personal data:

• contact information, such as full name, address, phone numbers and e-mail addresses;
• data about your device, such as information about the device you use, the type of your device, your IP-address and various diagnostic data; and
• any other information provided by the person contacting us.

5) PURPOSE OF THE PROCESSING OF PERSONAL DATA

Personal data of the data subjects of Sections 3.1) – 3.6) can be handled for the following purposes:

• management and development of the customer relationship;
• customer service;
• for improving our user experience;
• profiling;
• marketing;
• to prevent, detect and investigate money laundering and terrorist financing and such crimes as were committed to gain the assets or proceeds of crime subject to money laundering or terrorist financing.
• to enable us to comply with our legal and regulatory obligations; and
• analysis and statistics.

Personal data of the data subjects of Section 3.7) can be handled for the following purposes:

• management and development of the employee and jobseeker relationships;
• management of employment contracts and other related matters.
• customer service;
• for improving our user experience;
• to enable us to comply with our legal and regulatory obligations; and
• analysis and statistics.

Personal data of the data subjects of Section 3.8) can be handled for the following purposes:

• management of contacts;
• customer service;
• for improving our user experience;
• marketing;
• to enable us to comply with our legal and regulatory obligations; and
• analysis and statistics.

6) LEGAL BASIS FOR PROCESSING

The controller has the right to process the personal data of the data subjects, depending on the situation at hand, based on the:

• consent received from the data subjects;
• performance of a contract in which the data subject acts as the contact person of the organizer;
• legitimate interests pursued by the controller or by a third party; or
• legal obligation to which the controller is subject.

7) REGULAR SOURCES OF INFORMATION

Information regarding the data subjects are regularly gathered:

• from data subjects themselves via phone, internet, e-mail or in other similar fashion;
• with cookies and other similar technology;
• by Coinmotion Oy’s other Finnish affiliate companies; and
• from the Population Register Center/Population Information System, Posti’s address database, phone companies’ databases and other similar private and public registries.

8) PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

8.1) We shall retain the data of the data subjects of Section 3.1) – 3.6) for a period of five (5) years following the end of customer relationships.

8.2) We shall retain the data of our employees of Section 3.7) for a period of ten (10) years following the end of their employment in our company, because we have a legal obligation to provide our former employees with references during that period.

8.3) We shall not retain the data of the jobseekers of Section 3.7) if the data subjects do not explicitly give us their consent to do so. Having received such a consent, we may retain the data of the data subjects for a period of six (6) months following explicit consent.

8.4) We shall retain the data of the data subjects of Section 3.8) for a period of one (1) year following the contact.

8.5) However, we may retain the data of the data subjects of Sections 3.1) – 3.8) for longer than is described above, where is necessary for the purpose of criminal investigation, pending judicial proceedings or securing the rights of parties subject to the reporting obligation or persons employed by them. The data subject concerned has no right of access to the data gathered.

8.6) The controller inspects annually the necessity of the stored customer data.

9) CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The recipients of personal data may consist of the following categories:

• Coinmotion Oy’s affiliate companies;
• parties who offer cloud services for data storage;
• parties who offer accounting and auditing services; and
• parties who help Coinmotion Oy to fulfill its legal obligations.
• Banking partners and other parties involved in money transfers and transactions

10) REGULAR DISCLOSURE OF DATA AND INFORMATION TRANSFER OUTSIDE OF EU OR THE EUROPEAN ECONOMIC AREA

Some of the recipients of personal data described in Section 9 are located in the United States of America and Australia. When transferring personal data those parties, Coinmotion Oy shall ensure that the personal data is provided adequate security measures, e.g. by ensuring that the receiving party has an EU-U.S. Privacy Shield certificate or that the party has signed a valid standard data protection clause with us.

11) DATA SUBJECTS’ RIGHTS

The data subject has a right to use all of the below mentioned rights.

The contacts concerning the rights shall be submitted to the person in charge of the data file stated in Section 2. The rights of the data subject can be put into action only when the data subject has been satisfactorily identified.

Right to inspect

Having presented the adequate and necessary information, the data subject has the right to know what, if any, data the controller has stored of her/him into this register. While providing the requested information to the data subject, the controller must also inform the data subject of the register’s regular sources of information, to what are the personal data used for and where is it regularly disclosed to

Right to rectify and erasure

The data subject has a right to request the controller to rectify the inaccurate and incomplete personal data concerning the data subject.

The data subject can request the controller to erase the personal data concerning the data subject, if:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• the data subject withdraws consent on which the processing is based on;
• the personal data have been unlawfully processed; or
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

Let it be known that the data subjects’ rights to rectify and erase data does not concern the data which the controller must retain due to its legal obligations.

If the controller does not accept the data subject’s request to rectify or erase the personal data, it must give a decision on the matter to the data subject in a written form. The decision must include the reasons for which the request was not granted. The data subject may refer the matter to the relevant authorities (the Data Protection Ombudsman in Finland).

The controller must inform the party to whom the controller has disclosed the personal data to or has received the personal data from of the rectification or erasure of personal data. However, there is no such obligation where the fulfilment of the obligation would be practically impossible or otherwise unreasonable.

Right to restriction of processing

The data subject can request the controller to restrict the processing of the personal data concerning the data subject where one of the following applies:

• the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
• the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; or
• the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If the controller has based the restriction of the processing of personal data on the abovementioned criteria, the controller shall give a notification for the data subject before removing the restriction.

Right to object

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning her/him for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Right to data portability

The data subject shall have the right to receive the personal data concerning her/him, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or a contract.

Automated individual decision-making, including profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

However, the data subject shall not have the aforementioned right if the decision is:

• necessary for entering into, or performance of, a contract between the data subject and us;
• is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
• is based on the data subject’s explicit consent.

Right to withdraw consent

Where the legal basis for the processing of personal data is the consent of the data subject, the data subject shall have the right to withdraw her/his consent.

12) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

The data subject shall have the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. The complaint can be lodged in the Member State of her/his habitual residence, place of work or place of the alleged infringement.

13) COOKIES

Please refer to our Cookie Notice.

14) PROFILING

We can make customer profiling with a crosscheck method. The data for crosscheck will be gathered from our own databases. We can for example profile customers based on their country codes. Profiling may have effects on the data subject’s right to use our services. The data is being processed by our company employees.

15) SECURITY OF PROCESSING

We implement at least the following technical and organizational measures to ensure appropriate level of safety to the processing of personal data:

• the entry to our servers and other related databases is strictly limited;
• our servers are reduplicated and we keep backup copies of our data, which means that it is easy for us to ensure ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• we have the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
• we use external audits in evaluating the data processing in our systems and all changes to the source code of the production system are reviewed by several people before the code is updated to the production system.

16) DATA PROTECTION PRINCIPLES

Coinmotion Oy uses all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect personal information from unauthorized or inappropriate access, but Coinmotion Oy note that the Internet is not always a secure medium. Coinmotion Oy restricts access to information about data subjects only to the personnel of Coinmotion Oy that need to know the information e.g. for responding to inquiries or requests made by the data subjects.